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 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.
Many companies are not aware that retrospective intercompany transfer pricing adjustments could potentially impact the customs valuation of goods imported into the EU. It is therefore imperative that ...
In this edition of the FS Tax newsletter we discuss two important judgments by the Court of Justice of the European Union in VAT cases: firstly, in the A Oy case, the Court established that co-lo ...
In July, EU heads of government reached agreement on the largest-ever EU recovery package to mitigate the consequences of the corona recession. The agreement includes new environment-related measures ...
As of July 1, 2020 the Netherlands will no longer maintain the travel ban for citizens of the following 14 countries: Algeria, Australia, Canada, Georgia, Japan, Montenegro, Morocco, New Zealand, Rwan ...
Recently, agreement was reached at the EU level on postponing by six months the deadline(s) for notifying reportable cross-border arrangements to the Dutch tax authorities under the Mandatory Disclosu ...
On Thursday June 11th, KPMG Meijburg & Cos transfer pricing team organized a webcast to share the first experiences regarding transfer pricing issues in the context of the COVID-19 crisis. We have ...
From a letter sent to the Lower House of Parliament on May 28, 2020, it appears that the government has further consulted with employer and employee organizations in response to Emergency package 2.0. ...
