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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Bill on Share Option Rights Tax Scheme (Amendment) Act not changed in substance

April 5, 2022

The Lower House of Parliament had doubts about both the costs of enforcement and the generic application of the bill. It was therefore decided to stay the bill and examine it further.

NL-Africa Tax Desk newsletter – March 2022

March 31, 2022

The aim of this newsletter is to give you an easy-to-read overview of the latest tax updates in Africa. This month’s NL-Africa Tax Desk newsletter includes summaries of the tax measures in the budg ...

KPMG Belgium-Holland Desk Newsletter | March 2022

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De KPMG Belgium-Holland Desk nieuwsbrief verschijnt maandelijks met uitzondering van juli en augustus. In deze nieuwsbrief gaan wij in op actuele ontwikkelingen op fiscaal gebied in Nederland en Belgi ...

NieuwsFlits WOZ en lokale belastingen – 1st quarter 2022

March 24, 2022

De Nieuwsbrief WOZ, lokale belastingen besteedt aandacht aan interessante ontwikkelingen en rechtspraak en verschijnt twee keer per jaar. Hierbij presenteren wij u de tweede editie van 2021 ...

Pillar 2: verheven verstand aan het eind van de cyclus? - lees artikel

March 18, 2022

EU sanctions against Russia

March 10, 2022

The European Union (EU) has announced significant new sanctions and export control regulations related to Russia. To comply with the new regulations, action may be required.

NL-Africa Tax Desk newsletter – February 2022

February 28, 2022

The aim of this newsletter is to give you an easy-to-read overview of the latest tax updates in Africa.

Pillar Two – impact on the maritime industry

February 18, 2022

On December 20, 2021, the OECD published the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) report, involving 137 countries. This one-pager provides insights into specialists view on t ...

Ministry changes stance on severance paid to cross-border workers

February 14, 2022

The Dutch Ministry of Finance has issued new guidance on the allocation of the right to tax severance payments of cross-border workers.

Collective decision on Box 3 class-action appeal

February 8, 2022

On Friday, February 4, 2022 the tax inspector issued a collective decision on the class-action appeal against the Box 3 tax regime for the years 2017 through 2020.

Introduction of corporate income tax in the United Arab Emirates

February 2, 2022

Barring Bahrain, the UAE has introduced the lowest corporate income tax rate within the Gulf Cooperation Council (GCC) region at a standard rate of 9%

Blog: Pillartalk

February 2, 2022

This blog considers the responses to pillar Two seen to date and the impact that the introduction of QDMTT might have on policy behaviours.

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