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.
On December 22, 2021, the European Commission published its proposal for the next generation of EU own resources. There are from a Tax Sustainability perspective two proposed new resources o ...
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.
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.
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.
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 ...
This is the second edition of our new Tax Update for the Shipping & Offshore sector, in which we inform you about national and international developments, various court decisions, bills and practi ...
The change to the zero VAT rate for the delivery and provisioning of seagoing vessels and the performance of services to seagoing vessels had already been announced in the 2018 Tax Plan and was origin ...
There have been recent developments on the US sanctions against Cuba, Russia and Iran. In addition, various Arab nations recently imposed a boycott on Qatar. Please find set out below an update.
