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.
ESG is a trend that will alter the business environment beyond recognition in the near future. To better understand how ESG will impact tax, KPMG Meijburg organized the ESG Tax Seminar: Guidance to ex ...
This report is one of the world’s largest dataset on Family Office compensation and with more than 650 single Family Office professionals participating in its creation, KPMG P ...
On July 6, 2023 a letter was sent to the Lower House of Parliament in which the Deputy Minister of Finance announced that he intends to amend / relax the ruling policy as of the beginning of October 2 ...
De België-Nederland Nieuwsbrief verschijnt maandelijks met uitzondering van juli en augustus. In deze nieuwsbrief gaan wij in op actuele ontwikkelingen op fiscaal gebied in Nederland en België.
The new treaty will apply at the earliest from January 1, 2024 (but probably only from January 1, 2025). We have summarized some important aspects of the new treaty.
The Amsterdam Court of Appeal recently issued a judgment in preliminary relief proceedings focusing on the bank's termination of a banking relationship.
In 2022, KPMG Private Enterprise Tax published a reported titled “Carving a new path: How private companies can contribute to future economic stability”. It strongly suggested that supporting the resi ...