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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 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.

The aim of this newsletter is to give you an easy-to-read overview of the latest tax updates in Africa. This month’s newsletter includes, amongst others, an update on the tax proposals (including Pillar 2) in Kenya’s 2024 Finance Bill, as well as a summary of grants and tax incentives in Southern Africa.

From the rise of artificial intelligence, ever-expanding globalization, new forms of non-financial reporting, continually changing legislation to the constant shifts in public opinion. How do you overcome these challenges? And above all: how do other corporate tax consultants do that?

Even if the 30% ruling is applied with retroactive effect in the payroll records in 2022 or 2023, employees will still fall under the transitional rules. This was announced by the Dutch tax authorities in its latest position.

We recommend that all parties involved in the issue, resale or redemption of vouchers review the VAT treatment of their activities based on this ruling.

We recommend that all parties involved in the issue, resale or redemption of vouchers review the VAT treatment of their activities based on this ruling.

On April 16, 2024 the Deputy Minister of Finance provided general insights into the upcoming 2025 Tax Plan package in the Tax Policy and Implementation Agenda.

As of this year all payment service providers are obliged to keep a register with cross border payments. The first reporting deadline is April 30.

The Lower House of the Dutch Parliament has adopted a motion asking the government to propose new legislation with regard to what they call “carried interest”. Specifically, the government was asked to tax carried interest at the progressive personal income tax rate (top rate of 49.5%) for private equity structures.