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.

Read more

News

No Results

Newsoverview (7)

Budget Day 2021: changes to payroll taxes

September 23, 2021
In our memorandum we address the most significant changes proposed for payroll taxes and social security contributions.
Read more

Conditions for NOW 3, changes to NOW 1 and 2 and opening NOW 1 Subsidy Determination Desk

October 9, 2020
The Minister of Social Affairs and Employment informed the Lower House of Parliament on September 30, 2020 about the precise conditions of NOW 3, several changes to NOW 1 and NOW 2 and about the openi ...
Read more

Budget Day 2020: changes to payroll taxes

September 17, 2020
In our memorandum we address the most significant changes proposed for payroll taxes and social security contributions.
Read more

The Netherlands: gradual lifting of travel ban for non-EU citizens as of July 1, 2020 (COVID-19)

July 2, 2020
As of July 1, 2020 the Netherlands will no longer maintain the travel ban for citizens of the following 14 countries: Algeria, Australia, Canada, Georgia, Japan, Montenegro, Morocco, New Zealand, Rwan ...
Read more

Additional agreements about the second Jobs and Economy emergency package (Emergency package 2.0)

May 28, 2020
From a letter sent to the Lower House of Parliament on May 28, 2020, it appears that the government has further consulted with employer and employee organizations in response to Emergency package 2.0. ...
Read more

Upper House adopts 2020 Tax Plan package and bills on ATAD2 and DAC6

December 18, 2019
Along with the adoption of the 2020 Tax Plan package and the bills on the implementation of ATAD2 and DAC6, the Upper House also adopted several motions.
Read more

Budget Day 2019: changes to payroll taxes

September 20, 2019
On Budget Day, September 17, 2019, the Cabinet presented the 2020 Tax Plan package to the Lower House. In this memorandum we address the most significant changes proposed for payroll taxes and social ...
Read more

© 2024 Meijburg & Co is a partnership of limited liability companies under Dutch law, is registered in the Trade Register under number 53753348
and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee.
All rights reserved.