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.
Tax Management Consulting
Navigating tax and statutory compliance within the current intricate economic and regulatory landscape is a formidable undertaking. The rapid pace of globalization, evolving tax legislation, shifts in accounting standards, and heightened expectations from tax authorities are all contributing to the mounting pressures on tax and finance departments. All the while, tax departments are confronted with the daunting task of delivering enhanced reporting and compliance outcomes within increasingly constrained timelines.
KPMG België-Nederland desk
De KPMG België-Nederland desk is onderdeel van de tax en legal praktijk van KPMG Meijburg & Co in Nederland. Haar voornaamste doelstelling is het adviseren en bijstaan van Nederlandse cliënten met belastingplicht in België, alsook in België wonende en gevestigde cliënten met belastingplicht in Nederland.
Tax measures in the general coalition agreement
On May 15, 2024 the four coalition parties PVV, VVD, NSC and BBB published their general agreement ‘Hope, Courage and Pride’. The general agreement and the budgetary appendix provide insight into the main features of the tax plans of the new coalition government. In this memo we discuss the tax measures.