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.
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.
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 ...
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.
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 ...
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 ...
Who will be elected by the members of the Conservative Party? Will it be Boris Johnson or Jeremy Hunt? For the time being, Boris Johnson seems to be the favourite. On 22 July it will be announced who ...
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 ...
