The letter therefore also addressed the previously promised study on a ‘net equity allowance’. Put simply, such a scheme gives companies a tax advantage on shareholders’ equity. By way of illustration: in 2010, an investigation committee proposed to give a bv with a shareholders’ equity surplus a flat-rate deduction of, for example, 4% of that equity.
The net equity allowance is at issue because the cabinet wants to try to treat equity and debt capital more equally for tax purposes. To a certain extent interest on debt capital, such as loans, is now deductible for Corporation tax. Mr Vijlbrief of the Ministry of Finance has said before that this deductibility is ‘a wrong incentive’ and should be further restricted. The study on these aspects is expected to be completed soon, for the letter says it will be delivered ‘in the spring’. Another study to better align entrepreneurs’ tax treatment in respect of income tax and corporation tax is also underway. The Senate requested this, because for the taxation of profit it should not make a difference which legal form the entrepreneur has chosen. The results will come in the first half of 2021.