Europe & African region International Tax Newsletter

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.

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

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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.

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

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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.

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

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

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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.

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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.

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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).

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

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

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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.

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

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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.

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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.

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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.

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

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

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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.

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

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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.

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

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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.

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

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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”.

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

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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.

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

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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.

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

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Different approaches in recent direct and indirect tax judgments.

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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.

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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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