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 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 ‘ ...
On April 16, 2024 the Deputy Minister of Finance provided general insights into the upcoming 2025 Tax Plan package in the Tax Policy and Implementation Agenda.
The Lower House of the Dutch Parliament has adopted a motion asking the government to propose new legislation with regard to what they call “carried interest”. Specifically, the government was asked t ...
When purely tax-driven and artificial attempts are made to stay (just) outside the formal requirements of Section 10a CITA 1969, the interest deduction can be refused by invoking fraus legis.
Meijburg & Co has updated the overview of the CbCR notification requirements for all countries that have (currently) implemented final CbCR legislation.
Although the method of assessment is less clearly defined than in current qualification policy, the legal forms list may offer more practical certainty.
On December 15, 2023 the Ministry of Finance published a new decree on the allocation of taxing rights in respect of severance payments in an international context. The decree took effect on January 1 ...
The vast majority of work-based residence permits issued in the Netherlands every year are for the purpose of employment as a highly skilled migrant or intra-company transferee. To employ these highly ...
An easy-to-use reference work that will help businesses, institutions and organizations in their accounting practices. The tax rates, premiums and contributions for 2024 have been summarized for your ...
On January 19, 2024 the Dutch Supreme Court clarified the rules applying to the crediting of dividend withholding tax for corporate income tax purposes.
On December 19, 2023 the Upper House of Parliament adopted virtually the entire 2024 Tax Plan package, various other tax bills and a number of tax motions. We have prepared a summary about this.