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.
As the winner of the Meijburg Art Commission, Popel Coumou was asked to create a piece for the Meijburg art collection. Her work will be given pride of place at the Meijburg & Co head office befor ...
The most important changes are the incorporation of the results of the OECD’s BEPS project and the source exemption that was introduced into the Corporate Income Tax Act 1969 in 2012.
In recent years the public debate about corporate social responsibility (CSR) and taxation has seen an upsurge with the public, including civil society organizations and authorities (including the EU ...
The changes to the Decree are mainly a reaction to the changes made to the OECD guidelines in respect of financial transactions, intra-group services and recent OECD publications on the treatment of g ...
The new Dutch Transfer Pricing Decree was published on July 1, 2022. The new decree focuses on recent developments that have resulted in changes to the OECD Transfer Pricing Guidelines but also ...
The policy statement sets out how rights will be restored in Box 3 and how the new Box 3 income will be calculated according to the flat rate savings option.
De KPMG Belgium-Holland Desk nieuwsbrief verschijnt maandelijks met uitzondering van juli en augustus. In deze nieuwsbrief gaan wij in op actuele ontwikkelingen op fiscaal gebied in Nederland en Belgi ...
This is the first Tax Update for the Shipping & Offshore sector for 2022. A bit later than usual because the focus in the first half of the year has been on developments surrounding Pillar 2 and t ...
