Europe & African region International Tax Newsletter

The Austrian parliament passed legislation that introduces a tax on digital services. Under this new law, a tax on digital advertising will be imposed effective 1 January 2020.

• Read more

KPMG in Austria has prepared a report providing brief summaries of tax developments for August and September 2019.

• Read more
  

The Belgian Constitutional Court issued a decision annulling the annual tax on securities accounts, with effect as of 1 October 2019.

• Read more

Guidance from the tax authority reflects that economic substance questions are to be included in future corporate tax returns.

• Read more

The deadline for organizations to submit information on their ultimate beneficial owners in a new “Register of Ultimate Beneficial Ownership” to be maintained by the Croatian financial authority is 31 December 2019. Failure to comply could result in penalties.

• Read more

KPMG in Denmark prepared a summary of recent tax developments.

• Read more

KPMG’s EU Tax Centre summarizes the most recent implementation updates of the EU MDR rules into Member States’ domestic legislation.

• Read more

The Council adopted a revised EU blacklist of non-cooperative jurisdictions for tax purposes. The EU Finance Ministers agreed to remove the United Arab Emirates and the Marshall Islands from the list.

• Read more

The French government released the finance bill for 2020. The bill includes measures that may affect corporations such as a delay of the scheduled reduction of the corporate income tax “standard” rate for 2020 and 2021 for large companies; a new set of rules to address the use of hybrid instruments and entities in a cross-border context.

• Read more

The European Commission announced that it had decided to send a formal notice to Germany in relation to German legislation with regard to the taxation of distance sales of goods sold through digital marketplaces.

• Read more

Representatives of the governments of Gibraltar and the United Kingdom signed a new income tax treaty.

• Read more

A budget for 2020 was submitted to the Greek Parliament in early October 2019.

• Read more

Ireland's Finance bill 2019 was published.

• Read more

A digital services tax was proposed in a draft law decree earlier in October 2019. However, the final version of the law decree (no. 124 of 26 October 2019) does not include the digital services tax provisions.

• Read more

The president today presented the federal government budget proposals for 2020.

• Read more

A provincial tax court concluded that Italian withholding tax imposed on dividends paid to foreign foundations is discriminatory because Italian foundations benefit from lower taxation on the same dividends.

• Read more

The Luxembourg government presented the 2020 draft budget law. The bill’s main tax measure relates to advance tax agreements issued before 1 January 2015.

• Read more

A new Protocol to amend the method of avoiding double taxation between France and Luxembourg appears to apply the tax credit method to avoid double taxation. According to the text of the new Protocol, the method used to prevent double taxation of French tax residents working in Luxembourg is a “tax credit equal to French tax.”

• Read more

The KPMG member firm in Luxembourg has prepared three reports that consider the possible implications of Brexit on direct tax, on VAT, and on the taxation of global employees.

• Read more

The multilateral instrument (MLI) negotiated under Action 15 of the OECD/G20 base erosion and profit shifting project and signed by Mauritius will enter into force 1 February 2020.

• Read more

The Dutch government intends to amend the liquidation and cessation loss rules for corporate income tax purposes as of 2021, in order to prevent improper use and to broaden the tax base.

• Read more

The president presented the federal government budget proposals for 2020.

• Read more

The Norwegian government presented 2020 budget proposals to the Norwegian Parliament, including measures that would change the Norwegian interest limitation rules.

• Read more

An appointed expert committee in a report presented 30 September 2019 proposed changes to the current scheme for taxation of hydropower producers in Norway.

• Read more

Taxpayers purchasing goods—including electronics, fuels, steel, recyclable materials, car parts, or construction services—need to be aware of a requirement to settle their payments using the split-payment mechanism for VAT purposes.

• Read more

Guidance published in the official gazette provides rules with regard to monthly reporting and remittances of stamp tax (duty).

• Read more

The Court of Justice of the European Union issued a judgment in a case concerning the value added tax treatment of the assignment of a debt that had been recognized in enforcement proceedings.

• Read more

Amendments to the income tax law, approved by Parliament, aim to support small and medium-sized enterprises and the automotive industry; simplify tax calculations; reduce administrative burden; and implement the EU directive for the prevention of tax avoidance with regard to hybrid mismatches.

• Read more

A bill would extend “dividend stripping” provisions to situations when extraordinary dividends are declared on or after 20 February 2019 and are followed by a dilution of a corporate shareholding.

• Read more

A bill would no longer allow tax-neutral transfers of interest-bearing instruments and exchange items between group companies.

• Read more

A proposal would require taxpayers to pay more withholding tax if they fail to renew their declarations and undertakings every five years.

• Read more

The Swedish supreme administrative court announced it is requesting a preliminary ruling from the Court of Justice of the European Union (CJEU) regarding the value added tax (VAT) treatment of supplies from an overseas head office to its branch in Sweden, in a situation when the overseas head office is a member of a VAT group but the Swedish branch is not a member of the VAT group.

• Read more

Companies need to consider what would be certain implications if there is a ”no deal” Brexit—including country-specific information about Sweden.

• Read more

The Swiss Federal Council issued additional guidelines on a proposed reform of the Swiss withholding tax and Swiss stamp tax regimes.

• Read more

The exclusion from the hybrid mismatch rules for regulatory capital instruments has been amended to comply with ATAD.

• Read more

Notice 700/22 includes details of how to request an extension to the MTD digital links soft landing period beyond the current 12 months.

• Read more

The UK Court of Appeal in October 2019 issued its decision in a case concerning a claim for withholding tax on manufactured overseas dividends.

• Read more

The Minister of Finance presented the 2020 budget. There are no changes proposed to the corporate income tax rates, to the rules for tax loss carryforwards, or to the deductions for capital allowances.

• Read more