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.

Read more

News

Newsoverview (37)

Brexit and import: after principles also pragmatism

October 14, 2020
With January 1, 2021 fast approaching, companies exporting to the UK are eagerly looking for answers and solutions.
Read more

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.
Read more

Brexit: implications for frontier workers

September 30, 2020
The UK government recently published new policy for all EU frontier workers who work in the United Kingdom.
Read more

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.
Read more

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 ...
Read more

Brexit: right of UK citizens to reside in the Netherlands

February 19, 2020
On January 31, 2020 the United Kingdom left Europe. A withdrawal agreement (‘deal’) was negotiated under which UK citizens and their family members who lawfully resided in the Netherlands before the B ...
Read more

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 ...
Read more

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 ...
Read more

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.
Read more

Brexit Update: EU grants delay until January 31, 2020

October 31, 2019
After a long period of silence, there has been a rapid succession of Brexit developments. Our Brexit taskforce, comprising Brexit specialists from KPMG Meijburg & Co and KPMG, would like to update ...
Read more

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 ...
Read more

“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 ...
Read more

© 2024 Meijburg & Co is a partnership of limited liability companies under Dutch law, is registered in the Trade Register under number 53753348
and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee.
All rights reserved.