Note 10 Trade and other receivables

At the end of 2017, impairment of trade receivables totalled €9 million (2016: €10 million). The impairment loss on trade receivables recognised in the income statement in 2018 amounted to €2 million (2017: €1 million). For further information, see the credit risk section of note [34].

The other receivables include an amount of €17 million (2017: €22 million) owed by the non-controlling interest 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. It was assumed that the periodic payments made to the holders of the bonds issued in 2010 would count as deductible interest expense for the purposes of corporate income tax. To date no agreement has been reached with the Dutch Tax & Customs Administration concerning the tax treatment of these loans. In the appeal proceedings, the District Court at Arnhem declared Alliander’s appeal well-founded in a ruling dated 20 December 2016. The case was taken to the Arnhem-Leeuwarden Court of Appeal that upheld the District Court’s decision in a ruling given on 12 June 2018. The Dutch Tax & Customs Administration is seeking to have the Appeal Court ruling overturned in cassation by the Supreme Court.

In 2016 and 2017, assessments for corporate income tax were imposed in respect of the period 2010-2013 which did not allow for the above 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. 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. As at year-end 2018, the total maximum exposure for Alliander including interest, was €38 million.