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.
In our MTN of February 3, 2023 we informed you about the statutory increase in the rate used for charging interest on tax due on corporate income tax and (interest and royalty) withholding tax assessm ...
As of 2024, the Pillar 2 rules will become a reality within the EU and other jurisdictions worldwide. Under Pillar 2, the Global Anti-Base Erosion (GloBE) rules ensure that large multinational enterpr ...
On Friday, January 27, 2023 a draft bill was published that must introduce a temporary levy on the market revenues from inframarginal electricity production.
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 December 20, 2022 the Upper House of Parliament adopted the 2023 Tax Plan package, various other tax bills and seven tax motions. We have prepared a summary about this.
The Minister of Finance has asked the Dutch Chamber of Commerce to temporarily stop providing information from the UBO register, effective as of November 22, 2022.
Non-litigants will also be governed by a Supreme Court judgment in these litigation proceedings for the years 2017 through 2020 even if they have not filed a request.
The policy statement sets out how rights will be restored in Box 3 and how the new Box 3 income will be calculated according to the flat rate savings option.
