Recent Articles

June 2024

17 Jun - EU: Toll manufacturer does not constitute a fixed establishment for VAT purposes (CJEU judgment)

17 Jun - Germany: Ministry of Finance releases draft regulation for implementing e-invoicing mandate

17 Jun - Poland: Draft legislation amending VAT for small enterprises

14 Jun - Poland: Draft legislation amending real estate tax regime announced

14 Jun - Cyprus: Extended deadline for payment of central body for equal burden sharing fee on transfers of real estate, shares

12 Jun - Netherlands: Report to Parliament on investigation into REIT regime

12 Jun - Sweden: Report on government study of “3:12 rules”

12 Jun - Sweden: Report on government study of interest deduction limitation rules

11 Jun - Czech Republic: Amendment to Income Tax Act in response to new Accounting Act

11 Jun - Netherlands: “Box 3” (wealth tax) regime also contrary to EU law because flat-rate returns still in use (Supreme Court decision)

11 Jun - Poland: Foundation grants not charged into VAT base; UK pension benefits not exempt; financing fees fully includible; real estate tax base (Supreme Administrative Court decisions)

11 Jun - Poland: Postponement of e-invoicing mandate signed by president

7 Jun - Cyprus: Withholding tax and contribution declarations due 31 July 2024

6 Jun - Poland: Certain web services not subject to restrictions of corporate income tax law; settling costs of R&D activities (court decisions)

6 Jun - UK: Overview of employee share plan reporting, annual return filing deadline is 6 July 2024

6 Jun - UK: Tax statements from main political parties ahead of general election on 4 July 2024

5 Jun - Cyprus: Tax treatment of premiums and medical plans

5 Jun - EU: Formal notices sent to member states for failure to exchange information required under DAC7

5 Jun - Germany: Transactions within VAT groups may be VAT-exempt; other VAT developments

4 Jun - Greece: New code of tax procedures revises tax system

3 Jun - Czech Republic: Amendment to investment companies and funds law passes Senate

3 Jun - Spain: Excise duty on hydrocarbons infringes EU Directive for taxation of energy products and electricity (CJEU judgment)

May 2024

30 May - Italy: Certain additional obligations on online service providers not allowed under EU law (CJEU judgment)

30 May - Poland: Intra-community VAT supply of construction materials; issuance of invoice for bad debt relief (court decisions)

30 May - Poland: Lectures, courses, and trainings provided by universities subject to VAT

30 May - Poland: Postponement of e-invoicing mandate and reporting obligations of digital platform operators (DAC7) passed by Parliament

28 May - Cyprus: Final version of 2022 transfer pricing documentation form

28 May - Germany: Law implementing MLI passed by lower house of Parliament, other tax developments

28 May - Hungary: Rule requiring submission of information and documents for VAT refund claims within one month held contrary to EU law (CJEU judgment)

24 May - Netherlands: Financial instrument treated as equity (Supreme Court decision)

23 May - KPMG report: Comments on consultation on UK tax administration framework

23 May - UK: Denial of R&D tax incentives upheld (First-tier Tribunal decision)

22 May - Switzerland: Cantonal tax law changes in response to Pillar Two global minimum tax

21 May - EU: EC Directorate-General for Taxation and Customs Union management plan 2024

21 May - EU: European Commission public consultation on directive on administrative cooperation (DAC)

21 May - France: Claim for cross-border loss relief denied (Supreme Administrative Court decision)

21 May - France: Taxation of assets held abroad (CJEU referral)

21 May - Italy: Regulations implementing 15% substitute tax to controlled foreign company taxation

21 May - Poland: Excise duty on leased cars provided to employees; taxation of employee accommodation benefits; taxation of family foundation (court decisions)

20 May - Cyprus: Applications for reduced VAT rate on supply or construction of private dwelling must be submitted online beginning 27 May

17 May - Netherlands: Direct and indirect tax measures in general coalition agreement

16 May - Malta: Tax measures in 2024 budget enacted

16 May - Norway: Proposal for new calculation method for ground rent tax

16 May - Czech Republic: Changes that could affect scope of “windfall tax” on fuel

16 May - Czech Republic: Draft amendment to VAT Act 2025 published

15 May - Czech Republic: Transfer prices for advertising expenses; statutory rate of interest on retained VAT deductions upheld (Supreme Administrative Court decisions)

15 May - Poland: Real estate tax exemption for railway freight terminals; VAT on installation of renewable energy sources, asbestos removal

15 May - Poland: Taxable amount of in-kind contribution of property for VAT purposes is value of shares issued in exchange (CJEU judgment)

14 May - EU: ECOFIN agrees on new rules for harmonized withholding tax procedures (FASTER Directive)

14 May - Luxembourg: Implications of protocol to tax treaty with Germany for individuals, cross-border workers, corporate taxpayers, and investment funds

14 May - Sweden: Amended agreement with Denmark on cross-border workers in Oresund region announced

9 May - EU: New draft of EU VAT reform (VAT in the Digital Age (ViDA))

9 May - UK: Expenses allegedly for employee renumeration held not wholly and exclusively for trade purposes and thus not deductible (Upper Tribunal decisions)

9 May - UK: Property held to be purely residential and thus subject to higher stamp duty land tax rate (First-tier Tribunal decision)

8 May - Luxembourg: NACE code assigned investment funds upheld (Administrative Court of Appeal decision)

7 May - Czech Republic: Amendment to investment companies and funds law passes Parliament

7 May - Czech Republic: Beneficial owner of royalties under tax treaty (Supreme Administrative Court decision)

3 May - Estonia: New reporting requirements for cross-border payment service providers beginning 2024

2 May - Estonia: Draft legislation proposes mandatory issuance of e-invoice by sellers upon request of clients

April 2024

30 Apr - Germany: Draft bill for Annual Tax Act 2024 includes VAT-related measures, other VAT developments

30 Apr - Slovakia: Amendments to VAT Act approved by Parliament

29 Apr - EU: Working paper on VAT treatment of “crypto art”

29 Apr - Czech Republic: Amendments to income tax provisions in consolidation package approved by lower house of Parliament

26 Apr - Czech Republic: Draft bill implementing directive on tax transparency rules for service providers facilitating cryptoasset transactions (DAC8)

26 Apr - Cyprus: Temporary zero VAT on specific goods extended to 30 June 2024

26 Apr - EU: European Parliament adopts resolution on transfer pricing directive

26 Apr - France: New rules to avoid double-taxation from sale of CFC

26 Apr - Poland: New deadlines for e-invoicing mandate announced

26 Apr - Portugal: Proposed reduction of corporate income tax rate to 15%

25 Apr - Germany: Draft bill for Annual Tax Act 2024 includes Pillar Two changes, other tax developments

24 Apr - Cyprus: Tax card for 2024

24 Apr - UK: Consultations on VAT treatment of private hire vehicles, charitable donations

24 Apr - UK: Related-party interest arm’s length but still disallowed based on unallowable purpose (Court of Appeal decision)

24 Apr - UK: Taxpayer’s arguments that no withholding tax due on interest paid to foreign lenders rejected (Court of Appeal decision)

23 Apr - Germany: VAT treatment of vouchers (CJEU judgment)

23 Apr - Poland: Timing of tax exemption; inheritance and donation tax exemption; insurance proceeds not exempt income (Supreme Administrative Court decisions)

23 Apr - Serbia: Tax card for 2024

22 Apr - Austria: Guidance on VAT exemption for board renumeration; other recent direct and indirect tax developments

22 Apr - Cyprus: Increased capital allowances for “green” investments

19 Apr - Cyprus: Reduced 5% VAT for purchase or construction of residence

19 Apr - Czech Republic: Taking into account estimated payables for income tax purposes (Supreme Administrative Court decisions)

19 Apr - Netherlands: Insights into upcoming 2025 Tax Plan package

19 Apr - Serbia: Protocol to Switzerland income tax treaty adopted by Parliament

18 Apr - Serbia: Amendments to VAT rulebook

18 Apr - Germany: “Planned cooperation” between charitable corporations (fiscal court decision)

16 Apr - Italy: Agreement with UK on VAT refunds

16 Apr - Poland: Excise tax warehouse as place of import, charitable spending requirement, no gain upon transfer of real estate title as security (court decisions)

16 Apr - Poland: Reporting obligations for digital platform operators (DAC7) enacted, other tax-related legislative developments

16 Apr - Poland: VAT account not accessible asset in bankruptcy proceedings (CJEU Advocate General opinion)

12 Apr - Netherlands: Proposed legislation to tax “carried interests” as ordinary income

11 Apr - Netherlands: Consultation on proposed division exemption in real estate transfer tax

11 Apr - Czech Republic: Deductibility of increased interest; uncollectible debt (Supreme Administrative Court decisions)

11 Apr - Czech Republic: Draft amendment to VAT law includes changes to treatment of construction sector

11 Apr - Italy: Scope of self-disclosure regime extended to certain VAT-registered companies and deadline extended to 31 May 2024

11 Apr - UK: EC erred in finding illegal State aid based on controlled foreign company rules in isolation (CJEU Advocate General opinion)

10 Apr - Serbia: Amended guidance relating to “Eco Tax”

10 Apr - UK: Consultation on additional tax relief for visual effects in film expenditures

10 Apr - UK: Consultation on carbon border adjustment mechanism (CBAM)

10 Apr - UK: Draft legislation on new reserved investor fund regime

10 Apr - UK: HMRC guidance on salaried member rules for professional partnerships

10 Apr - UK: Labour announces planned international tax reforms

10 Apr - UK: Labour announces plans to close tax gap

10 Apr - UK: Updated draft guidance on overseas restrictions, subcontracted rules under new merged R&D tax relief regime

8 Apr - Germany: Proposed legislation includes VAT-related measures, other VAT developments

8 Apr - Luxembourg: Referral to CJEU for failing to correctly transpose ATAD interest limitation rules

8 Apr - Poland: Consultations on mandatory use of KSeF and changes to issuer’s and remitter’s statement templates

8 Apr - Poland: No taxable income upon lapse of statute of limitations, treatment of Norwegian VAT, appropriate individual tax form (court decisions)

8 Apr - Poland: Public country-by-country reporting bill approved by lower house of Parliament, updated national list of non-cooperative jurisdictions

8 Apr - Sweden: Withholding tax on foreign public pension funds incompatible with EU law (CJEU Advocate General opinion)

5 Apr - Cyprus: Extension of deadline for submission of data to register of beneficial owners for certain “refugee” companies

5 Apr - Cyprus: Legislation providing tax benefits for companies implementing energy upgrades passes Parliament

5 Apr - Hungary: Audit plan for 2024 focuses on transfer pricing

5 Apr - Ireland: Proposed R&D tax credit rate and refund increases

4 Apr - Spain: Most favoured nation clause under income tax treaty activated by India, reduces tax rate on royalties for technical services

3 Apr - Belgium: Proposed reform of investment deduction regime

3 Apr - Poland: Employee compensation under settlement; cashless payments; VAT on payment for transmission easement (court decisions)

3 Apr - Poland: New bill implementing reporting obligations for digital platform operators (DAC7)

2 Apr - Sweden: VAT treatment of NFTs associated with a digital work

March 2024

29 Mar - Cyprus: End of reduced excise taxes on certain fuels, VAT on certain products

27 Mar - Estonia: Income tax treaty with Qatar signed, treaty with Pakistan reaches second reading in Parliament

27 Mar - Estonia: Penalties on taxpayer who failed to appear in person to provide explanations to tax authority upheld (District Court judgment)

27 Mar - Netherlands: Interest deduction denied under fraud provision of corporate income tax law (Supreme Court decision)

26 Mar - Poland: Cash register receipts alone are valid evidence of overstated VAT (CJEU judgment)

26 Mar - Poland: Proposed changes to health insurance contributions by individuals

26 Mar - Germany: Tax reform bill enacted, other tax developments

25 Mar - Germany: Parliament approves legislation introducing e-invoicing mandate

25 Mar - Ireland: Tax changes for the asset management and funds industry, including Pillar Two rules

25 Mar - UK: Consultation on draft legislation introducing payroll reporting changes

25 Mar - UK: Finance (No. 2) Bill 2024

22 Mar - Cyprus: Consultations on draft legislation on carbon tax on energy products, daily accommodation fee

22 Mar - Poland: Update on consultations on national e-invoicing system (KSeF)

20 Mar - Greece: Extension of deadlines for updating retail payment systems

20 Mar - Netherlands: Interest deduction limitation rule compatible with EU law (CJEU Advocate General opinion)

19 Mar - Germany: Guidance on shareholder data reporting requirement for listed companies beginning 2025

19 Mar - Poland: Interpretation of retail sales tax law; lump-sum car allowance taxable; expenses for B2B team-building meetings not deductible (Supreme Administrative Court decisions)

19 Mar - Poland: Temporary zero VAT rate on food products not extended

19 Mar - Sweden: Taxpayer entitled to penalty relief for incorrectly claimed interest deductions (Court of Appeal decision)

18 Mar - Lithuania: Tax card for 2024

18 Mar - Netherlands: Old taxpayer portal used for filing VAT returns will close 1 July 2024

18 Mar - Netherlands: Pension funds not treated as special investment funds eligible for VAT exemption (CJEU Advocate General opinion)

15 Mar - EU: European Parliament committee adopts opinion on FASTER proposal

15 Mar - France: VAT recovery for Olympics operators with new expenses in France

15 Mar - Germany: Updated guidance on permanent establishments

15 Mar - Italy: New tax credit for energy saving investments

15 Mar - Latvia: Updated domestic list of low-tax or tax-free jurisdictions

15 Mar - Cyprus: Compliance campaign for stamp tax liability

15 Mar - Cyprus: Guidance on submission of data to register of beneficial owners

12 Mar - Cyprus: Notional interest deduction “reference rates” for 2024

12 Mar - Poland: Bill introducing cap on individual capital gains tax submitted before Sejm

12 Mar - Poland: Certain EU non-cooperative jurisdictions not included in list of countries applying harmful tax competition

12 Mar - Poland: General working time not eligible for R&D relief (Supreme Administrative Court decision)

11 Mar - Czech Republic: Beneficial ownership of royalties; VAT exemption for intra-community supply; proof of “essential costs” (Supreme Administrative Court decisions)

11 Mar - Czech Republic: Draft amendments to VAT law include narrowing of exemptions for financial activities

11 Mar - EU: VAT obligations of digital platforms pre-2015 (CJEU referral)

8 Mar - Cyprus: Submission of statements of dividend and interest withholding forms expected soon

8 Mar - Netherlands: Consultation on draft bill on VAT adjustment on services to immovable property

7 Mar - Serbia: VAT refund for 2023 to foreign taxpayers

7 Mar - Sweden: Further guidance on application of “3:12 rules” in cases of significant outside ownership (Tax Court Board decision)

7 Mar - UK: “Spring Budget” 2024

5 Mar - Czech Republic: No exemption under EU VAT common system when proof not provided that recipient is taxable person (CJEU judgment)

5 Mar - EU: European public prosecutor's office estimates serious VAT fraud amounting to €11.5 billion

5 Mar - Poland: Bill introducing option for small enterprises to elect cash method

5 Mar - Poland: Proposed reduction in VAT rate on beauty treatment services

5 Mar - Spain: Digital platform operators must file returns under DAC7 by 8 April 2024

4 Mar - Belgium: Mandatory disclosure rules (DAC6) compatible with EU law (CJEU Advocate General opinion)

4 Mar - Isle of Man: Guidance on tax treatment of dividends from domestic companies

1 Mar - Switzerland: Draft law to reduce wealth tax on shares of unlisted companies held by entrepreneurs (Geneva)

1 Mar - Cyprus: Guidance on submission of data to register of beneficial owners

February 2024

29 Feb - Cyprus: Deadline to submit 2022 return for taxpayers required to submit transfer pricing documentation extended

29 Feb - Germany: Compromise tax reform bill adopted by mediation committee of Parliament, other tax developments

29 Feb - Germany: Guidance on division of input VAT using overall sales key, other VAT developments

28 Feb - Belgium: Application of anti-abuse provision upheld even though taxpayer not involved in all parts of transaction (Supreme Court decision)

28 Feb - EU: Member states submit opinions to EC on new common corporate tax system proposal (BEFIT)

28 Feb - Ireland: Comments on public consultation on introduction of participation exemption

28 Feb - Serbia: Individual income tax filing deadlines and rates for 2023

27 Feb - Latvia: Tax card for 2024

26 Feb - Poland: Payments to employees on leave qualify as eligible R&D expenses

26 Feb - Poland: Social security liability; reduction in depreciation rates for prior years; taxable base for real estate taxes (court decisions)

26 Feb - UK: Closure notice held valid (First-tier Tribunal decision)

26 Feb - UK: Draft guidance on overseas restrictions, subcontracted rules under new merged R&D tax relief regime

26 Feb - UK: “Spring Budget” expected 6 March 2024

22 Feb - Italy: New rules for fiscal representatives of non-EU companies

22 Feb - Switzerland: Tax aspects of limited qualified investor fund for real estate investments

21 Feb - EU: Updates to list of non-cooperative jurisdictions

21 Feb - Germany: Limitation on inheritance and gift tax relief applicable to regular operating companies

21 Feb - Isle of Man: 2024 budget includes proposed increases in corporate and individual income tax rates

20 Feb - Netherlands: Guidance on application of zero VAT rate

20 Feb - Poland: Corporate income tax on buildings; tax-deductible costs; revenue from trademark (Supreme Administrative Court decisions)

20 Feb - Poland: Draft legislation implementing new reporting obligations for digital platform operators (DAC7)

20 Feb - Poland: Guidance and consultation on national e-invoicing system (KSeF)

16 Feb - Czech Republic: Determining whether income and expenses are “related” (court decisions)

16 Feb - France: Tax authority guidance on VAT treatment of non-fungible tokens

15 Feb - Netherlands: Qualification of land as developed or undeveloped for VAT purposes (Supreme Court decision)

15 Feb - Spain: Guidance under new mandatory corrective self-assessment procedure for direct and indirect taxes

14 Feb - Czech Republic: Deadline for assessing tax; technical improvement of real property (Supreme Administrative Court decisions)

13 Feb - Czech Republic: Application of VAT deduction for selected passenger cars in 2024

13 Feb - Greece: Guidance on new reporting obligations for digital platform operators (DAC7)

13 Feb - Poland: VAT rate on take-away meals; eligible costs of new investment projects (Supreme Administrative Court decisions)

12 Feb - EU: VAT treatment of transfer pricing adjustments (CJEU referral from Romania)

12 Feb - Netherlands: Consultation on new framework for determining characterization for tax purposes of foreign legal forms

12 Feb - UK: Additional capital gains tax changes for save as you earn plans

12 Feb - UK: Income tax treaty relief for foreign dividends (Upper Tribunal decision)

12 Feb - UK: Tax “pledges” in Labour’s plan for business

12 Feb - UK: Tax measures in Autumn statement substantively enacted

12 Feb - UK: Taxpayer not estopped from arguing invalidity of inquiry notices (First-tier Tribunal decision)

12 Feb - UK: Time limits for discovery assessments relating to stamp duty land tax (First-tier Tribunal decision)

9 Feb - Belgium: Provisions transposing DAC6 mandatory disclosure rules annulled (Constitutional Court decisions)

9 Feb - EU: Certain member states extend DAC7 reporting deadlines

9 Feb - EU: Formal notices to nine member states on failure to transpose minimum tax directive

9 Feb - Netherlands: FAQs on reporting obligations of digital platform operators (DAC7)

8 Feb - Netherlands: Changes to proposal for new “Box 3” (wealth tax) regime as of 2027

8 Feb - Croatia: Comprehensive double taxation agreement with Hong Kong signed

8 Feb - Sweden: Guidance on application of “3:12 rules” in cases of significant outside ownership (Supreme Administrative Court decision)

7 Feb - Netherlands: EC approval of COVID-19 related State aid annulled (CJEU General Court judgment)

6 Feb - Malta: Reduced VAT rate on short-term hiring of “pleasure” boats

6 Feb - Poland: Board member liability for VAT arrears (CJEU referral)

6 Feb - Poland: Taxpayers may retroactively change depreciation rates (Supreme Administrative Court decision)

5 Feb - Belgium: Parliament approves new law project to introduce e-invoicing mandate from 1 January 2026

January 2024

31 Jan - Italy: Amendments to direct and indirect tax rules effective 1 January 2024

30 Jan - EU: Penalty relief due to technical issues related to CBAM registry and import control system 2

30 Jan - Germany: Final guidance on CFC rules, other tax developments

30 Jan - Germany: Guidance on obligations of payment service providers, other VAT developments

30 Jan - KPMG report: Comments on public consultation on new common corporate tax system in the EU (BEFIT)

30 Jan - North Macedonia: New rulebook on application of VAT

30 Jan - Poland: Employer not liable for VAT based on fraudulent invoices prepared by employee (CJEU judgment)

30 Jan - Poland: Sublicense receivables treated as capital assets; taxation of refunds from employee capital plans (Supreme Administrative Court decisions)

30 Jan - Sweden: European Commission opens State aid investigation into non-food biogas and bio-propane tax exemption schemes

30 Jan - Czech Republic: Tax card for 2024

29 Jan - Czech Republic: Information on application of VAT from January 2024

29 Jan - UK: Capital Allowances on camping pods (First-tier Tribunal decision)

29 Jan - UK: Government response to consultations on proposed changes to transfer pricing and international tax rules

29 Jan - UK: Mandatory payrolling for benefits in kind beginning April 2026

29 Jan - UK: Proposed changes to Scottish land and buildings transaction tax

29 Jan - UK: Unallowable purpose, connection, and control (First-tier Tribunal decision)

26 Jan - Gibraltar: Amendment to the income tax law

25 Jan - Spain: Amendments to tax incentives under taxes on economic activities and real estate (Madrid)

24 Jan - Albania: Withholding tax and double tax treaties applications

24 Jan - Netherlands: Only beneficial owner of dividend entitled to credit dividend withholding tax (Supreme Court decision)

24 Jan - Serbia: Amendments to “Eco Tax” adopted

24 Jan - Spain: Several corporate tax law measures declared unconstitutional (Constitutional Court decision)

23 Jan - Poland: Taxation of employee incentive shares; supplementary capital contribution deductible (Supreme Administrative Court decisions)

23 Jan - Sweden: Interest deductions incurred to finance intra-group share acquisition allowed (Supreme Administrative Court decision)

23 Jan - Sweden: Proposed amendments to rules on deducting prior year losses to facilitate changes in ownership

22 Jan - Cyprus: Extension of deadline to submit data to register of beneficial owners to 31 March 2024

22 Jan - Malta: Deduction in respect of intellectual property and intellectual property rights

19 Jan - Belgium: Anti-abuse rule applied to deny withholding tax exemption under EU Parent-Subsidiary Directive (Supreme Court decision)

19 Jan - Denmark: Proposed updates to list of jurisdictions subject to defensive tax measures

19 Jan - EU: Challenge to EU global minimum tax directive dismissed (EU General Court judgment)

19 Jan - EU: Priorities of Belgian Presidency of EU Council

19 Jan - Germany: Interest deduction limitation rules aligned with ATAD

19 Jan - Italy: Legislation implementing international tax reform published

19 Jan - Italy: Procedure for obtaining hybrid mismatch penalty protection

19 Jan - Malta: Updates to pension tax exemption and rebate rules

19 Jan - Poland: Mandatory e-invoicing system postponed

19 Jan - Portugal: “Windfall profits tax” on banks incompatible with EU law (CJEU judgment)

18 Jan - Bulgaria: Amendments to individual income tax and social security contributions effective 1 January 2024

18 Jan - Spain: Amendments to special inbound expatriate regime

17 Jan - Czech Republic: Changes in VAT from 2024; amendment to Real Estate Tax Act

17 Jan - Czech Republic: Treaty must be interpreted based primarily on general interpretation rules (Supreme Administrative Court decision)

17 Jan - Italy: New tax calendar, implications for transfer pricing documentation

16 Jan - Poland: Bill on cryptoassets; Minister of Finance activities for 2024

16 Jan - Poland: Taxation of benefits provided to workers in another EU member state; deductibility of debt financing costs (Supreme Administrative Court decisions)

16 Jan - Spain: Changes to tax regime for non-profit entities and tax incentives for patronage

16 Jan - UK: Carbon border adjustment mechanism (CBAM) announced for 2027

16 Jan - UK: New investment exemption from the electricity generator levy

16 Jan - UK: Tax measures in Scottish and Welsh 2024/2025 budgets

12 Jan - Belgium: Law project to introduce a new e-invoicing mandate from January 2026

12 Jan - Spain: Tax measures in new laws approved at end of 2023

12 Jan - Sweden: Voluntary tax liability for VAT purposes appliable in context of jointly managed rental properties (Supreme Administrative Court decision)

11 Jan - KPMG report: Comments on European Commission consultation on transfer pricing initiative

11 Jan - France: Tax-related provisions in finance law for 2024, including Pillar Two rules and transfer pricing documentation changes

11 Jan - Cyprus: Reduced special defence contribution rate on interest

11 Jan - Spain: Procedures for VAT required during January and February 2024

10 Jan - Spain: Issues to be considered by financial, insurance industries when calculating VAT pro-rata for 2023

10 Jan - Bulgaria: Amendments to VAT law effective 1 January 2024

9 Jan - Greece: New law introduces amendments to taxation of insurance funds and pension plans

9 Jan - Serbia: Amendments to rulebook on e-invoicing adopted

8 Jan - Cyprus: Registration in tax registry must be done electronically through taxpayer portal

8 Jan - Moldova: Fixed social security and health insurance contributions for 2024

8 Jan - Poland: Refusal to apply preferential withholding tax treatment upheld; R&D conducted by contractor treated as carried out by taxpayer (Supreme Administrative Court decisions)

4 Jan - Greece: Tax provisions in new law

4 Jan - Netherlands: Farewell bonuses not treated as non-deductible participation selling costs (Supreme Court decision)

4 Jan - Sweden: Revaluation of tax base for VAT purposes for group-wide services (CJEU referral)

3 Jan - North Macedonia: New rulebook on VAT registration of foreign taxpayers through a tax representative

3 Jan - Serbia: Amendments to VAT rulebook

2023 Articles

December 2023

26 Dec - Luxembourg: Director’s fees not subject to VAT (CJEU judgment)

22 Dec - Cyprus: VAT return deadline extension

22 Dec - EU: 2023 year-end overview of direct tax initiatives

21 Dec - Netherlands: Waiver of default penalties for non-compliance with OSS mechanisms of VAT e-commerce package

21 Dec - Poland: Mandatory e-delivery postponed; reduced VAT rates on basic food products; real estate and transportation tax exemptions

21 Dec - Poland: Suspension of statute of limitations constitutional; maximum tax rate for residential buildings; deduction of input VAT on employee accommodations (court decisions)

21 Dec - Belgium: Proposed amendments to anti-abuse rules

20 Dec - Belgium: Compatibility of “fairness tax” with EU law (CJEU referral)

20 Dec - Belgium: Year-end VAT review

20 Dec - Cyprus: Submission of data on ultimate beneficial owners due 29 February 2024

20 Dec - Czech Republic: Law incorporating corporate sustainability reporting directive (CSRD) enacted

20 Dec - EU: European Parliament resolution on further reform of corporate tax rules, including BEFIT proposal

20 Dec - France: Claims for foreign tax credits on dividends rejected (court decision)

20 Dec - Luxembourg: Overview of certain tax developments for 2024

20 Dec - Netherlands: 2024 Tax Plan package and law implementing Pillar Two global minimum tax enacted

20 Dec - Spain: Notifications for excise taxes required during first few months of 2024

19 Dec - Estonia: Board member liable for taxes; Finnish tax liability collectible (Circuit Court decisions)

19 Dec - Spain: Requirements for billing systems as of 1 July 2025

15 Dec - Spain: VAT applications required by 31 December 2023

14 Dec - Luxembourg: European Commission erred in finding grant of State aid based on OECD Transfer Pricing Guidelines (CJEU judgment)

14 Dec - Poland: Draft law increasing limits on tax-deductible costs

14 Dec - Poland: Surcharge on alcoholic beverages applicable; loan management services not VAT-exempt (Supreme Administrative Court decisions)

14 Dec - Sweden: Corrections related to new information from Pandora leak due by 29 February 2024 to avoid penalties

13 Dec - Austria: Summary of recent direct and indirect tax developments

13 Dec - Czech Republic: Draft law introducing long-term investment product for retirement savings approved by Chamber of Deputies

13 Dec - Czech Republic: VAT deduction on anti-radar equipment; VAT treatment of transfer of technical improvements at lease end (Supreme Administrative Court decisions)

12 Dec - Belgium: Draft law proposes new stricter CFC rules

12 Dec - Belgium: Requirements for mixed VAT taxpayers calculating VAT deductions using general pro rata method

11 Dec - Netherlands: Agreement with Belgium on permanent establishment implications of remote working

11 Dec - Romania: E-invoicing updates for established persons and nonresident VAT payers

8 Dec - Belgium: Beneficial ownership concept under Netherlands treaty (Lower Court decision)

8 Dec - Cyprus: Extended “central equal weight sharing tax” payment deadline for real estate and share transfers

8 Dec - EU: ECOFIN report addressing “Unshell” and FASTER directives

8 Dec - EU: European Parliament subcommittee on tax matters discussion with code of conduct group on business taxation

8 Dec - Germany: Circumstances of group of companies may be considered in applying new German anti-treaty shopping rule (Lower Court decision)

8 Dec - Hungary: Local rules applicable to domestic reorganizations inconsistent with EU merger directive (CJEU judgment)

8 Dec - UK: Consultation on full expensing for leased plant and machinery

8 Dec - UK: Consultation on simplification of capital allowances for plant and machinery

8 Dec - UK: Finance Bill 2024, including amendments to Pillar Two minimum tax rules 

8 Dec - UK: HMRC guidance on employer tax compliance obligations with respect to umbrella companies

8 Dec - UK: HMRC guidance on off-payroll working compliance

8 Dec - UK: Notice requiring taxpayer to disclose emails containing specified terms upheld (First-Tier Tribunal decision)

7 Dec - Denmark: Deadline for reporting information about employee share plans and share repurchases is 20 January 2024

7 Dec - Italy: Guidance on new reporting obligations for digital platform operators (DAC7)

6 Dec - Poland: Draft regulations related to mandatory use of national e-invoicing system (KSeF)

6 Dec - Poland: Recent corporate income tax guidance

6 Dec - Poland: R&D activities; individual depreciation rate for certain non-residential premises (Supreme Administrative Court decisions)

5 Dec - Belgium: Access to VAT e-services “Isabel” and “GlobalSign” to end beginning 31 January 2024

5 Dec - Belgium: Draft law proposes changes to Cayman tax

5 Dec - Greece: Guidance on VAT treatment of over the counter derivatives

5 Dec - Luxembourg: European Commission erred in finding grant of State aid (CJEU judgment)

5 Dec - Malta: Draft legislation implementing certain VAT measures in 2024 budget

1 Dec - Albania: Source of income and permanent establishment rules for 2024

1 Dec - Portugal: Tax treaty with Australia signed

1 Dec - Spain: Forms for new reporting obligations for digital platform operators (DAC7)

November 2023

30 Nov - Germany: Tax reform bill and draft law on future financing passed by Parliament, other tax developments

30 Nov - Germany: VAT changes in tax reform bill and draft law on future financing, other VAT developments

30 Nov - Ireland: Changes for share options (2024)

30 Nov - KPMG report: Global developments in ESG-related taxes, incentives, and grants (ESG tax tracker)

30 Nov - Luxembourg: Flat minimum net wealth tax partly declared unconstitutional (Constitutional Court decision)

29 Nov - EU: VAT Committee considers that individuals regularly selling in-game assets are subject to VAT

29 Nov - Spain: Constitutionality of temporary solidarity tax on large fortunes upheld, Madrid proposes repeal for its residents

28 Nov - Spain: Update on new reporting obligations for digital platform operators (DAC7)

28 Nov - Italy: Legislative decrees implementing tax reform

28 Nov - Poland: Extension of zero percent VAT rate on foods, waiver of tax on certain financial institutions

28 Nov - Poland: Taxation of employee share grants; tax depreciation of real estate (court decisions)

27 Nov - Belgium: Joint VAT liability for electronic interfaces

27 Nov - Cyprus: Temporary zero VAT rate on meat and vegetables

27 Nov - Luxembourg: Temporary VAT rate reductions set to expire 1 January 2024

27 Nov - Spain: Compatibility with EU law of application of nonresident income tax on dividend distributions (CJEU referral)

27 Nov - UK: Guidance on reclaiming national insurance contributions on car allowances

27 Nov - UK: Shares in closely held company treated as employment-related securities for income tax purposes (Supreme Court decision)

27 Nov - UK: Update on consultation on proposed changes to transfer pricing and permanent establishment rules

22 Nov - Serbia: Amendments to VAT rulebook

22 Nov - UK: Tax proposals in Autumn statement

21 Nov - Poland: Cash register receipts alone are valid evidence of overstated VAT (CJEU Advocate General opinion)

21 Nov - Poland: Proposed extension of list of taxes payable to tax micro-accounts

17 Nov - Czech Republic: Proposed direct and indirect tax changes, including public country-by-country reporting

17 Nov - Switzerland: Consultation on draft amendments to anti-money laundering law

16 Nov - Poland: Supplies of electricity to foreign partners not subject to VAT; costs deductible against capital gains (court decisions)

13 Nov - Czech Republic: Proposed amendments to proving R&D allowances, taxation of employee stock option plans

13 Nov - Italy: New reporting obligations for payment service providers

10 Nov - Cyprus: Tax liability for transfer of real property following a sale

10 Nov - Czech Republic: Pharmaceutical marketing services are separate supply of services not subject to VAT (Supreme Administrative Court decision)

10 Nov - Greece: Guidelines on tax residency of individuals

10 Nov - Serbia: Amendments to electronic invoicing law

10 Nov - UK: Autumn statement expected 22 November 2023

10 Nov - UK: Capital allowances for surveys and studies (Upper Tribunal decision)

10 Nov - UK: Share exchange on sale of company not tax avoidance (Court of Appeal decision)

10 Nov - UK: Share options granted by employer deemed part of employee compensation (Supreme Court decision)

9 Nov - EU: List of national portals for reporting to central electronic system of payment information

9 Nov - EU: Member states approve statements of EU Council and European Commission reconfirming support for Pillar One and Pillar Two

9 Nov - Belgium: Referral to CJEU for failing to correctly transpose ATAD CFC rules

9 Nov - EU: European Parliament adopts resolutions on tax policy in times of crisis and further reform of corporate tax rules

9 Nov - Finland: Reservations on proposed EU BEFIT, transfer pricing, and head office tax system directives

9 Nov - Iceland: New income tax treaty with Australia now in force

9 Nov - Ireland: Judgment of General Court regarding tax rulings issued to multinational group must be set aside (CJEU Advocate General opinion)

9 Nov - Ireland: Purchase and resale of second-hand cars does not meet conditions under VAT margin scheme

9 Nov - Portugal: Tax measures in draft 2024 budget law submitted to Parliament

8 Nov - Albania: Changes to interest deductibility rules for corporate income tax purposes

8 Nov - Ireland: Proposed changes in Finance Bill 2023 impacting funds and the asset management industry

7 Nov - Germany: No input VAT deductions for import VAT on goods never received (Federal Tax Court decision), other VAT developments

7 Nov - Poland: Real estate tax on cableways; enforcement fees as public levies; basis of fixed assets for minimum tax purposes (Supreme Administrative Court decisions)

6 Nov - Bulgaria: Recovery of VAT on uncollectible receivables using new electronic service

6 Nov - Serbia: Amendments to various tax laws, including property tax and lump sum tax on entrepreneurs

6 Nov - Spain: VAT actions required by 30 November 2023 deadline

6 Nov - Switzerland: Blockchain services partially taxable and partially non-taxable for VAT purposes (Federal Administrative Court decision)

3 Nov - Cyprus: Excise tax on certain fuels reduced

3 Nov - Cyprus: New income tax treaty with Croatia signed

3 Nov - Netherlands: Place of risk and transport exemption for insurance premium tax purposes (court decision)

2 Nov - Estonia: Income tax assessment based on incorrect valuation of non-monetary contribution to share capital struck down (Supreme Court decision) 

2 Nov - Romania: New law modifying the tax code

2 Nov - Sweden: VAT recovery on the disposal of shares in a subsidiary undertaking (Supreme Administrative Court decision)

1 Nov - France: VAT digital economy enforcement included in 2024 Finance Bill

October 2023

31 Oct - Malta: Tax measures in budget 2024, including deferral of implementation of Pillar Two global minimum tax

31 Oct - Netherlands: 2024 Tax Plan package adopted by Lower House of Parliament

31 Oct - Luxembourg: Constitutional Court to decide constitutionality of different treatment under minimum net wealth tax for holding companies

31 Oct - Luxembourg: U.S. branch denied permanent establishment status, previous ruling nullified (administrative court decision)

31 Oct - Poland: Striking taxable person from VAT register; exit law compatible with EU law; construction management services subject to VAT (court decisions)

30 Oct - Austria: Draft guidance on non-carbon infrastructure provision under interest limitation rule; other recent direct and indirect tax developments

27 Oct - UK: New guidance on corporate tax deductibility of cash cancelled or net-settled employee share options

26 Oct - Albania: Changes to tax depreciation and inventory valuation methods

26 Oct - Germany: Draft of updated guidance on reorganization tax law

26 Oct - Germany: Loss limitation rule inapplicable because no change in control (lower tax court decision)

25 Oct - Cyprus: VAT exemption for specific training services

24 Oct - Belgium: FAQ on new obligations of digital platform operators (DAC7)

24 Oct - EU: VAT gap statistics for 2021

24 Oct - Poland: Real estate tax on parking space; re-registering sole proprietorship as private limited company; revenue under employment contract (court decisions)

24 Oct - Sweden: VAT apportionment rules violate of EU law (Supreme Administrative Court decision)

23 Oct - France: Withholding tax on dividends to nonresident loss-making companies upheld (Constitutional Court decision)

23 Oct - Portugal: Individual income tax on interest paid by foreign banks incompatible with EU law (CJEU judgment)

23 Oct - Ukraine: Reduced withholding tax under Cyprus treaty denied because recipient not considered beneficial owner (court decision)

20 Oct - Belgium: Tax proposals in budget 2024 include real estate VAT changes, mandatory e-invoicing, stricter CFC rules

20 Oct - Cyprus: Deadline for filing appeal for individual income taxes extended

20 Oct - Cyprus: Direct and indirect tax measures approved by Cabinet of Ministers

20 Oct - Ireland: Tax proposals in Finance bill 2023 include implementation of Pillar Two global minimum tax

20 Oct - Sweden: Proposed increase in excise tax on gambling

20 Oct - Switzerland: Refund claim for withholding tax on government bond interest denied due to cross-currency swap (Federal Administrative Court decision)

19 Oct - France: New deadlines for implementation of e-invoicing

18 Oct - France: Tax measures in 2024 draft finance law include Pillar Two implementation and transfer pricing documentation changes

17 Oct - EU: New directive on tax transparency rules for service providers facilitating cryptoasset transactions (DAC8)

17 Oct - EU: Updates to list of non-cooperative jurisdictions

17 Oct - Ireland: Public consultation on VAT modernization

17 Oct - Poland: Individual ruling denied; tax-deductible costs; qualified R&D income; qualified employment income; taxable permanent establishment (court decisions)

16 Oct - Cyprus: Deadline for filing date of individual’s tax return, self-assessment extended to 31 October 2023

13 Oct - Portugal: Introductory gift does not constitute separate VAT-taxed (deemed) supply of goods (CJEU judgment)

12 Oct - Albania: Changes to expenses considered non-deductible for corporate income tax purposes

12 Oct - Italy: Registry of ultimate beneficial owners now operational, reporting deadline of 11 December 2023

12 Oct - Malta: Reduced VAT rate on certain services effective 1 January 2024

11 Oct - Ireland: Tax proposals in budget 2024

11 Oct - Poland: Foodstuffs containing same main ingredient may be subject to different reduced VAT rates (CJEU judgment)

10 Oct - Czech Republic: Deadline for filing additional tax return for lower tax (Supreme Administrative Court decision)

6 Oct - Germany: New guidance on entrepreneurial status and input VAT deductions for research institutions

5 Oct - Austria: Updated DAC6 guidance

5 Oct - Cyprus: Extension of deadline for VAT returns

5 Oct - Ireland: Public consultation on introduction of participation exemption

5 Oct - Romania: Proposed minimum turnover tax for large companies and supplementary tax for banks

4 Oct - Croatia: Direct and indirect tax law amendments effective 1 January 2024

4 Oct - Poland: Insurance services not subject to lump-sum income tax; power equipment taxable as structures; recordkeeping requirements for preferential tax rate (Supreme Administrative Court decisions)

4 Oct - Poland: Public consultations on beneficial owner for withholding tax purposes, expansion relief measures

3 Oct - Belgium: B2B e-invoicing mandatory effective 1 January 2026

3 Oct - Switzerland: Partial revision of cantonal tax law (Zug)

3 Oct - KPMG report: Comments in response to EC public consultation on proposal to improve withholding procedures (FASTER)

3 Oct - KPMG report: Effect of EU small business VAT reform on nonresidents and large businesses

2 Oct - Germany: Tax measures in draft tax reform bill, other tax developments

2 Oct - North Macedonia: Amendments to corporate income tax and VAT, windfall profits tax adopted

2 Oct - Sweden: Response to notice by European Commission that withholding rules targeting foreign contractors violate EU law

September 2023

29 Sep - Poland: New draft explanation on withholding tax

29 Sep - Slovakia: Guidance on proving identity of beneficial owner of income

29 Sep - Spain: EC decision of unlawful State aid annulled to protect legitimate expectations (CJEU General Court judgment)

29 Sep - UK: Updated Finance Bill 2023 draft legislation, including Pillar Two global minimum tax rules

26 Sep - Austria: Summary of recent direct and indirect tax developments

26 Sep - Poland: Look-through approach for dividend exemption; tax treatment of losses incurred by Romanian branch; no VAT on stolen goods (court decisions)

26 Sep - Poland: Tax consequences of issuing fake invoice by employee without knowledge of employer (CJEU Advocate General opinion)

25 Sep - Albania: Changes to corporate income tax

22 Sep - Netherlands: 2024 Tax Plan includes changes to payroll taxes and social security contributions

20 Sep - Netherlands: Direct and indirect tax measures in 2024 Tax Plan

20 Sep - Belgium: Tax exemptions granted on certain “excess” profits constitute unlawful State aid (CJEU judgment)

20 Sep - Switzerland: Elimination of tariffs on industrial goods effective 1 January 2024

20 Sep - UK: Taxpayer acting as principal and not agent for VAT purposes (First-tier Tribunal decision)

19 Sep - Poland: Real estate tax imposed on fuel and gas dispensers (Supreme Administrative Court decision)

18 Sep - France: Tax officials announce e-invoicing mandate would become effective in 2026

18 Sep - Belgium: Requirement under DAC6 for intermediaries to notify other intermediaries of their reporting obligation is invalid (Constitutional Court decision)

18 Sep - Germany: Updated draft tax reform bill

18 Sep - Ireland: Amendments to patent box regime in response to Pillar Two implementation

18 Sep - Italy: Law directing the government to reform the tax system now effective

18 Sep - Italy: Nonresident company eligible for domestic participation regime for capital gains when selling Italian company (Supreme Court decision)

18 Sep - Ukraine: Proposed “windfall profits tax” on banks

15 Sep - Cyprus: Temporary reduction in interest levy

15 Sep - Cyprus: Zero VAT rate extended for another six months

15 Sep - Netherlands: Changes for domestic and cross-border mergers, divisions and conversions

15 Sep - Netherlands: Memorandum to parliament in response to report regarding bill implementing Pillar Two

15 Sep - UK: Consultation on repeal of stamp duty on issuances of new shares

15 Sep - UK: Employers may reclaim national insurance contributions on car allowances (Upper Tribunal decisions)

15 Sep - UK: Increased scrutiny of R&D tax incentive claims

14 Sep - Albania: Changes to taxation of individuals’ business income

14 Sep - Greece: New reporting obligations for digital platform operators (DAC7)

14 Sep - Netherlands: Consultation on new “Box 3” (wealth tax) regime

14 Sep - EU: European Commission proposal for directive on head office tax system for micro, small, and medium sized enterprises

13 Sep - EU: European Commission proposals for directives on business income taxation framework (BEFIT) and transfer pricing

13 Sep - Poland: Draft decree exempting certain supplies of goods and services from obligation to issue structured invoices

13 Sep - Poland: Proposed amendments to tax code abandoned

12 Sep - Czech Republic: Accommodation service versus lease of real estate for VAT purposes, and abuse of rights concept (municipal court decision)

12 Sep - Czech Republic: Tax deductibility of management services (Supreme Administrative Court decision)

11 Sep - Czech Republic: Guidance on application of VAT to gratuitous supplies of goods

11 Sep - Bulgaria: New reporting obligation for VAT-registered persons

8 Sep - Albania: Special provisions and rules on taxation of investment income realized by individuals

8 Sep - Cyprus: Registry of beneficial owners; payment of central equal weight sharing agency fee

8 Sep - Sweden: Extension in scope and time of government study of “3:12 rules”

7 Sep - Spain: Changes to corporate income tax deductibility of financial expenses

6 Sep - Belgium: Application of VAT to company cars

5 Sep - Poland: Insurance services not guarantee services subject to lump-sum tax (Supreme Administrative Court decision)

5 Sep - Poland: Updated version of national e-invoicing system

5 Sep - UK: Interest deductions on intra-group debt disallowed on grounds of unallowable purpose (Upper Tribunal decision)

1 Sep - Cyprus: Submission of company income statements and self-employed with accounts due 31 March 2024

1 Sep - EU: Enhanced enforcement of VAT rules on non-resident digital economy businesses

1 Sep - Ireland: VAT rate to increase for tourism and hospitality sector effective 1 September 2023

August 2023

29 Aug - Poland: Application of general anti-abuse rule; taxation of restricted stock; taxation of company conversion (Supreme Administrative Court decisions)

29 Aug - Poland: Extended deadline for tax on unrealized gains; guidance on capital duty

29 Aug - Czech Republic: Amendments to bill containing proposed direct and indirect tax changes

29 Aug - EU: Certain carbon border adjustment mechanism rules challenged before CJEU

29 Aug - Italy: Temporary solidarity contribution (“windfall profits tax”) on banking sector

29 Aug - Latvia: Proposed solidarity contribution (“windfall profits tax”) on banking sector

29 Aug - Luxembourg: Beneficial ownership of trademark (court decision)

29 Aug - Spain: Burden of proving abuse of withholding tax exemption under EU Parent-Subsidiary Directive (Supreme Court decision)

29 Aug - United Kingdom: Policy paper on reporting obligations for digital platform operators (DAC7)

28 Aug - Germany: Tax measures in draft bill for law on future financing, other tax developments

22 Aug - Poland: Reduced depreciation period for buildings and non-building structures

22 Aug - Poland: Tax-deductible costs; income from IP and credit default swaps (court decisions)

18 Aug - Germany: Draft tax reform bill includes mandatory e-invoicing, other VAT developments

18 Aug - KPMG report: Rules for transitional phase of EU carbon border adjustment mechanism adopted

17 Aug - EU: Implementing rules for transitional phase of carbon border adjustment mechanism adopted

16 Aug - Denmark: Increase in VAT audits of nonresident digital services providers

16 Aug - Denmark: Interest on corrections of VAT and excise duties for past periods effective 1 July 2023

16 Aug - Poland: Mandatory e-invoicing legislation enacted

16 Aug - Poland: Tax on revenue from buildings; VAT treatment of preliminary land sale contract; social media barter contract (court decisions)

16 Aug - Switzerland: Tax exemptions for electric vehicles expected to be repealed, but customs duties also abolished

14 Aug - Hungary: Amendments to extra profit surtaxes

11 Aug - Albania: Changes to real estate tax base

10 Aug - Albania: Guidance on law providing direct and indirect tax incentives for technological and scientific parks

9 Aug - Czech Republic: VAT developments

9 Aug - Hungary: Corporate income tax credit for “net zero” investments

8 Aug - Poland: Costs of foreign posting; withholding on foreign payments; increased real estate tax (court decisions)

8 Aug - Poland: New maximum 2024 rates for real estate and transportation tax and other local fees

7 Aug - UK: Consultation on proposed changes to taxation of employee trusts

7 Aug - UK: Guidance on corporation tax relief for cost of net-settled and cash cancelled employee share awards

4 Aug - EU: Reasoned opinion to six member states on failure to fully transpose DAC7

4 Aug - Hungary: Formal notice of failure to align corporate income tax rules with ATAD

4 Aug - Italy: Taxpayer not respected as beneficial owner of interest payments (Supreme Court decision)

4 Aug - Luxembourg: Referral to CJEU by European Commission for failure to correctly transpose ATAD interest limitation rules

3 Aug - Poland: Response to Parliamentary inquiry regarding inclusion of prior year losses in calculating wealth solidarity tax

2 Aug - Germany: Draft guidance on CFC rules

2 Aug - Germany: Draft guidance on hybrid mismatch rules

2 Aug - Germany: Draft tax reform bill

1 Aug - Bulgaria: Amendments to beneficial owners registry law

1 Aug - Poland: Amendments to capital duty and perpetual usufruct provisions; proposed tax changes related to e-administration

1 Aug - Poland: Recordkeeping for IP Box relief; cash as tax-deductible cost; residential property used in business; taxation of agricultural prizes (Supreme Administrative Court decisions)

July 2023

28 Jul - France: Delay in e-invoicing and e-reporting implementation

27 Jul - Ireland: Updated R&D tax credit; cloud computing costs

27 Jul - Luxembourg: New bill to modernize investment tax credit

27 Jul - Luxembourg: Payment service providers VAT legal package

27 Jul - Luxembourg: VAT treatment of activities carried out by board member (CJEU Advocate General opinion)

25 Jul - Cyprus: Reduced VAT rates for certain goods and services

25 Jul - North Macedonia: Revised amendments to corporate income tax, VAT, and windfall profits tax

25 Jul - Poland: Recent tax-related developments

24 Jul - Slovakia: Major changes in draft amendment to VAT Act

24 Jul - UK: Draft legislation for Finance Bill 2024 and several consultation responses published on “L Day”

19 Jul - Luxembourg: U.S. branch denied permanent establishment status (administrative court decision)

19 Jul - Poland: Mandatory e-invoicing legislation rejected; proposed solidary contribution for coal sector

19 Jul - Poland: Preferential corporate rate; residential depreciation repeal; deductibility of certain expenses (Supreme Administrative Court decisions)

14 Jul - Gibraltar: 2023 budget includes consultation on implementation of Pillar Two global minimum tax, stamp duty changes

12 Jul - EU: European Parliament’s Committee on Economic and Monetary Affair public exchange with Commissioner for Economy

12 Jul - Ireland: Bill to introduce solidarity contribution on windfall gains of companies in the fossil fuel sector

12 Jul - Italy: Withholding tax on dividends paid to investment fund breaches EU law, refund granted (court decision)

12 Jul - Latvia: Updated list of non-cooperative jurisdictions

12 Jul - Malta: Guidance on DAC7

12 Jul - Netherlands: Proposed amendments to tax ruling policy

11 Jul - Poland: Legislative developments include reduced VAT on children’s clothing, increase in revenue cap for lump-sum income tax scheme

11 Jul - Poland: Mobile application for e-invoicing; consultation on schemas for digital platform operators (DAC7)

10 Jul - Estonia: Direct and indirect tax amendments

10 Jul - Hungary: Draft direct and indirect tax amendments

10 Jul - UK: No UK taxing rights under UK-Canada treaty on UK oil field production profits paid to non-resident (Court of Appeal judgment)

10 Jul - UK: Updates to energy profits levy and electricity generator levy in Spring Finance Bill 2023

7 Jul - KPMG report: Shipping and offshore tax update (July 2023)

7 Jul - Luxembourg: Updated FAQ on mandatory disclosure rules (DAC6)

7 Jul - Poland: Definition of structure for real estate tax purposes held unconstitutional (Constitutional Tribunal decision)

7 Jul - Spain: Deadline to claim VAT refunds for 2022 is 30 September 2023

6 Jul - Albania: New tax incentives for “digital nomads”

June 2023

29 Jun - Belgium: Toll manufacturer does not constitute VAT fixed establishment (CJEU judgment)

29 Jun - Cyprus: Changes to application of reduced VAT rate on supply or construction of permanent residence

28 Jun - Austria: Summary of recent direct and indirect tax developments

28 Jun - EU: European Commission guidance on foreign subsidies regulation

28 Jun - Greece: Guidance on exemption from special real estate tax

28 Jun - Lithuania: Amendments to excise duty law

28 Jun - Luxembourg: Guidance on reverse hybrid rules

28 Jun - Netherlands: Amendments to draft bill to abolish property transfer tax concurrence exemption for share transactions

28 Jun - OECD: Updated guidelines for multinational enterprises, final cryptoasset reporting framework rules

28 Jun - Poland: Consultations on clarifications to shifted profit tax, amendments to tax procedures

28 Jun - Poland: Reducing depreciation during period of State aid not tax evasion; invoices issued prematurely not fictitious

26 Jun - Belgium: Income tax treaty with Netherlands signed

26 Jun - Switzerland: Increase to VAT rates effective 1 January 2024

26 Jun - UK: Consultation on transfer pricing, permanent establishment, and DPT rules

26 Jun - UK: Deduction denied for payments on related-party indebtedness (First-tier Tribunal decision)

26 Jun - UK: Draft guidance on Pillar Two global minimum tax rules published, comments requested

26 Jun - UK: New guidance on appointing reporting companies for corporate interest restriction rules

26 Jun - UK: Spring Finance Bill 2023, including Pillar Two global minimum tax rules, substantively enacted

26 Jun - UK: Updated guidance on anti-avoidance rules for creative sector tax reliefs

22 Jun - EU: European Parliament adopts resolution on lessons learned from Pandora Papers

21 Jun - EU: EC proposal for second basket of “own resources”

21 Jun - Poland: Invoices issued prematurely not fictitious; documentation of business in special economic zone (Supreme Administrative Court decisions)

21 Jun - Poland: Reduced VAT on food extended; mandatory e-invoicing; revocation of state of health emergency (COVID-19)

20 Jun - Spain: Draft e-invoicing regulations published

20 Jun - EU: European Commission proposal to improve withholding tax procedures

16 Jun - EU: ECOFIN report addressing “Unshell” Directive, DAC8, automatic exchange of information

16 Jun - Poland: Interest required to be paid on unduly withheld taxes (CJEU judgment)

15 Jun - Poland: Amendments to simplify and accelerate VAT settlements, including “Slim 3 VAT package”

15 Jun - Poland: Revenue from business in special economic zone; deduction of VAT in cross-border transactions and residential leases (Supreme Administrative Court decisions)

15 Jun - Denmark: Expanded territory for tax liability for taxpayers within continental shelf/exclusive economic zone

15 Jun - Netherlands: Denial of dividend withholding tax exemption under anti-abuse provision upheld (CJEU Advocate General opinions)

14 Jun - Cyprus: Deadline for filing date of individual’s tax return, self-assessment extended to 2 October 2023

14 Jun - EU: Comments requested on draft implementing regulation of carbon border adjustment mechanism

14 Jun - Czech Republic: VAT treatment of electricity supplies from charging stations (CJEU judgment)

13 Jun - Czech Republic: Changes to application of VAT to real property

12 Jun - UK: Importance of commercial reality in assessing withholding tax obligations (Upper Tribunal decision)

12 Jun - UK: New accruals framework for carried interest

12 Jun - UK: New measures to regulate umbrella companies and improve labour supply chain tax compliance

12 Jun - UK: Treasury “call for evidence” on employee save-as-you-earn and share incentive plans

9 Jun - Hungary: Rates for the extended producer responsibility scheme published

9 Jun - Netherlands: Increased interest on tax due for individual income tax, dividend tax, VAT, other taxes

8 Jun - Luxembourg: European Commission erred in finding grant of State aid based on OECD Transfer Pricing Guidelines (CJEU Advocate General opinion)

7 Jun - Hungary: Changes to “extra profit” surtaxes on financial services and other sector-specific taxes

6 Jun - EU: European Commission recommendations for member states in 2023 European Semester Spring Package

6 Jun - France: New proposals to counter international tax fraud, including lower turnover threshold for transfer pricing documents

6 Jun - Germany: Interim findings and outcomes from mandatory disclosure rules (DAC6) reporting

6 Jun - Greece: Guidance on temporary solidarity contribution (“windfall profits tax”) for fossil sector

6 Jun - Luxembourg: Draft law implementing DAC7

6 Jun - Spain: Foreign alternative investment fund entitled to refund of dividend withholding tax (Supreme Court decision)

6 Jun - Switzerland: Consultation on draft law implementing Pillar Two global minimum tax

5 Jun - Netherlands: Bill implementing Pillar Two presented to Lower House of Parliament

1 Jun - Germany: Lease of operating equipment ancillary to VAT-exempt lease of property, other VAT developments

May 2023

31 May - Poland: New reporting requirements for cross-border payment service providers beginning 2024

30 May - UK: Definition of “structure” for capital allowance purposes (Supreme Court decision)

30 May - UK: No time limit for seeking judicial review of adverse income tax credit determination (Court of Appeal decision)

30 May - UK: Update on mandatory disclosure rules (DAC6), now effective

25 May - Germany: Expenses for rental of moveable and immoveable assets may be subject to trade tax (Federal Tax Court decision)

25 May - Germany: Losses of permanent establishments in other EU countries not deductible (Federal Tax Court decision)

24 May - EU: VAT implications of proposed EU Customs Union Reform

24 May - EU: Update on DAC7 implementation (May 2023)

24 May - Poland: E-invoicing legislation submitted to lower house of Parliament

24 May - Poland: Excise duty on exported passenger cars not contrary to EU principles (CJEU judgment)

24 May - Poland: Insurance not subject to lump-sum income tax; scope of economic zone exemption (Supreme Administrative Court decisions)

24 May - Spain: Bill implementing DAC7; VAT, income tax, and FATCA implications for finance and insurance industries

22 May - Czech Republic: Proposed direct and indirect tax changes

19 May - Denmark: Beneficial ownership for purposes of withholding tax exemption for cross-border interest payments (court decision)

19 May - EU: Agreement on DAC8 compromise text (EU Council)

19 May - EU: Resolution proposing new taxes as own resources adopted by European Parliament

19 May - France: Tax integration scheme held incompatible with EU freedom of establishment (CJEU judgment)

18 May - Spain: Differential treatment runs contrary to free movement of capital for foreign, domestic non-UCITS funds (Supreme Court decision)

17 May - Lithuania: Temporary solidarity contribution (“windfall tax”) for credit institutions signed into law

17 May - Switzerland: Proposal to eliminate municipal business tax, increase cantonal income tax rate (Geneva)

17 May - EU: Rules for carbon border adjustment mechanism (CBAM) are effective

16 May - EU: New tax transparency rules for service providers facilitating cryptoasset transactions

16 May - Greece: Guidance on business income of individuals

16 May - Poland: Deduction limitation applies to company’s car rental payments (Supreme Administrative Court decision)

16 May - Poland: Fees for single-use plastic products

15 May - UK: Guidance on interest deduction limitation rule for loans with “unallowable purpose”

15 May - UK: Proposed changes to construction industry scheme gross payment status for subcontractors

15 May - UK: Proposed changes to payroll reporting following public consultation on data collection

15 May - UK: Proposed changes to rules on compliance errors relating to “off-payroll working”

15 May - UK: Public consultation on modernization of stamp taxes on share transfers

15 May - UK: Public consultation on new reserved investor fund regime

15 May - UK: Public consultation on simplification of construction industry scheme for contractors and deemed contractors

15 May - UK: Public consultation on taxation of lending or staking of cryptoassets

12 May - Bulgaria: No adjustment of input VAT deductions for scrapped or destroyed goods (CJEU judgment)

12 May - Cyprus: New format of tax identification number

11 May - Belgium: Changes to investment deduction under proposal for first phase of tax reform

11 May - Czech Republic: Sale of land treated as sale of goods for VAT purposes; no reverse charge for supplies of moveable items (Supreme Administrative Court decisions)

11 May - Lithuania: Temporary windfall tax for credit institutions

10 May - Denmark: Proposed interest charge on VAT, tax corrections from 1 July 2023

10 May - Malta: One-time concession on administrative penalties for failure to file recapitulative statements for VAT

10 May - Switzerland: Prior tax year losses allowed against real estate gains (Federal Supreme Court decision)

10 May - Poland: Council of Ministers adopt mandatory e-invoicing draft law

9 May - Poland: Compatibility with EU law of tax exemption for real estate forming part of railway infrastructure (CJEU referral)

9 May - Poland: Loan between VAT payers subject to capital duty; VAT on gas and energy supplies; EU directive on single-use plastics implemented

9 May - Poland: Proposed revocation of state of health emergency (COVID-19)

9 May - Italy: UK VAT groups not recognized beginning 2021

9 May - Netherlands: New guidance on mandatory disclosure rules (DAC6)

5 May - Romania: Tax rules for purely domestic mergers not required to be interpreted consistently with EU law (CJEU judgment)

4 May - Belgium: Referral by European Commission to CJEU for failure to properly transpose CFC rules under ATAD

4 May - France: Foreign tax credit on foreign-source dividends cannot exceed corporate income tax paid on such dividends (Supreme Court decision)

4 May - Germany: Guidance on use of OECD commentary in interpreting German income tax treaties

4 May - Luxembourg: European Commission erred in finding grant of State aid (CJEU Advocate General opinion)

4 May - Malta: Updated FAQs with further clarifications on DAC6 notice requirements for intermediaries

4 May - Netherlands: 2023 Spring Memorandum proposed direct and indirect tax measures

4 May - Spain: Requirement under DAC6 for intermediaries to notify other intermediaries of their reporting obligation suspended (Supreme Court decision)

3 May - Italy: Withholding tax on dividends paid to U.S. collective investment funds breaches EU law (court decision)

1 May - UK: Business premises renovation allowances not allowed (Court of Appeal decision)

1 May - UK: Final draft legislation on electricity generator levy

1 May - UK: New tax subsidy control regime

1 May - UK: Tax policy and consultation documents on modernizing, simplifying and improving the tax system

April 2023

28 Apr - Germany: Corporate income tax applicable to nonresident closed-end real estate funds held incompatible with EU law (CJEU judgment)

28 Apr - Malta: Tax measures in 2023 budget implementation law

28 Apr - Spain: New reporting requirements for cross-border payment service providers beginning 2024

27 Apr - Cyprus: Update on income tax treaty with the Netherlands

27 Apr - Estonia: Date on which taxable payment from equity determined in cross-border merger of companies (Supreme Court decision)

27 Apr - EU: VAT Committee working paper on deduction of import VAT by lessee of imported goods

27 Apr - Germany: Discussion draft of proposed changes to taxation of partnerships to conform to partnership modernization law

27 Apr - Germany: Expenses for rental of trade fair stand not subject to trade tax (federal tax court decision)

27 Apr - Germany: Proposed change to taxation of employee share ownership effective 2024

27 Apr - Slovakia: Exemption for income on corporate bonds paid to nonresidents restored

25 Apr - France: E-invoicing and digital reporting pilot program beginning January 2024

25 Apr - Germany: Consultation on implementation of B2B e-invoicing requirement effective 2025

24 Apr - Cyprus: Extension of deadline for VAT returns

24 Apr - EU: European Parliament adopts rules for carbon border adjustment mechanism (CBAM)

21 Apr - Sweden: Proposed tax law changes related to new rules for cross-border divisions, conversions and mergers between EU member states

20 Apr - Estonia: Proposed increase in corporate income tax rate

20 Apr - EU: European Commission adopts DAC7 for exchange of information with non-EU countries

20 Apr - EU: European Economic and Social Committee adopts supportive opinion on DAC8 proposal

20 Apr - Italy: Draft legislation for implementation of DAC7

20 Apr - Spain: Withholding tax on royalties must be on net basis (court decision)

18 Apr - Spain: Constitutional challenge to temporary solidarity tax on large fortunes

17 Apr - Poland: Dividends paid to foreign related entity subject to withholding tax (court decision)

17 Apr - UK: Pension tax changes in Spring Finance Bill 2023

14 Apr - Czech Republic: Compensation paid to electricity and gas suppliers subject to VAT

14 Apr - Czech Republic: Deductibility of advertising costs (Supreme Administrative Court decisions)

14 Apr - Czech Republic: Guidance on “windfall profits tax”

14 Apr - Czech Republic: Updated information on tax assessment obligations of accommodation service providers

14 Apr - Luxembourg: Draft legislation on APAs and MAP procedures, transfer pricing documentation requirements, and general tax procedures

12 Apr - Poland: Limit on deductibility for costs of intangible services; deductibility of expenses relating to opening event (Supreme Administrative Court decisions)

12 Apr - Poland: New binding rate information template

11 Apr - Ireland: EU medical devices regulations and R&D tax credits

10 Apr - Greece: Tax treatment of dividends of ship brokering and other shipping entities

6 Apr - Switzerland: Reminder of 30 June 2023 deadline to claim VAT refunds

6 Apr - Ireland: Changes to R&D tax credit, knowledge development box and digital games tax credit in Finance Act 2022

6 Apr - UK: Additional flexibility in tonnage tax regime

6 Apr - KPMG report: Global developments in ESG-related taxes, incentives, and grants (ESG tax tracker)

5 Apr - Estonia: Guidance on tax defensive measures relating to non-cooperative jurisdictions

5 Apr - Finland: Temporary “windfall profit tax” on electricity and fossil fuels sector enacted for 2023

5 Apr - EU: European Parliament committees adopt positions on anti-money laundering measures

4 Apr - EU: Updated State aid guiding templates

4 Apr - Poland: Deductibility of interest on late payments; depreciation by real estate companies (court decisions)

4 Apr - Poland: Municipality installing renewable energy systems and removing asbestos not subject to VAT (CJEU judgment)

4 Apr - Poland: Withholding tax collection mechanism; implications of Brexit for withholding tax exemption

3 Apr - Denmark: Draft legislation proposing additional reporting for VAT-exempt taxpayers

3 Apr - Italy: Draft legislation directing the government to reform the tax system

3 Apr - UK: Employee share plan changes under Spring Finance Bill 2023

3 Apr - UK: Full expensing for plant and machinery expenditures under Spring Finance Bill 2023

3 Apr - UK: Mandatory disclosure rules (DAC6) effective

3 Apr - UK: Overview of Spring Finance Bill 2023

3 Apr - UK: Tax measures relating to individuals and employers under Spring Finance Bill 2023

March 2023

30 Mar - Estonia: Amendments to taxation of income received in a pension investment account

30 Mar - Estonia: Exemption for sale of surplus electricity by small “green” producers

30 Mar - EU: Provisional agreement to reinforce EU renewable energy directive

30 Mar - Spain: Services performed by Spanish branch for foreign head office not subject to VAT (National High Court decision)

30 Mar - Sweden: Foreign tax credit carryforward allowed on income not subject to foreign tax

29 Mar - Poland: Deadline for corporate income tax filings extended to 30 June 2023

29 Mar - Poland: Limitation period for tax liabilities (COVID-19); R&D costs; real estate tax (Supreme Administrative Court decisions)

29 Mar - Poland: Public Finance Committee passes amendments to tax law, including VAT

29 Mar - Germany: Expansion of list of non-cooperative jurisdictions, implications for measures against tax havens

29 Mar - Germany: Shareholder not entitled to challenge assessment against corporation (federal tax court decision)

28 Mar - Germany: Taxation of profits from cryptocurrencies (federal tax court decision)

28 Mar - EU: New regulation to deploy sufficient alternative fuels infrastructure

28 Mar - Poland: New bill on mandatory use of national e-invoicing system

24 Mar - Belgium: “Windfall profits tax” on electricity producers enacted

24 Mar - Latvia: Tax card for 2023

23 Mar - Bulgaria: Proposal for temporary solidarity contribution (windfall profits tax) on all sectors

23 Mar - EU: VAT Committee working paper on treatment of NFTs

23 Mar - EU: European Parliament adopts recommendations from report on lessons learned from Pandora Papers

23 Mar - Germany: Public consultation on implementation of Pillar Two global minimum tax

23 Mar - Greece: Updated lists of non-cooperative jurisdictions and preferential tax regime countries

23 Mar - Lithuania: Proposal for temporary solidarity contribution (windfall profits tax) on banking sector

23 Mar - Malta: Clarifications on DAC6 notification requirements for intermediaries

23 Mar - Sweden: Proposed additions to interim report on implementation of EU global minimum tax directive

22 Mar - Belgium: Draft legislation modernizing “VAT chain” passed by Chamber of Representatives

21 Mar - Ireland: R&D tax credit changes in Finance Act 2022

21 Mar - Montenegro: Amendments to tax law, including real estate sales tax and corporate income tax

20 Mar - UK: Group relief provision compatible with EU law (Court of Appeal judgment)

17 Mar - Cyprus: Mandatory use of single tax portal for VAT payments

17 Mar - Ireland: R&D tax credit in detail

16 Mar - UK: “Spring Budget” 2023

15 Mar - EU: Temporary State aid rules adopted to support green transition

15 Mar - Netherlands: Draft bill changes to fiscal and exempt investment institution, definition of taxable mutual fund

15 Mar - Poland: Extended deadline for submitting ORD-U reports

15 Mar - Poland: Scope of debt financing expenses; taxation of cross-border employee (Supreme Administrative Court decisions)

15 Mar - Poland: Tax consultations regarding introduction of concept of VAT warehouses

13 Mar - Czech Republic: Amendment to VAT treatment of compensation paid to electricity and gas suppliers

13 Mar - Czech Republic: Ownership of goods for VAT purposes (Supreme Administrative Court decision)

13 Mar - Czech Republic: VAT, individual income tax, and road tax obligations of digital transport service providers

10 Mar - Czech Republic: Updated list of non-cooperative jurisdictions

10 Mar - Croatia: Guidance on windfall profits tax

10 Mar - EU: European Parliament study on tax compliance costs borne by European companies

10 Mar - France: Ruling on withholding tax on dividend equivalent payments

10 Mar - Greece: Determination of shipping income eligible for tonnage tax regime

10 Mar - Netherlands: Ruling on permanent establishment issues when employees work from home

9 Mar - Serbia: Tax card for 2023

8 Mar - Moldova: Tax card for 2023

8 Mar - Belgium: Proposal for first phase of tax reform

8 Mar - Netherlands: Deduction of interest not limited in active group financing companies (Supreme Court decision)

8 Mar - Spain: New tax incentive for foreign investors (Madrid)

8 Mar - Spain: Temporary solidarity tax on large fortunes

7 Mar - Poland: Potential new windfall profits tax for mining and fuel companies

7 Mar - Poland: Tax-deductible costs in revenue and expense ledgers; mutual trademark transactions

6 Mar - Cyprus: Extension of time for objecting to tax assessment notices

3 Mar - Poland: Obligation to disclose interests in real estate companies applies to non-residents

3 Mar - Romania: Tax guide for 2023

3 Mar - Serbia: Amendments to VAT rulebook

3 Mar - UK: Details of “Windsor Framework” for Northern Ireland trade and VAT issues

3 Mar - UK: Employment tax reporting for 2022/2023

3 Mar - UK: “Spring Budget” expected 15 March 2023

3 Mar - UK: Tax treatment of employee benefits-in-kind and reimbursements

2 Mar - Montenegro: Draft law on temporary solidarity contribution (windfall profits tax)

2 Mar - Netherlands: Consultation on draft bill to abolish property transfer tax concurrence exemption for share transactions

1 Mar - Germany: Reduction of the basis for assessment of VAT due to irrecoverable debts, other VAT developments

1 Mar - Hungary: Update on e-VAT system

1 Mar - Serbia: VAT refund for 2022 to foreign taxpayers

February 2023

28 Feb - KPMG report: Domestic tax rules governing family business transfers

28 Feb - Serbia: Changes to taxation of individual (personal) income

28 Feb - UK: Regulation providing online platform is liable to pay VAT is valid (CJEU judgment)

27 Feb - Austria: Summary of recent direct and indirect tax developments

27 Feb - Germany: Summary of recent federal tax court decisions

27 Feb - Italy: Withholding tax on dividends paid to investment fund breaches EU law (court decision)

27 Feb - Poland: Scope of tax rulings; due diligence obligation of tax remitters (Supreme Administrative Court decisions)

27 Feb - Poland: VAT exclusion for supply of undertaking or organized part thereof (CJEU judgment)

24 Feb - Belgium: Qualitative evaluation of whether renovations constitute new construction for VAT purposes required (court decision)

24 Feb - Malta: Electronic filing of VAT returns and payments due 22 February 2023 extended to 28 February 2023

24 Feb - Malta: One-year extension of allowance to transfer unabsorbed capital allowances intra-group

23 Feb - EU: Public consultation on implementation of regulation on foreign subsidies distorting the internal market

23 Feb - Lithuania: Indirect tax updates

23 Feb - UK: Group transfer rules not contrary to EU law (CJEU judgment)

22 Feb - Isle of Man: No major tax changes in 2023 budget

21 Feb - Denmark: New automatic check of reported VAT figures

21 Feb - Lithuania: Tax card for 2023

21 Feb - Poland: Definition of “joint venture”; deductibility of employment contract termination costs (court decisions)

21 Feb - Poland: Draft decree would extend deadline for 2022 corporate income tax returns to 30 June 2023

21 Feb - Spain: Publication of list of non-cooperative jurisdictions

20 Feb - UK: Employee share plan reporting for 2022/2023

20 Feb - UK: Guidance under new mandatory disclosure rules

20 Feb - UK: Overview of employer-financed retirement benefit schemes and related compliance obligations

14 Feb - Czech Republic: Abuse of law concept, documentation of expenses for related-party services (regional court decisions)

14 Feb - Czech Republic: Tax card for 2023

14 Feb - North Macedonia: Draft law on temporary solidarity (windfall profits) tax on fossil sector

14 Feb - Poland: Draft legislation implementing new reporting obligations for digital platform operators (DAC7)

14 Feb - Poland: Extended deadline for 2022 corporate income tax returns

14 Feb - Poland: Family foundations law signed by president

14 Feb - EU: Updates to list of non-cooperative jurisdictions (four added to “black list”, revisions to “grey list”)

13 Feb - EU: New excise duty rules in updated directive effective 13 February 2023

10 Feb - France: Tax-related provisions in finance law for 2023

10 Feb - KPMG report: Green Deal Industrial Plan

9 Feb - Switzerland: New obligation for streaming services to invest in Swiss filmmaking determined by VAT return

8 Feb - Bulgaria: Withholding tax on deemed interest on interest free loans (Supreme Administrative Court decision)

8 Feb - Denmark: Public consultation on new tax transparency rules for service providers facilitating cryptoasset transactions (DAC8)

8 Feb - EU: Notice by EC to 14 member states of noncompliance with transposition of DAC7

8 Feb - Italy: Public consultation on draft clarifications on amended patent box regime

8 Feb - Spain: Law on packaging and packaging waste

8 Feb - Sweden: Interim report on implementation of EU global minimum tax directive

8 Feb - Sweden: Referral to CJEU on withholding tax treatment of foreign public sector pension institutions

7 Feb - Romania: New reporting obligations for digital platform operators (DAC7)

6 Feb - Poland: Guidance for real estate companies, deductibility of intangible services costs incurred by acquired subsidiary (court decisions)

6 Feb - Poland: VAT rate ambiguities interpreted in taxpayers’ favor; “Slim VAT 4 package” announced

6 Feb - Sweden: Government study of potential exit taxation of natural persons suspended

6 Feb - Switzerland: Overview and case study of administrative assistance procedure under income tax treaties

6 Feb - UK: Upcoming changes to company share option plans

6 Feb - UK: Upcoming reductions in capital gains tax annual exemption for save as you earn share plans

3 Feb - Sweden: Government study of “3:12 rules” relating to taxation of dividends from closely-held companies

3 Feb - Netherlands: Interest on corporate income tax and withholding tax to increase to 10.5%

2 Feb - Netherlands: Draft bill on temporary windfall profits tax on electricity producers

2 Feb - Poland: Mandatory e-invoicing postponed until 1 July 2024

2 Feb - Spain: State aid determination annulled because aid recipients were erroneously identified (CJEU judgment)

1 Feb - Serbia: Update on income tax treaties

1 Feb - Sweden: Proposal for modernized VAT law

January 2023

31 Jan - Estonia: Company board member not liable for company’s VAT and income tax liabilities (Supreme Court decision)

31 Jan - Germany: VAT grouping, other VAT developments

31 Jan - Serbia: New practice regarding collection of tax

31 Jan - Slovakia: Tax developments (January 2023); analytical evidence of employees’ data; change in wage allowances

30 Jan - Denmark: Beneficial ownership for purposes of withholding on dividends (Supreme Court decisions)

30 Jan - EU: European Commission public consultation on DAC7 implementing regulation

30 Jan - EU: European Commission work program for first half of 2023

30 Jan - EU: Report on “Unshell” Directive proposal adopted by EU Parliament

30 Jan - Germany: 2022 Annual Tax Act

30 Jan - Germany: Dividends received by partnership not eligible for exemption under EU Parent-Subsidiary Directive (tax court decision)

30 Jan - Germany: Status of income tax treaties

30 Jan - Germany: Taxpayer satisfied “motive test“ under CFC rules (lower tax court decision)

30 Jan - Lithuania: Temporary windfall profits tax on fossil sector enacted

30 Jan - Poland: Timing of income recognition with respect to overpaid taxes, income recognition from social security contributions (Supreme Administrative Court decisions)

30 Jan - Poland: Updates on tax legislation concerning family foundations, the “legal shield,” and “Slim VAT 3 package”

30 Jan - Romania: Withholding tax on renumeration paid to non-resident service provider (CJEU Advocate General opinion)

30 Jan - Spain: Public consultation on changes to criteria for non-cooperative jurisdictions

27 Jan - Sweden: Penalties for omission of Form N9 relating to negative net interest income (Court of Appeal decisions)

27 Jan - KPMG report: Comments on public consultation on new common corporate tax system in the EU (BEFIT)

26 Jan - Montenegro: Amendments to individual and corporate income tax laws

25 Jan - Italy: 2023 budget law tax measures, including DAC7 and windfall profits tax on energy

25 Jan - KPMG report: Shipping and offshore tax update (January 2023)

25 Jan - Poland: Guidance on partnership merger, transformation (Supreme Administrative Court decisions)

25 Jan - Poland: Tax on “additional” apartments

24 Jan - EU countries: Transposition of EU directive, cross-border distributions of collective investment undertakings

24 Jan - Poland: Deadline for follow-up withholding tax statement is 31 January 2023

23 Jan - UK: Consultation on R&D tax relief reform

23 Jan - UK: Elements of nuclear decommissioning facility qualifying for plant and machinery allowances (Court of Appeal decision)

23 Jan - UK: Final mandatory disclosure rules (DAC6) regulations published

20 Jan - Albania: Changes to tax legislation effective 2023 include temporary windfall profits tax on energy producers

19 Jan - Poland: Amendments to legislation on family foundations

19 Jan - Poland: Guidance on tax rulings (Supreme Administrative Court decisions)

19 Jan - Poland: Proposed 0% VAT rate for goods and provisions to support Ukraine

19 Jan - Cyprus: New single tax administration portal

18 Jan - Cyprus: New register for self-service establishments

18 Jan - Channel Islands: Annual tax reporting for partnerships (Jersey)

17 Jan - Czech Republic: Application of thin capitalization test to interest paid on bonds (court decision)

17 Jan - Czech Republic: Guidance provided in Q&As on new reporting obligation under DAC7

17 Jan - Czech Republic: Referral to CJEU of issue relating to VAT exemption for supplies of goods to another member state when recipient is unknown

17 Jan - Greece: Instructions on procedure for adjustment of taxable profits following tax audit

17 Jan - Spain: Tax measures in 2023 budget law

13 Jan - Cyprus: Social insurance contributions for 2023

12 Jan - Italy: 2023 budget law VAT measures

12 Jan - Switzerland: Tonnage tax regime approved by National Council

11 Jan - EU: Update on DAC7 implementation

11 Jan - Hungary: Windfall profits tax on pharmaceutical companies for 2022 and 2023

11 Jan - Poland: Changes to enforcement proceedings include recovery of VAT

11 Jan - Poland: Recent tax-related developments (court decisions)

11 Jan - Sweden: License fees paid to companies not performing DEMPE functions are not deductible (court decision)

10 Jan - Bulgaria: Changes in VAT law, including reporting of data regarding cross-border payments

10 Jan - Kosovo: Introduction of tax procedures for application of income tax treaties

10 Jan - North Macedonia: Amendments to direct and indirect tax legislation

9 Jan - UK: Draft guidance on R&D tax relief reform

9 Jan - UK: Energy generator levy draft legislation

9 Jan - UK: Making tax digital for income tax self-assessment, introduction delayed and threshold increased

9 Jan - UK: New guidance on “associated companies” test for determining applicable corporation tax rate and payment deadlines

9 Jan - UK: “Time to pay” arrangements to help mitigate liquidity challenges

6 Jan - Austria: Amendments to non-cash benefits ordinance relating to electric vehicles

3 Jan - Bulgaria: Amendments to corporate income tax law, including “windfall profits tax” on fossil sector

3 Jan - EU: Overview of “plastics taxes”

3 Jan - Netherlands: VAT deduction exclusion decree on promotional gifts and staff benefits

3 Jan - Poland: Corporate income tax exemption applied to total revenue from activities performed in special economic zones (court decision)

3 Jan - Poland: Recent indirect tax-related developments

2022 Articles

December 2022

30 Dec - Serbia: Amended decree on obligation to record sales via electronic fiscal device

23 Dec - EU: Summary of tax-related initiatives in 2022

23 Dec - Norway: Changes to VAT law effective 1 January 2023

22 Dec - KPMG report: Provisional agreements in EU on emissions trading, carbon border adjustments, and climate funding

22 Dec - Italy: Obligation to report information and withhold tax on short-term rentals upheld (CJEU judgment)

22 Dec - Latvia: New reporting obligations for digital platform operators (DAC7)

22 Dec - Latvia: Amendments to law on excise tax, application of excise tax to distance sales

22 Dec - Latvia: Updates to list of low-tax or tax-free countries and territories

22 Dec - Netherlands: 2023 Tax Plan adopted by upper house of Parliament, including DAC7, windfall profits tax on fossil sector

22 Dec - Spain: “Start-ups law” adopted

22 Dec - Serbia: Changes to property taxes law

22 Dec - Serbia: Changes to the law on e-invoicing

21 Dec - Serbia: Changes to tax procedure and administration law

21 Dec - Serbia: Changes to VAT law

21 Dec - Serbia: Changes to customs law

21 Dec - Belgium: Proposed changes to taxation of copyright income earned by individuals

20 Dec - Poland: Legislation on family foundations passed by lower house of Parliament

20 Dec - Netherlands: Tax developments concerning financial institutions (December 2022)

19 Dec - Netherlands: Elimination of real estate fiscal investment institution

19 Dec - Belgium: Limitation of corporate tax deductions in assessment year 2024

16 Dec - Belgium: New obligations of digital platform operators (DAC7)

16 Dec - EU: Council adopts EU minimum tax directive

16 Dec - Switzerland: Parliament approves constitutional amendment to implement Pillar Two global minimum tax

16 Dec - Greece: Tax provisions in new laws, shipping taxation developments

16 Dec - Luxembourg: 2023 budget law passed by Parliament

16 Dec - Serbia: Changes to individual income tax and social security contributions

15 Dec - Serbia: Amendments to “fiscal law”

14 Dec - Netherlands: Referral to CJEU of issue relating to taxation of dividend income received by non-resident insurance company

14 Dec - EU: Provisional agreement reached on carbon border adjustment mechanism

14 Dec - EU: Proposal to extend tax transparency rules to cryptoassets

13 Dec - EU: VAT gap statistics for 2020

13 Dec - Austria: Summary of recent direct and indirect tax developments

13 Dec - Czech Republic: Application of VAT to fuel cards

13 Dec - Czech Republic: Taxpayer entitled to deduct VAT on supply within fraudulent transactions chain (Supreme Administrative Court decision)

13 Dec - Czech Republic: Windfall profits tax on surplus market revenues of electricity producers

13 Dec - Poland: Application of general anti-avoidance clause (GAAR)

13 Dec - Poland: 50% restriction on the right to deduct input VAT on certain vehicles extended

9 Dec - Slovakia: Changes to transfer pricing rules and limitations on deductibility of interest

9 Dec - Slovakia: New meal allowance amounts effective 1 January 2023

9 Dec - UK: HMRC response to consultation on basis period reform issues

9 Dec - UK: Income tax treaty with Brazil signed

9 Dec - UK: Report of national audit office on operation and implementation of digital services tax

9 Dec - EU: Requirement under DAC6 for intermediaries to notify other intermediaries of their reporting obligation is invalid under EU law (CJEU judgment)

8 Dec - EU: European Commission proposals to modernize and digitalize VAT system

8 Dec - EU: European Commission proposes new tax transparency rules for service providers facilitating cryptoasset transactions

8 Dec - Germany: Ownership of majority voting rights as requirement to form VAT fiscal unity (CJEU judgment)

8 Dec - Poland: Draft legislation making e-invoicing mandatory effective 1 January 2024

8 Dec - Slovakia: Amendment to VAT law approved

7 Dec - Croatia: Income tax treaty with United States signed

7 Dec - Estonia: Recent tax-related developments, including reporting obligations for digital platform operators (DAC7)

6 Dec - Italy: Proposed PE exemption for investment manager activities

5 Dec - Italy: Update on withholding tax on dividends paid to investment funds and related refund opportunities

5 Dec - Belgium: Reform of periodic VAT returns, debts

2 Dec - Belgium: Election to determine VAT deduction on basis of actual use

1 Dec - Belgium: Assessment periods for income tax and VAT extended

1 Dec - Austria: Proposal for temporary windfall profits tax on fossil sector

1 Dec - Finland: Clarifications on DAC7 reporting obligations

1 Dec - Ireland: Proposal for temporary windfall profits tax on fossil sector

1 Dec - Spain: Reverse hybrid mismatch rules introduced

November 2022

30 Nov - EU: Regulation on foreign subsidiaries distorting the internal market approved by EU Council

30 Nov - Germany: Guidance on stock exchange exception under real estate transfer tax

30 Nov - Germany: Law on DAC7, submitting transfer pricing documentation in tax audits, adopted by lower house of Parliament

30 Nov - Germany: No exit tax resulting from amendment of income tax treaty (fiscal court decision)

30 Nov - Italy: New rules on import VAT recovery

30 Nov - Poland: Legislation on family foundations passed by government

30 Nov - Poland: Royalty payments to beneficial owner outside EEA not eligible for withholding tax exemption (court decision)

30 Nov - Poland: Updated “SLIM VAT 3 package”; suspension of duty on imported alcohol intended for production of medicines upheld

29 Nov - Netherlands: Floating solar park not considered immovable property subject to property tax (court decision)

29 Nov - Belgium: Interest on foreign regulated savings deposits exempt from individual income tax (court decision)

28 Nov - Belgium: Changes to the reverse-charge mechanism for immovable property

28 Nov - Croatia: Proposal for windfall profits tax

28 Nov - Cyprus: Amendment regarding imposition of VAT on supply of buildings

28 Nov - Cyprus: Amendments regarding tax payable on sales of immovable property

28 Nov - EU: Anti-money laundering measure allowing access to beneficial ownership information held invalid (CJEU judgment)

28 Nov - UK: Advisor fees related to potential disposal of subsidiary treated as non-deductible capital expenses (Court of Appeal decision)

28 Nov - UK: Proposed changes to taxation of income from residential property

23 Nov - Sweden: Proposed legislation on cross-border divisions, conversions and mergers between EU member states

22 Nov - Poland: Proposed amendment to tax on certain financial institutions

22 Nov - Poland: Ratification of treaty with Georgia; MCAA for automatic information exchange under digital platform reporting rules signed

22 Nov - Poland: Recent VAT-related developments (court decisions)

18 Nov - Finland: Changes to taxation of non-residents’ capital gains derived from Finnish real estate

18 Nov - Spain: Wealth tax-related legislative proposals

18 Nov - Sweden: Proposed legislation on cross-border divisions, conversions and mergers between EU member states

17 Nov - UK: Tax proposals in Autumn statement

17 Nov - Lithuania: New legislation for VAT deduction on purchased electric cars

16 Nov - Austria: Changes to reclaim procedure for withholding taxes on dividend distributions

16 Nov - Belgium: Amendments to VAT statute of limitations, retention period and applicable interest rates

16 Nov - Denmark: DAC7 guidance

16 Nov - EU: Public consultation on new common corporate tax system in the EU (BEFIT) extended to 26 January 2023

16 Nov - Poland: Proposed amendment to tax on financial institutions; guidance on tax micro-accounts

15 Nov - Hungary: Draft legislation introducing tax-related amendments

15 Nov - Netherlands: VAT recovery based on bank’s “actual use method” (Supreme Court decision)

14 Nov - Italy: Intermediate holding companies in private equity structures served genuine, non-tax purpose (court decisions)

14 Nov - Spain: Amendments to proposed windfall profits tax on banks

11 Nov - UK: Autumn statement expected 17 November 2022

11 Nov - UK: Tax considerations for cross-border hybrid and remote working

11 Nov - UK: Tax considerations for hybrid and remote working within the UK

10 Nov - Czech Republic: Penalty for filing VAT ledger statement for incorrect taxable period struck down (Supreme Administrative Court decision)

10 Nov - EU: ECOFIN Council agrees on revised Code of Conduct for Business Taxation

10 Nov - Netherlands: Concept of “essentially a new building” for VAT purposes (Supreme Court decision)

10 Nov - OECD: Jurisdictions sign MCAA for automatic information exchange under digital platform reporting rules, CRS disclosure rules

10 Nov - Poland: New draft legislation on family foundations

9 Nov - Poland: Cashback discounts do not reduce output tax; correcting invoice does not reduce taxable base (administrative court decisions)

9 Nov - Poland: Draft legislation guidelines of reporting obligations for digital platform operators (DAC7)

9 Nov - Poland: Proposed amendments to sugar fee; extension for declarations relating to special purpose cash registers

8 Nov - Belgium: Retroactive application to 2016 of annual tax on credit institutions struck down (Constitutional Court decision)

8 Nov - Czech Republic: “Windfall profits tax” on fossil sector and banks approved by Parliament

8 Nov - Germany: Loss recognized on settling option can be carried back to offset related income earned in earlier year

8 Nov - Luxembourg: Finding of illegal State aid involving application of arm’s length principle set aside (CJEU judgment)

8 Nov - Sweden: Tax proposals in 2023 budget include cross-border payment reporting, extension of diesel excise tax reduction

7 Nov - Netherlands: Class-action-plus procedure for ex-officio reduction in “Box 3” (wealth tax) liability

4 Nov - Netherlands: Updated policy statement on hybrid mismatches, deduction allowed in cost-plus situations

3 Nov - Netherlands: Dynamic interpretation of tax treaties (Supreme Court decision)

3 Nov - Netherlands: Draft legislation for temporary solidarity contribution or “windfall profits tax” on fossil sector for 2022

3 Nov - Austria: Inflation relief-related tax measures, DAC7 implementation, guidance on crypto taxation, updated VAT guidelines, other tax developments

3 Nov - Czech Republic: Revised list of non-cooperative jurisdictions for CFC rules

3 Nov - FinlandDraft legislation to implement DAC7

3 Nov - Ireland: Finance Bill 2022 amendments to residential zoned land tax

3 Nov - Portugal: Tax measures in 2023 budget, including new crypto tax regime

3 Nov - Spain: Dynamic interpretation of tax treaties (Supreme Court decision)

1 Nov - Germany: Deduction of input VAT on “outplacement consultation” services, other VAT developments

1 Nov - Poland: Government approves extension of excise tax exemption for plug-in electric vehicles

1 Nov - Poland: New draft bill to implement EU single-use plastics directive

1 Nov - Poland: Recent tax developments related to debt for equity swaps, deductibility of team-building event costs (Supreme Administrative Court decisions)

October 2022

31 Oct - Belgium: Tax on securities accounts upheld, but certain anti-abuse measures struck down (Constitutional Court decision)

31 Oct - Spain: Report on compulsory electronic invoicing for traders and professionals

28 Oct - Lithuania: Right to charge VAT on sale of immovable property to VAT payer (CJEU judgment)

28 Oct - Netherlands: Proposed legislation implementing cross-border payment reporting obligation beginning 2024

28 Oct - UK: Update on policy announcements in Chancellor’s “growth plan”; full autumn statement expected 17 November 2022

27 Oct - Cyprus: Reverse-charge mechanism applicable to acquisition of precious metals

27 Oct - Germany: Taxpayer may benefit from preferential treatment under any applicable income tax treaty (tax court decision)

27 Oct - Germany: Trade tax treatment of dividend from dual resident corporation (tax court decision)

27 Oct - Spain: VAT proposals in draft 2023 budget law

25 Oct - Malta: Tax measures in budget 2023

25 Oct - Belgium: Limitation on dividends received deduction surpluses carried over to absorbing company compatible with EU law (CJEU judgment)

25 Oct - Poland: Proposed amendments to sugar tax and fee on alcohol; other tax developments

24 Oct - Poland: Legislation amending corporate income tax measures in “Polish Deal” passed

21 Oct - Denmark: Recent changes to share-based investment companies investor tax reporting

21 Oct - Spain: Financial measures in “Creation and Growth Law”

21 Oct - Sweden: Availability of tax exemption for electricity and fuel consumed in industrial activities

20 Oct - Ireland: Tax measures in Finance Bill 2022

20 Oct - EU: Solidarity contribution on surplus profits in the fossil sector adopted by EU Council

20 Oct - Hungary: Availability of online cash register data via online invoice system

20 Oct - Hungary: Reconsideration of electronic VAT system to machine-to-machine concept

20 Oct - Spain: Proposal for new tax measures to combat inflation, including new wealth tax

20 Oct - Czech RepublicDetails of proposed “windfall profits tax” announced

20 Oct - Poland: Draft legislation to introduce “windfall profits taxes” on large enterprises

20 Oct - Sweden: Proposal for “windfall profits tax”

19 Oct - Malta: Mandatory online filing of VAT returns for certain registered persons

19 Oct - Poland: Clarifications regarding VAT grouping; criteria for identifying a fixed establishment for VAT purposes

18 Oct - EU: Call for evidence and public consultation on new common corporate tax system in the EU (BEFIT)

17 Oct - KPMG report: Comments in response to EC public consultation on the SAFE initiative

17 Oct - Poland: Services provided by securitization fund to bank/investment fund qualified as “granting of credit” for VAT purposes (CJEU judgment)

17 Oct - UK: Proposed changes to additional rate of income tax and corporation tax rate will no longer proceed

17 Oct - UK: Repeal of “off-payroll working” rules from 6 April 2023

14 Oct - Luxembourg: Tax proposals in budget 2023, property tax reform

14 Oct - Greece: Tax measures in new law

14 Oct - Spain: Compulsory electronic invoicing between traders and professionals

13 Oct - Belgium: Tax proposals in budget 2023-2024 include “windfall profits tax” on energy producers

11 Oct - Czech Republic: Extension of excise movement and control system (EMCS)

11 Oct - Czech Republic: Proposed legislation on cross-border conversions, mergers and divisions between EU member states

11 Oct - Lithuania: Supply recipient may deduct VAT even though supplier did not pay output VAT (CJEU judgment)

6 Oct - EU: Report on EU Parliament meeting with European Commissioner; discussion of solidarity contribution on surplus profits in fossil sector, minimum tax directive

6 Oct - Lithuania: Draft law on implementation of DAC7 rules for digital platform operators

6 Oct - Netherlands: Memorandum of amendment to 2023 Tax Plan includes “windfall profits tax” on natural gas sales

6 Oct - Spain: Reductions in individual income tax rates and repeal of wealth tax for 2022 tax year (Andalusia)

5 Oct - Sweden: Proposed legislation on cross-border divisions, conversions and mergers between EU member states

4 Oct - EU: Updates to list of non-cooperative jurisdictions

4 Oct - Germany: Disallowance of final losses incurred by UK permanent establishment upheld (CJEU judgment)

4 Oct - Switzerland: New VAT rates, updates to e-filing portal

3 Oct - Poland: Recent tax developments relating to holding structure, deduction cap for intangible services (Supreme Administrative Court decision)

September 2022

30 Sep - UK: Overview and analysis of Chancellor’s “growth plan”

30 Sep - Belgium: Guidance on VAT refund procedures and remunerations in football

30 Sep - Portugal: EU General Court upholds EC’s determination that tax benefits in Madeira free zone not correctly applied

30 Sep - Slovakia: Proposed changes to transfer pricing rules and limitations on deductibility of interest

29 Sep - Ireland: Additional reports on tax proposals in budget 2023

29 Sep - Italy: Swiss social security institute entitled to withholding tax refund; possible refund opportunities (Supreme Court decision)

29 Sep - Spain: Challenge to Spanish tax leasing system (CJEU Advocate General opinion)

28 Sep - Germany: Draft legislation for 2022 Annual Tax Act

28 Sep - Germany: Draft legislation on implementation of DAC7 and modernization of tax procedures law

28 Sep - Germany: Withholding tax exemption denied (lower tax court decision)

27 Sep - Ireland: Tax proposals in budget 2023

27 Sep - Luxembourg: Temporary 1% decrease of VAT rates

23 Sep - UK: Tax relief measures and tax cuts in Chancellor’s “growth plan”

23 Sep - Netherlands: Payroll tax measures in 2023 Tax Plan

23 Sep - Austria: Proposed inflation relief-related tax measures, excise movement and control system, stamp tax exemption, other tax developments (COVID-19)

22 Sep - Finland: Withholding tax refunds for Luxembourg SICAV funds

21 Sep - Netherlands: Income and indirect tax measures in 2023 Tax Plan

19 Sep - Belgium: DAC6 legislation held invalid, questions raised to CJEU (Constitutional Court decision)

19 Sep - UK: Fiscal announcement expected 23 September 2022, potential tax implications

19 Sep - UK: Government report on tax implication of domestic and cross-border remote working arrangements

19 Sep - UK: Increased HMRC scrutiny of R&D claims

16 Sep - Finland: Plan to introduce “windfall profit tax” on energy announced

16 Sep - Greece: Guidance on “windfall profit tax” on energy companies, equal treatment of EU and UK dividends in FY 2021

16 Sep - Luxembourg: Updated time thresholds for cross-border workers under certain income tax treaties

16 Sep - Malta: Temporary reduced tax and duty rates on immovable property extended until June 2023 (COVID-19)

16 Sep - Romania: Expansion of “windfall profit tax” on energy companies, extension to March 2023

16 Sep - Spain: Tax-related provisions in revised insolvency law

16 Sep - UK: Anti-treaty shopping rule under Irish treaty did not apply to deny withholding tax relief on interest income (court decision)

15 Sep - EU: Proposed regulation would provide for solidarity contribution on surplus profits in EU fossil sector

15 Sep - Belgium: Notional interest deduction for assessment year 2024

15 Sep - Gibraltar: Rule preventing double taxation of amounts recovered as unlawful state aid may be applied (CJEU judgment)

15 Sep - Netherlands: Lower House of Parliament passes bill on excessive borrowing from a taxpayer's own companies

15 Sep - UK: Regulation providing online platform is liable to pay VAT is valid (CJEU Advocate General opinion)

14 Sep - UK: Taxation of cross-border intragroup asset transfer not contrary to EU law (CJEU Advocate General opinion) 

14 Sep - EU: Proposal to ban products made with forced labor from the EU market

14 Sep - Germany: Holding company has no right to recover VAT on services contributed to subsidiary (CJEU judgment)

14 Sep - Poland: Initial schedules for funding under recovery plan for 2022-2023

13 Sep - Czech Republic: Proposed record keeping and reporting obligation for payment service providers beginning 2024

13 Sep - Czech Republic: Working paper on possible “windfall tax”

13 Sep - Ireland: Budget 2023 scheduled to be announced 27 September 2022

12 Sep - Spain: Deadline to claim VAT refunds for 2021 is 30 September 2022

8 Sep - Denmark: VAT corrections and errors subject to 30% interest surcharge

8 Sep - Italy: Legislation to accelerate tax dispute resolution and improve tax court efficiency

8 Sep - Italy: Withholding tax on dividends paid to U.S. pension funds; refund opportunities (Supreme Court decisions)

7 Sep - Netherlands: Tax developments concerning financial institutions (September 2022)

6 Sep - Sweden: Proposal to repeal energy tax relief for computer server facilities, tax on waste incineration

6 Sep - Poland: Draft decree proposes changes to national e-invoicing system

6 Sep - Poland: Proposed increase to thresholds for declarations on goods transported within EU

6 Sep - Poland: Recent tax developments relating to company reorganizations, lump-sum income tax, e-signing returns

6 Sep - UK: Updated HMRC guidance on making tax digital for income tax self-assessment

2 Sep - Cyprus: Non-deductible input VAT on acquisition of apartment under Cypriot Investment Program (tribunal decision)

1 Sep - Slovenia: Reduced VAT rate on energy effective 1 September 2022

1 Sep - Switzerland: Update on special arrangements for cross-border workers (COVID-19)

August 2022

30 Aug - Malta: Record keeping and reporting obligations for payment service providers beginning 2024

29 Aug - EU: Implications of carbon border adjustment mechanism

29 Aug - Poland: Draft bill includes amendments to “Polish Deal” corporate income tax measures

29 Aug - Poland: Extension of excise tax exemption for plug-in electric vehicles and anti-inflation measures

29 Aug - Poland: Recent tax developments relating to robotization (Supreme Administrative Court decision)

26 Aug - Bulgaria: MLI ratified

26 Aug - EU: Taxation-based obstacles and distortions in cross-border investment; regulation of intermediaries in the EU (European Parliament)

26 Aug - EU: Opinion on taxation of cross-border teleworkers (European Economic and Social Committee)

26 Aug - OECD: Peer review reports on transparency and exchange of information on request

26 Aug - Finland: Mandatory disclosure rules (DAC6) reporting assessment published

26 Aug - Slovenia: Public consultation on implementation of directive for income earned by digital platforms (DAC7)

26 Aug - Switzerland: Public consultation on draft ordinance regulating minimum taxation in Switzerland (Pillar Two)

25 Aug - Luxembourg: Penalties related to real estate levy reporting obligation assessed

24 Aug - Germany: Extension of simplification procedure for non-resident tax liability when rights listed in domestic registers

24 Aug - Germany: Law amending interest on back taxes and tax refunds effective 22 July 2022

24 Aug - Germany: Proposed changes to “register cases,” depreciation for residential buildings, VAT recording and reporting

24 Aug - Germany: Real property management company premises can be permanent establishment of contracting company (tax court decision)

24 Aug - Germany: Withholding taxes on cross-border payments for software development

23 Aug - KPMG report: Implementation of ATAD I and II by EU Member States

22 Aug - Poland: Deductibility of expenses incurred on behalf of third party; required information for individual ruling (court decisions)

22 Aug - Poland: Customs post in Pulawy removed from list that can handle exports, imports, and transit of strategic goods

22 Aug - UK: HMRC guidance on errors in coronavirus job retention scheme (CJRS) calculations (COVID-19)

22 Aug - UK: Trust registrations due 1 September 2022

19 Aug - KPMG report: European Commission business tax agenda

17 Aug - Poland: Recent tax developments relating to company reorganizations

17 Aug - Poland: Summary of recent indirect tax developments

12 Aug - Ireland: Overview of funding mechanisms for research and development (R&D)

10 Aug - Italy: Criteria for selecting MNE taxpayers for audits

9 Aug - Czech Republic: Guidance provided in Q&As on cross-border arrangement reporting under DAC6

9 Aug - Poland: Tax authority’s access to banking information of taxpayers subject to proceedings

8 Aug - UK: Commercial transaction structured in tax-efficient way did not have “main purpose” of tax avoidance (court decision)

8 Aug - UK: HMRC “claw back” of coronavirus job retention scheme (CJRS) grants for noncompliance (court decision)

8 Aug - UK: Tax positions of candidates for Conservative Party leadership (prime minister)

5 Aug - Austria: Implementation of DAC7 and reporting requirements for digital platform operators

5 Aug - Belgium: Guidance on taxation of cryptocurrency and NFTs; corporate income tax measures in tax reform proposals

5 Aug - France: Status of windfall profits tax proposal

5 Aug - Germany: Proposed changes to the taxation of payments for IP rights

5 Aug - Spain: Proposal for windfall profit taxes on energy companies and banks

4 Aug - Gibraltar: Budget 2022 measures affecting companies

2 Aug - EU: Proposed directive for debt-equity bias reduction allowance and limiting deductibility of interest for corporate income tax purposes (KPMG comments on DEBRA proposal)

2 Aug - Greece: Measures regarding customs duties for intra-Community transfer of goods, other customs provisions

2 Aug - Poland: Draft bill to implement EU single-use plastics directive

2 Aug - Poland: Summary of recent indirect tax developments

July 2022

29 Jul - Cyprus: Operation of registry of beneficial owners; extended deadline for individual income declaration of 31 August 2022

29 Jul - Lithuania: VAT relief to support Ukraine

26 Jul - Poland: Real estate tax rates on land and buildings; tax-deductible costs of sale of real estate

26 Jul - Romania: Summary of recent tax law changes, including VAT and excise tax

25 Jul - UK: Draft legislation for Finance Bill 2023 and several consultation responses published on “L Day”

25 Jul - UK: Draft legislation for R&D tax changes planned for 2023

25 Jul - UK: HMRC consultation on collecting data from taxpayers

25 Jul - UK: “Windfall tax” on extraordinary oil and gas profits receives Royal Assent

22 Jul - EU: Infringement procedures against UK for not complying with parts of Ireland / Northern Ireland Protocol

22 Jul - Ireland: BEPS 2.0 implications for aviation sector

22 Jul - Slovenia: Increased “fire fee” rate, effective 1 October 2022

21 Jul - EU: Tax-related developments from CJEU, EU Council, European Commission, and EU Parliament

20 Jul - Greece: Legislation incorporating ATAD measures for reverse hybrid instruments

19 Jul - Netherlands: Update on consultation regarding options to address dividend stripping

19 Jul - Poland: Pre-consultation on assumptions for digital platform owners (DAC7)

19 Jul - Poland: Remarks to draft VAT bill; consultation on VAT groupings; proposed amendments to excise tax guarantee provisions

18 Jul - Czech Republic: Tax priorities of the Czech EU Presidency

18 Jul - Czech Republic: Waiver of default interest on VAT granted (Supreme Administrative Court decision)

18 Jul - Netherlands: Interest deductions in acquisition structures (Dutch Supreme Court)

16 Jul - Hungary: Income tax treaty terminated by United States

15 Jul - Germany: Proposals including transposition of DAC7

14 Jul - Bulgaria: Changes in VAT, excise tax (duties), and fuel relief (compensation) legislation

14 Jul - EU: Update on minimum tax directive; priority of new presidency of the European Council

14 Jul - Italy: Withholding tax on dividends paid to U.S. collective investment funds; refund opportunities (Supreme Court decision)

12 Jul - Poland: Excise duty regulations compliant with EU directive, VAT on chain transactions (CJEU action)

12 Jul - Poland: Proposed suspension of tax on certain interest

11 Jul - UK: Closer look at consultation on tax immunity for sovereign investors

11 Jul - UK: Guidance on operation of making tax digital for income tax self-assessment; comments requested

8 Jul - Netherlands: Policy statement on VAT fixed establishments reflects position change

7 Jul - Italy: Withholding tax on services provided by property intermediation platform via internet (CJEU Advocate General opinion)

7 Jul - UK: Consultation on tax treatment of foreign sovereign investors

6 Jul - Gibraltar: Tax measures in budget 2022

6 Jul - Hungary: Financial transaction tax extended to cross-border payment services

5 Jul - France: Tax authorities issue revised guidelines regarding VAT “option to tax” for financial services

5 Jul - Netherlands: Policy statement on “Box 3” (wealth tax) restoration of rights

5 Jul - EU: Tax-related actions of CJEU, EU Council, European Commission, and EU Parliament

1 Jul - Poland: Proposed legislation includes amendments to “Polish Deal” corporate income tax measures, transfer pricing changes

1 Jul - EU: Waiver of customs duties and VAT on import of “life-saving goods” to Ukraine

1 Jul - Netherlands: Temporary reduction in VAT on energy and excise duties on fuel

1 Jul - Switzerland: Arrangements for French cross-border workers extended through 31 October 2022 (COVID-19)

June 2022

30 Jun - KPMG report: Transition to new transmitter control code application for FIRE reporting, considerations for Swiss banks

29 Jun - Slovakia: Implementation of EU directive on reporting obligations of digital platforms (DAC7)

29 Jun - Slovakia: Proposals to support businesses approved (COVID-19)

29 Jun - Slovakia: Proposed changes to VAT law

29 Jun - Switzerland: Real estate “step-up” now available in Geneva

28 Jun - Belgium: Temporary VAT rate reduction for face masks, supplies of electricity, gas, and heat (COVID-19)

28 Jun - Germany: Amended dual consolidated loss rule cannot be applied retroactively (lower tax court decision)

28 Jun - Germany: Amendment to interest on back taxes and tax refunds

28 Jun - Germany: Application of anti-treaty/directive shopping rule to interest on convertible bond (tax court decision)

28 Jun - Germany: Fourth coronavirus tax assistance act enacted (COVID-19)

28 Jun - Germany: Legislation providing for energy-related lump-sum payment for employees enacted

28 Jun - KPMG report: Shipping and offshore tax update (June 2022)

28 Jun - Poland: Extension of filing deadline for corporate income tax return

28 Jun - Poland: Meaning of “one-off transaction value”; dividend income taken into account in allocating indirect costs (Supreme Administrative Court decisions)

27 Jun - Estonia: Reduced VAT on media outlets and excise duty on special-purpose diesel fuel

27 Jun - Serbia: Reminder of 1 July 2022 deadline for certain e-invoice obligations

27 Jun - UK: Background and implications of delayed implementation of Pillar Two

27 Jun - UK: Draft legislation for “windfall tax” on extraordinary oil and gas profits

27 Jun - UK: Payment of qualifying tax-free bonuses by employee-owned companies

24 Jun - Austria: R&D measures in proposed legislation, “green taxes,” group tax rules, other developments

23 Jun - Denmark: New VAT rules regarding transport services

22 Jun - Cyprus: Reduced rate of 3% tax on interest from certain savings certificates and bonds

22 Jun - Germany: Dividend withholding tax refund rules; reimbursing withholding tax on dividends received from portfolio investments (CJEU judgment) 

21 Jun - Poland: Transactions involving alternative investment company; ruling providing tax exemption applies to all manufacturing income

21 Jun - Poland: Update on mandatory e-invoicing, proposed extension of 0% VAT rate to support Ukraine

20 Jun - EU: Report of ECOFIN to European Council on tax issues including Pillar Two, minimum tax, harmful tax practices, preferential tax regimes, non-cooperative jurisdictions

17 Jun - EU: Proposal for EU minimum tax directive; update after ECOFIN Council meeting

17 Jun - Belgium: FAQs on VAT treatment of furnished accommodations

17 Jun - Denmark: Interest surcharges for tax corrections, including for VAT, enacted

17 Jun - EU: Latest court decisions, CJEU referral, EC and European Parliament developments

17 Jun - Sweden: Property tax investigation regarding industrial properties

16 Jun - Sweden: Revised proposal for legislation regarding withholding tax on dividends

16 Jun - KPMG report: Update on tax control framework requirements

 

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