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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Internet consultation on draft bill VAT adjustment on services to immovable property

March 7, 2024
Based on the proposed draft bill, a VAT adjustment period of approximately five years will apply.

Pro Memoria 2024

January 25, 2024
An easy-to-use reference work that will help businesses, institutions and organizations in their accounting practices. The tax rates, premiums and contributions for 2024 have been summarized for your ...

30% ruling scaled back even further

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As of 1 January 2024, the 30% ruling for highly-skilled employees recruited from abroad will be scaled back even further if the Upper House of Parliament also adopts the bill.

Budget Day 2023: changes to payroll taxes and labor market developments

September 20, 2023
In our memorandum we address the most significant changes proposed for payroll tax and social security contributions.

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.

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.

CESOP: as of 2024 cross-border payments must be reported for VAT purposes; bill presented to Lower House of Parliament

October 26, 2022
Virtually all of the EU rules on this have become an integral part of the bill that was presented to the Lower House of Parliament on October 24, 2022.

Changes to corporate income tax loss set-off as of January 1, 2022, BIK withdrawn

June 1, 2021
On Friday, May 28, 2021 the caretaker government announced that the changes to the corporate income tax loss set-off can take effect as of January 1, 2022. It was also announced that the Job related I ...

Lower House of Parliament adopts 2021 Tax Plan package and bill on the Liquidation and Cessation Loss Schemes Limitation Act

November 13, 2020
We have briefly outlined the adopted tax amendments and a selection of the adopted motions.

Legislative proposals on tightening CIT loss set-off and on Job-related Investment Allowance presented to Lower House

October 6, 2020
On October 5, 2020 the government presented two Memorandums of Amendment to the bill on the 2021 Tax Plan to the Lower House of Parliament. These memorandums had been announced on Budget Day.

Budget Day 2020: changes to payroll taxes

September 17, 2020
In our memorandum we address the most significant changes proposed for payroll taxes and social security contributions.

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