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.
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 ...
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 ...
An easy-to-use reference work that will help businesses, institutions and organizations in their accounting practices. The tax rates, premiums and contributions for 2022 have been summarized for your ...
The proposals include raising the top corporate income tax rate to 25.8% and tightening the generic interest deduction limitation by reducing the deduction percentage from 30% to 20% of the EBITDA for ...
By letter to the Lower House of Parliament dated August 30, 2021 the caretaker government announced that as of October 1, 2021 the generic relief and recovery package would largely end.
The extension of the relief package means, among other things, that the NOW and the TVL will also be available to businesses in the third quarter of 2021.
On January 21, 2021 in a letter sent to the Lower House of Parliament the government announced that the current relief and recovery package for the economy and labor market would again be expanded.
