Important judgment on tax classification of financial instrument

On May 17, 2024 the Dutch Supreme Court rendered an important judgment on the tax qualification of a financial instrument that was issued by a company established in France in 2007. It concerned the ‘obligation remboursable en actions’ (hereinafter: ORA). The question was whether the instrument had to be regarded as equity (capital) or debt capital (loan) for the purposes of the Corporate Income Tax Act 1969. Although the dispute focused on the question whether the costs related to the issue of the instrument were allocable to a Dutch permanent establishment of the French company, the Supreme Court judgment potentially has a much broader scope.

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Tax changes announced in the 2023 Spring Memorandum

May 4, 2023
In particular, property owners, businesses faced with business successions and Box 3 investors will experience the effect of these plans.
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Amendment of VAT policy statement: broader application of asset management exemption

November 3, 2021
On November 2, 2021, the updated Specific State Supervision Policy Statement of the Deputy Minister of Finance was published. The updating of the original policy statement was necessary due to Supreme ...
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Tax Update Shipping & Offshore - September 2019

September 4, 2019
This is the third edition of our Tax Update for the Shipping & Offshore sector, in which we inform you about national and international developments, various court decisions, bills and practical e ...
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Tax Update Shipping & Offshore No. 2 - June 2019

June 28, 2019
This is the second edition of our new Tax Update for the Shipping & Offshore sector, in which we inform you about national and international developments, various court decisions, bills and practi ...
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Tax Update Shipping & Offshore - Mei 2019

May 9, 2019
This is the first edition of our new Tax Update for the Shipping & Offshore sector, in which we inform you about national and international developments, various court decisions, bills and practic ...
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VAT policy statement on specific state supervision of investment funds

April 8, 2019
On April 1, 2019, the Deputy Minister of Finance (hereinafter: Deputy Minister) published the Specific State Supervision Policy Statement, effective April 2, 2019. In this policy statement the Deputy ...
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