Netherlands confirm favourable tax treatment of AT1s

Author: | Published: 6 Oct 2014

René van Eldonk (tax partner) and Steven den Boer (senior tax associate) at Simmons & Simmons in Amsterdam.

From a regulatory perspective, additional tier 1 capital (AT1) must meet the EU-wide regulatory requirements set out in the Capital Requirements Directive and the Capital Requirements Regulation (CRR), jointly known as CRD IV. From a tax perspective, the treatment of AT1 for banks and certain investment firms is not yet consistent across all European jurisdictions. Needless to say, today’s global banking industry requires a level-playing field across the EU, although this could take some time to achieve.

The Netherlands has now become one of the first jurisdictions to confirm the favourable tax treatment of AT1 issued by banks.

Tax treatment of AT1 for banks

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