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.

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News

Newsoverview (9)

Lower House of Parliament adopts various amendments and motions during vote on 2024 Tax Plan package

October 27, 2023
On the day the Lower House went into recess for the upcoming elections, the Members of Parliament made significant changes to the 2024 Tax Plan.
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Tax measures for 2024

September 19, 2023
The main features of the proposed measures are addressed in our memorandum. We have also prepared a two-page overview of the measures.
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The 2024 Tax Plan on two pages

September 19, 2023
We have prepared a two-page overview of the measures contained in the 2024 Tax Plan package.
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Upper House adopts 2023 Tax Plan package and other tax bills

December 21, 2022
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.
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The 2023 Tax Plan on two pages

September 20, 2022
We have prepared a two-page overview of the measures contained in the 2023 Tax Plan package.
Read more

Tax measures for 2023

September 20, 2022
The main features of the proposed measures are addressed in our memorandum. We have also prepared a two-page overview of the measures.
Read more

Brexit Update: EU grants delay until January 31, 2020

October 31, 2019
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 ...
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Dutch Lower House of Parliament passes Bill on ratification of the MLI

February 13, 2019
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 ...
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Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the Netherlands and other countries

June 9, 2017
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 ...
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