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.
Recently, the OECD released a public consultation document on Amount B under Pillar One. The Inclusive Framework aims to complete its remaining work in time for the final report on Amount B to be ...
If you have not yet filed a personal income tax return for 2022, you can minimize the interest on tax due by requesting an (additional) provisional tax assessment.
An easy-to-use reference work that will help businesses, institutions and organizations in their accounting practices. The tax rates, premiums and contributions for 2023 have been summarized for your ...
On January 24, 2023 Deputy Minister of Finance Mr. Van Rij clarified in a policy statement the scope of one of the measures to combat transfer pricing mismatches.