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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De NieuwsFlits WOZ en lokale belastingen besteedt aandacht aan interessante ontwikkelingen en rechtspraak en verschijnt twee keer per jaar. Hierbij presenteren wij u de tweede editie van 2023.
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The Netherlands is thus the first EU Member State to have submitted a bill to transpose EU Directive 2022/253 of December 14, 2022 into national legislation.
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De nieuwsbrief WOZ en gemeentelijke heffingen besteedt aandacht aan interessante ontwikkelingen en rechtspraak en verschijnt twee keer per jaar. Hierbij presenteren wij u de eerste editie van 2023.
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 ...