Note 10 Trade and other receivables

At the end of 2016, impairment of trade receivables totalled €12 million (2015: €9 million). The impairment loss on trade receivables recognised in the income statement in 2016 amounted to €4 million (2015: €1 million). For further information, see the credit risk section of note [34]. The other receivables include an amount of €6 million (2015: €13 million) owed by the joint venture Reddyn.

In November 2010, Alliander issued a subordinated perpetual bond loan with a nominal value of €500 million. In the closing two months of 2013, this subordinated perpetual bond loan was redeemed. Under IFRS, an instrument of this kind qualifies as equity. With respect to the periodical payments made to the holders of the bonds issued in 2010, it was assumed that the interest expense would be deductible for corporate income tax purposes.

So far, no agreement has been reached with the Dutch Tax & Customs Administration concerning the tax treatment of this loan. In the ongoing appeal proceedings, the District Court at Arnhem upheld Alliander's appeal in a ruling dated 20 December 2016. The Dutch Tax & Customs Administration has indicated its intention to appeal the decision before the Court of Justice.

In 2016, Alliander settled the corporate income tax assessments for the years 2010–2013. These assessments did not make allowance for the aforementioned deductible interest expense. Based on the advice of external consultants, the Management Board decided to recognise a receivable in respect of the disputed corporate income tax paid in 2016. A similar question hangs over the withholding tax payable on dividends. No withholding tax assessments (final or provisional) have been paid. Again, having consulted outside experts, the Management Board decided not to recognise a provision in this respect.

The total maximum exposure for Alliander is between €20 million and €30 million.