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In this issue of Tax Notes International, Ashley Peeters and Michael Molenaars examine a recent tax ruling of the Dutch Supreme Court regarding the qualifications of instruments as debt or equity for Dutch tax purposes.

Stephanie Kleefstra, Linde Respen en Maarten de Bruin bespreken hoe de Wet bronbelasting 2021 een rol kan spelen bij schuldherstructureringen.

Michael Molenaars, Jeroen Smits, Reinout de Boer and Rogier van der Struijk contributed to the Chambers Corporate Tax 2025 – Global Practice Guides.

What does the fund registration process involve, e.g., what documents are required to be filed? What are the consequences for failing to register a fund that is required to be registered in Dutch jurisdiction? Or, What are the types of entities that can b

What duties and potential liabilities should the directors/managers have regard to when managing a company in financial difficulties? Is there a specific point at which a company must enter a restructuring or insolvency process? 

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

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

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

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

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.

In this issue of Tax Notes International, Ashley Peeters and Michael Molenaars analyse key tax considerations related to restructurings in the Netherlands.