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 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 ...
As of July 1, 2020 the Netherlands will no longer maintain the travel ban for citizens of the following 14 countries: Algeria, Australia, Canada, Georgia, Japan, Montenegro, Morocco, New Zealand, Rwan ...
From a letter sent to the Lower House of Parliament on May 28, 2020, it appears that the government has further consulted with employer and employee organizations in response to Emergency package 2.0. ...
On January 31, 2020 the United Kingdom left Europe. A withdrawal agreement (‘deal’) was negotiated under which UK citizens and their family members who lawfully resided in the Netherlands before the B ...
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 ...