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Perpetual securities not considered equity for Dutch corporate income tax purposes

In a decision of Friday 15 May 2020, the Dutch Supreme Court confirmed that fixed-to-floating rate perpetual equity securities (“perpetual securities”) should not be considered a “participation loan” (deelnemerschapslening) for Dutch tax purposes. Under D

Stibbe in Amsterdam answers questions from consumers, small business foundations and NGOs about the coronavirus [updated]

In a special Q&A, lawyers from our Amsterdam office share their legal expertise and strive to provide answers to questions put to us by consumers, self-employed persons, enterprises large and small, foundations and NGOs as a result of the corona crisis.

Implementation of new AML Directive and new list of high-risk countries

After discussions in the Dutch Parliament leading to a late implementation of the amendment of the fourth anti-money laundering and anti-terrorism financing directive, the Dutch implementation will most likely be in force before 18 May 2020. In addition,

Reputation assessment to be introduced for UBOs of several regulated institutions

On 21 April 2020, the legislative proposal for the Financial Markets Repair Act 2020 (the “Proposal”) was submitted to Dutch Parliament (Tweede Kamer). The Proposal repairs deficiencies and omissions that have occurred in the implementation in Dutch law o

Financial difficulties due to the coronavirus: what about taxes?

In the context of the coronavirus the Belgian tax authorities have issued aid measures concerning taxation with the aim of supporting enterprises and natural persons facing financial difficulties. This short read, provides an overview of these measures.

OECD issues guidance on the impact of the COVID-19 crisis on tax treaties

As noted in our Short Read of 31 March 2020, multiple states have been implementing travel restrictions and mandatory quarantines in an effort to stop the spread of the corona virus (COVID-19). Governments have also taken measures to mitigate the economic

COVID-19 and the Financial Markets

As COVID-19 spreads across the globe, companies face various legal issues related to the disease and its spread. These issues result in disruption to business, alongside the related regulatory and contractual implications. The crisis is severely affecting

Bill of law on interest and royalties paid to non-cooperative jurisdictions

The Luxembourg Government proposes to introduce the non-deductibility of interest and royalties expenses of a Luxembourg taxpayer towards collective entities located in a blacklisted jurisdiction.

How to meet (Dutch) substance requirements during the COVID-19 pandemic?

Measures taken by multiple jurisdictions in an attempt to stop the spread of the corona virus (COVID-19) affect many people and businesses.

Draft bill of law regarding certain payments to non-cooperative jurisdictions

Luxembourg's Government announces draft bill of law addressing interest/royalties payments to related entities established in a country or territory listed under the EU list of non-cooperative jurisdictions for tax purposes.

DAC 6 introduced under Luxembourg law

On 21 March 2020, the Luxembourg Parliament voted to approve the law implementing the Council Directive (EU) 2018/822 which introduces disclosure obligations for intermediaries and taxpayers of certain reportable cross-border arrangements (the “Law”).

Additional Dutch tax measures to provide relief for economic impact corona crisis

Further to the measures already announced on 12 March 2020, the Dutch government earlier this week announced additional extraordinary measures (both tax and non-tax related) to mitigate the economic impact of the corona crisis. Below we will summarize som

Stibbe advises Rhône Capital and CSM Bakery Solutions

Stibbe has advised private equity firm Rhône Capital and CSM Bakery Solutions on the sale of its CSM Ingredients business to Investindustrial.

Luxembourg tax measures on non-cooperative jurisdictions: EU blacklist updated

The European Union updates non-cooperative jurisdictions list, affecting bill of law nº 7547. From Jan 1, 2021, interest or royalties paid to related enterprises in listed countries won't be tax-deductible.

Stibbe advises Qrf

Stibbe assisted listed regulated real estate company Qrf with the acquisition of the State Archives Bruges through the acquisition of 100% of the shares in RAB Invest NV from Leasinvest Real Estate Comm. VA., for the amount of EUR 20,6 million.

E-book: 'Governance van beloningen in de financiële sector'

Sinds de publicatie van ons e-book ‘Beloningen in crisistijd’ op 22 april 2020 zijn er ontwikkelingen geweest in wet- en regelgeving rond beloningen in de financiële sector. Samen vormen deze de basis van een nieuw e-book over de governance van beloning.

Stibbe advises Schneider Electric

Stibbe advises Schneider Electric, the leader in the digital transformation of energy management and automation, on its strategic investment in Planon.

Dutch Supreme Court: non-resident investment fund eligible for refund of Dutch dividend withholding tax

On 23 October 2020, the Dutch Supreme Court ruled that a non-resident UCITS fund is eligible for a refund of Dutch dividend withholding tax with respect to its investments in the Netherlands if strict criteria are met.

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