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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European Commission’s response to the OECD Pillar 2 model rules

December 23, 2021
On December 22, 2021, the European Commission published a proposed EU directive to incorporate Pillar Two into EU law. The rules generally mirror the OECD model rules released on December 20, 2021 but ...
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OECD publishes Global Anti-Base Erosion Model Rules (Pillar 2)

December 20, 2021
On December 20, 2021 the OECD published the Global Anti-Base Erosion (‘GloBE’) Model Rules, also known as Pillar 2. The GloBE Rules aim to impose a global minimum tax of 15% on multinational enterpris ...
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Article: Squaring away the total cost of tax compliance using SAP S/4 HANA - Key considerations for tax decision makers

December 9, 2021
Many organizations are moving towards SAP S/4 HANA. The implementation of this new SAP backbone provides a once in a decade opportunity to increase tax compliance while at the same time reducing assoc ...
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Getting tax data right with compliance by design

June 4, 2021
Many tax teams spend the bulk of their time dealing with tax data — finding it, correcting it, reconciling it and formatting it for tax reporting and other compliance needs. But processes like these a ...
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Taking stock: BEPS Action Plan as it relates to the ‘control over risk’ concept

March 18, 2021
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Article: The hidden engine for future-proofing tax management

February 26, 2021
In order to stay tax compliant and capture tax opportunities in an increasing digital society, instant access to good quality tax data is essential. In this article our specialists: Alexander Zegers a ...
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