International Tax Europe and Africa - April 2019

This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Europe and Africa Regions between 1 April and 30 April 2019.

Czech Republic Italy Nigeria
South Africa
European Union Luxembourg OECD Sweden
Germany Namibia Serbia Switzerland
Ireland Netherlands
Slovakia United Kingdom


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International Tax Newsletter - Europe & African region

Czech Republic

Tax legislation approved and regulatory update Anti-tax avoidance 1 April 2019

Changes to corporate and individual income tax are reflected in measures that were enacted in the 2019 tax package and generally have an effective date of 1 April 2019. Among others, the new law transposes and implements into Czech tax law the EU Anti-Tax Avoidance Directive.

Tax legislation approved and regulatory update VAT 1 April 2019

VAT measures included in the 2019 tax package generally have an effective date of 1 April 2019.

European Union (EU)

Administrative and case law Free trade agreement 30 April 2019

The CJEU issued an opinion finding that a mechanism for resolution of disputes between investors and EU Member States as provided for by the free trade agreement between the EU and Canada is compatible with EU law.

Administrative and case law Various tax areas  April 2019

The EU Tax Centre prepared a summary of EU tax developments that can have both a domestic and a cross-border impact.


Tax legislation approved and regulatory update VAT 17 April 2019

Depending on the specific structure of a contract and how it is actually implemented, a sale and lease-back transaction may consist of two separate transactions—a delivery and a return or a lease-back as supply of services.


Tax legislation approved and regulatory update Beneficial owner 22 March 2019

The Department of Finance released regulations to set up a Central Register of Beneficial Ownership of Corporates.


Tax legislation approved and regulatory update  Brexit  26 March 2019

A “law decree” provides guidance for various Italian industries and sectors in the event of a “no-deal” Brexit—including specific measures concerning VAT.

Proposed legislation VAT 4 April 2019

The Italian government is expected to discuss a bill that would replace and expand the VAT rules that currently apply to electronic marketplaces for certain types of electronic goods.

Treaties Double taxation treaties  March 2019 

In late March 2019, representatives of the governments of Italy and China signed a new income tax treaty—an agreement for the avoidance of double taxation and to prevent fiscal evasion.


Proposed legislation Corporate income tax / VAT    25 April 2019

The Luxembourg Parliament has passed the 2019 budget law. Among other, the law introduces additional provisions on interest limitation and fiscal unity, the decrease in the global corporate tax rate, as well as the extension of the super-reduced VAT rate (3 percent).

Treaties MLI   9 April 2019

Luxembourg has filed with the OECD its ratification instrument with respect to the list of reservations and notifications made on the Multilateral Instrument.


Proposed legislation  Budget  27 March 2019

The Minister of Finance delivered the budget for 2019-2020 that includes revenue raising measures as well as tax policy and administration reforms.


Tax legislation approved and regulatory update VAT 2 April 2019

In early April 2019, the Dutch Deputy Minister of Finance announced a policy statement concerning the VAT implications of the specific state supervision of investment funds.

Proposed legislation Beneficial owner 4 April 2019

Legal persons and other legal entities will soon be required to register their ultimate beneficial owners (UBOs) under legislation introduced in the Netherlands.

Proposed legislation Corporate income tax 23 April 2019

The Upper House passed a bill that requires certain corporate income tax and dividend withholding tax measures must be applied as if there is no fiscal unity.

Proposed legislation Corporate income tax 17 April 2019

A draft bill would amend the liquidation and cessation loss rules in the Dutch corporate income tax law, and would aim at preventing misuse of the liquidation and cessation loss rules and at expanding the tax base.

Proposed legislation Tax rulings   23 April 2019

The Ministry of Finance, in a letter to the Lower House, announced plans to revise and renew the policy for issuing tax rulings of an “international nature.” Under this revised policy, there would be stricter requirements for international tax rulings.


Treaties MAP 3 April 2019

The Federal Inland Revenue Service released guidelines concerning the mutual agreement procedure (MAP) to resolve income tax treaty-related disputes.


Treaties  Model Tax Convention 25 April 2019

The OECD announced the publication of the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital.


Tax legislation approved and regulatory update Environmental protection levy 19 April 2019

The Decree on criteria for determining environment protection and improvement of environment was published. The Decree was passed in line with the Law on Charges for Usage of Public Goods.

Treaties Double taxation treaties   4 April 2019

There are new developments with regard to Serbia’s network of income tax treaties.


Administrative and case law  State aid  2 April 2019

The European Commission announced opening an investigation into a tax on the food retail sector in Slovakia because of concerns that certain exemptions from the tax afford some retailers a selective advantage over their competitors, in breach of EU state aid rules.

South Africa

Tax legislation approved and regulatory update Foreign remuneration exemption 1 March 2020

Changes to the foreign remuneration exemption will be effective 1 March 2020 and may affect South Africans working temporarily abroad.

Administrative and case law Tax authorities  11 April 2019

Because the SARS missed its revenue collection targets for the financial year ended 31 March 2019 and given the additional pressure with respect to revenue collection, SARS may make greater use of its information gathering authority.

Administrative and case law Petroleum resources royalty 11 April 2019

A formula error has been identified on the mineral and petroleum resources royalty tax return.

Tax legislation approved and regulatory update Dividends tax 5 April 2019

Amendments to the Taxation Laws Amendment Act, 2018 include measures that affect the dividend exemption for a portfolio of a “collective investments scheme in securities”.


Administrative and case law Property tax/State aid  24 April 20199

The Supreme Administrative Court held that the EU state aid rules prohibit Sweden from providing a reduced rate of property tax for wind turbines.

Administrative and case law
VAT 12 April 2019

The Court of Justice of the European Union (issued a judgment in a case concerning the place of supply of courses and seminars for VAT purposes.


KPMG publication Swiss Tax Report 2019 3 April 2019

KPMG’s Swiss Tax Report 2019 compares corporate and income tax rates in 130 countries as well as all 26 cantons.

United Kingdom

Proposed legislation Capital gains tax  12 April 2019

HMRC have launched a consultation on changes to Private Residence Relief. The proposed changes will reduce the relief available on the sale of a home in some circumstances.

Proposed legislation Hybrids  1 January 2019

A proposed amendment to the definition of ‘hybrid capital instrument’.

Administrative and case law Tax judgments  12 April 2019

Different approaches in recent direct and indirect tax judgments.

Administrative and case law Taxpayer data 5 April 2019

The recent decision of the Court of Appeal, coupled with the new Crime Act 2019, represents a consolidation – if not extension – of HMRC’s powers to request information and data which is either outside the jurisdiction or in the possession or control of taxpayers who are offshore.

Administrative and case law CFC 2 April 2019

The European Commission announced its findings that the UK controlled foreign company rules targeting tax avoidance was partly justified and did not constitute state aid to the extent that the tax regime provides for the proper functioning and effectiveness of the relevant tax rules.

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