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.
On December 22, 2021, the European Commission published its proposal for the next generation of EU own resources. There are from a Tax Sustainability perspective two proposed new resources o ...
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 ...
As the end of the year is fast approaching, many organizations will soon start preparing their year end financial statements. The announced 2022 Tax Plan may have a significant impact on those financi ...
The proposals include raising the top corporate income tax rate to 25.8% and tightening the generic interest deduction limitation by reducing the deduction percentage from 30% to 20% of the EBITDA for ...
Among other things, the possibilities for setting off holding company losses have been limited and the permanent establishment concept has been expanded for the purposes of withholding tax on interest ...
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 ...