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 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 ...
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.
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.
Where the ruling practice used to be seen as a fundamental pillar of the Dutch business climate, the Dutch tax authorities now describe preliminary consultation as ‘an important element of its monitor ...
Interest on tax due and late payment interest also often play a role in the adjustment or reassessment of the profit. Sates involved maintain different national rules on interest, which can result in ...
The draft bill contains accompanying measures to avoid the (immediate) levying of corporate income tax, personal income tax and real estate transfer tax.
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 ...
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.