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.
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 ...
An internet consultation on a draft bill to abolish the property transfer tax concurrence exemption for share transactions was launched on February 27, 2023.
In our MTN of February 3, 2023 we informed you about the statutory increase in the rate used for charging interest on tax due on corporate income tax and (interest and royalty) withholding tax assessm ...
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 ...
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.
The proposal from the European Commission covers three issues: (1) Digital Reporting Requirements (2) the VAT treatment of the platform economy and (3) changes to e-commerce rules and a ‘single VAT re ...
