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.
As of 1 January 2024, the 30% ruling for highly-skilled employees recruited from abroad will be scaled back even further if the Upper House of Parliament also adopts the bill.
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 ...
After a long period of silence, there has been a rapid succession of Brexit developments. Our Brexit taskforce, comprising Brexit specialists from KPMG Meijburg & Co and KPMG, would like to update ...
This is the third edition of our Tax Update for the Shipping & Offshore sector, in which we inform you about national and international developments, various court decisions, bills and practical e ...
In anticipation of a possible ‘no-deal’ Brexit, the Deputy Minister of Justice and Safety has published withdrawal rules for citizens of the United Kingdom and their family members who lawfully reside ...
On February 12, 2019 the Dutch Lower House of Parliament passed the Bill for the ratification of the Multilateral Convention (“MLI”) to Implement Tax Treaty-Related Measures to Prevent Base ...
‘No-deal scheme’
The government has decided that UK citizens and their family members who lawfully reside in the Netherlands before Brexit will also retain their right of residence in the event of ...
On June 7, 2017, the Dutch Minister of Finance Dijsselbloem and other high-level representatives of 67 countries representing 68 jurisdictions signed the Multilateral Convention (“Multilater ...