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.
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 ...
As of Q1 2023 Alternative Investment Fund Managers (AIFMs) and non-EU fund managers who have notified Alternative Investment Funds (AIFs) for marketing in accordance with Articles 36 and 42 of the Alt ...
On August 22, 2022 the District Court of Amsterdam rendered judgment in a case concerning the termination of the banking relationship .The Court ruled that the termination by the bank of the banking r ...
The District Court of Overijssel recently rendered a judgment in respect of a dispute between an owner of a floating solar park (the plaintiff) and the tax officer of the joint tax office Lococensus-T ...
Since the 1st of January 2022 only a limited amount of GBP and JPY London IBOR’s (“LIBOR”) are published (the so called “synthetic LIBOR’s). The UK’s Financial Conduct Authority has clarified that the ...
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 ...
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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.