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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Budget Day 2021: changes to payroll taxes

September 23, 2021
In our memorandum we address the most significant changes proposed for payroll taxes and social security contributions.
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Tax measures for 2022

September 21, 2021
The main features of the proposed measures are addressed in our memorandum. We have also prepared a two-page overview of the measures.
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The 2022 Tax Plan on two pages

September 21, 2021
We have prepared a two-page overview of the measures contained in the 2022 Tax Plan package.
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Taking stock: BEPS Action Plan as it relates to the ‘control over risk’ concept

March 18, 2021
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Tax Update Shipping & Offshore - October 2020

October 6, 2020
Welcome to the third Shipping & Offshore Update of 2020, in which we inform you about global developments that may be important for businesses throughout the entire sector.
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Tax Update Shipping & Offshore - June 2020

June 9, 2020
Welcome to the second Shipping & Offshore Update for 2020, in which we inform you about developments around the world that could be relevant for companies throughout the entire industry.
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BEPS 2.0 Update: A new tax system for the digital era

March 2, 2020
On 24th of October, 2019, the roundtable session 'BEPS 2.0 Update' took place at KPMG Meijburg & Co. As a result, a report was made with interesting findings and feedback on the OECD consultation ...
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OECD Update: 'Unified Approach' promising for acceptance

February 2, 2020
On 31st of January, 2020, the OECD gave an update on the outline for a global taxation of multinationals: 'Unified Approach'. Jaap Reyneveld, partner at KPMG Meijburg & Co: “It looks like the 'Uni ...
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Major changes EU VAT and e-commerce 2021

December 10, 2019
New VAT rules for e-commerce will be introduced in the European Union (EU) as of January 1, 2021. In this blog Max van de Ven, Andy van Esdonk and Giancarlo Stanco, of KPMG Meijburg & Co, each sha ...
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State aid: Commission approves prolongation of amendments to the Dutch tonnage tax scheme

November 19, 2019
The European Commission has authorised, under EU State aid rules, the prolongation of three amendments to the Dutch tonnage tax regime until 31 December 2028.
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Tax Update Shipping & Offshore - September 2019

September 4, 2019
This is the third edition of our Tax Update for the Shipping & Offshore sector, in which we inform you about national and international developments, various court decisions, bills and practical e ...
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“An aging population and digitization are eroding the tax base.”

September 2, 2019
A digitizing economy and an aging population are creating financial problems for governments and forcing them to look at the financing of public expenditure over the longer term. In other words, the s ...
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