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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KPMG Belgium-Holland Desk Newsletter | Mei 2022

May 25, 2022
De KPMG Belgium-Holland Desk nieuwsbrief verschijnt maandelijks met uitzondering van juli en augustus. In deze nieuwsbrief gaan wij in op actuele ontwikkelingen op fiscaal gebied in Nederland en Belgi ...
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KPMG Belgium-Holland Desk Newsletter | April 2022

April 28, 2022
De KPMG Belgium-Holland Desk nieuwsbrief verschijnt maandelijks met uitzondering van juli en augustus. In deze nieuwsbrief gaan wij in op actuele ontwikkelingen op fiscaal gebied in Nederland en Belgi ...
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KPMG Belgium-Holland Desk Newsletter | March 2022

March 24, 2022
De KPMG Belgium-Holland Desk nieuwsbrief verschijnt maandelijks met uitzondering van juli en augustus. In deze nieuwsbrief gaan wij in op actuele ontwikkelingen op fiscaal gebied in Nederland en Belgi ...
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European Commission’s response to the OECD Pillar 2 model rules

December 23, 2021
On December 22, 2021, the European Commission published a proposed EU directive to incorporate Pillar Two into EU law. The rules generally mirror the OECD model rules released on December 20, 2021 but ...
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OECD publishes Global Anti-Base Erosion Model Rules (Pillar 2)

December 20, 2021
On December 20, 2021 the OECD published the Global Anti-Base Erosion (‘GloBE’) Model Rules, also known as Pillar 2. The GloBE Rules aim to impose a global minimum tax of 15% on multinational enterpris ...
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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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“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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“In a digital world, we don’t just tax profits in the country where a business has a physical presence.”

August 27, 2019
Most international businesses pay taxes via local offices (permanent establishments) on profits they realize in other countries. But in today’s digital economy there is often no such thing as a perman ...
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“Consumers are now digital resources that are mined without being paid for.”

August 26, 2019
The current tax system is no longer adequate because it is not designed for digital business models like Airbnb, Uber, or Amazon. This gives rise to international tax debates, which sometimes raise th ...
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