Note 10 Trade and other receivables

At the end of 2019, impairment of trade receivables totalled €10 million (2018: €9 million). The impairment loss on trade receivables recognised in the income statement in 2019 amounted to €1 million (2018: €2 million). For further information, see the credit risk section of note [34].

The other receivables include an amount of €8 million (2018: €17 million) for non-controlling interests.

The current financial assets concern the current portion of long-term receivables, which are made up primarily of a receivable from the City of Amsterdam relating to the Spaklerweg site. See note [7].

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 a deductible interest expense for the purposes of corporate income tax. 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. A decision by the Supreme Court is expected in early 2020.

In 2016 and 2017, Alliander paid its corporate income tax bills for the 2010-2013 period, not factoring in the aforementioned deductible interest expense. Aside from that, the outcome of the dispute with the Dutch Tax & Customs Administration has an impact on the timeliness of the offset of losses. Based on the advice of external consultants, the Management Board has decided to recognise a receivable in respect of the disputed corporate income tax paid in 2016 and 2017. A similar question hangs over the withholding tax payable on dividends. No withholding tax assessments (final or provisional) have been paid. Having again consulted outside experts, the Management Board decided not to recognise a provision in this respect. Total maximum exposure for Alliander is approximately €38 million.