International Tax Europe and Africa August 2023
This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Europe and Africa Regions between 1 August and 31 August 2023.
For a full summary of global tax developments, visit kpmg.com/TaxNewsFlash.
To contact the International Tax Team email internationaltax@kpmg.com.
To register for the International Tax webcasts, click here.
Bulgaria
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Bulgaria |
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Tax legislation approved and regulatory update |
Tax Compliance |
01 August 2023 |
Amendments to beneficial owners registry law. Read more. |
Croatia
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Croatia |
|||
Tax legislation approved and regulatory update |
Tax compliance |
04 August 2023 |
Implementation of the EU Public Country-by-Country Reporting Directive. Read more. |
European Union
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
European Union |
|||
Administrative and case law |
Indirect tax |
29 August 2023 |
Carbon Border Adjustment Mechanism (CBAM) and the European Union Emissions Trading System (ETS) reform challenged in front of the CJEU. Read more. |
Tax legislation approved and regulatory update |
Indirect tax |
17 August 2023 |
Implementing rules for transitional phase of CBAM adopted. Read more. |
| Tax legislation approved and regulatory update | Tax compliance | 04 August 2023 | Reasoned opinion sent to several Member States for incomplete transposition of DAC7 into national law. Read more. |
| Tax legislation approved and regulatory update | Tax compliance | 04 August 2023 | Letter of formal notice sent to multiple Member States for failure to notify the transposition of the EU Public Country-by-Country Reporting Directive. Read more. |
Finland
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Finland |
|||
Proposed Legislation |
BEPS |
29 August 2023 |
Public consultation launched on a legislative proposal to implement minimum taxation (Pillar Two). Read more. |
Germany
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Germany |
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Proposed Legislation |
Income tax |
28 August 2023 |
Tax measures in draft bill for law on future financing, other tax developments. Read more. |
| Proposed legislation | Tax compliance |
02 August 2023 | Draft guidance on hybrid mismatch rules. Read more. |
| Proposed legislation | Income tax | 02 August 2023 | Draft guidance on controlled foreign corporations rules. Read more. |
| Tax legislation approved and regulatory update | Tax compliance |
01 August 2023 | Updated Common Reporting Standards (CRS) guidance, final state exchange list. Read more. |
Hungary
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
|
|||
Tax legislation approved and regulatory update |
Income Tax |
09 August 2023 |
Corporate income tax credit for “net zero” investments. Read more. |
Tax legislation approved and regulatory update |
Tax Compliance |
04 August 2023 |
Letter of formal notice sent to Hungary to align its corporate income tax rules with Anti-Tax Avoidance Directive. Read more. |
Ireland
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Ireland |
|||
Tax legislation approved and regulatory update |
BEPS |
04 August 2023 |
Release of Feedback Statement regarding Pillar Two application. Read more. |
Italy
Administrative and case law |
Income Tax |
04 August 2023 |
Supreme Court decision on beneficial ownership of domestic interest payments. Read more. |
Jersey
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Jersey |
|||
Tax legislation approved and regulatory update |
Tax Compliance |
30 August 2023 |
Channel Islands: Closure of FATCA and CRS reporting portal (Jersey). Read more. |
Luxembourg
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Luxembourg |
|||
Administrative and case law |
Tax compliance |
29 August 2023 |
Ruling on the beneficial ownership of a trademark. Read more. |
| Proposed legislation | BEPS | 10 August 2023 | Draft law implementing Pillar Two global minimum tax. Read more. |
| Administrative and case law | Tax compliance | 04 August 2023 | Luxembourg referred to CJEU for failing to correctly transpose the interest limitation rules under Anti-Tax Avoidance Directive. Read more. |
Netherlands
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Netherlands |
|||
Proposed Legislation |
Tax compliance |
29 August 2023 |
Draft legislation to implement the European Union Public Country-by-Country Reporting Directive adopted by the House of Representatives. Read more. |
OECD
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
OECD |
|||
Tax legislation approved and regulatory update |
Tax Compliance |
09 August 2023 | Cryptoasset reporting framework updates and common reporting standards amendments. Read more. |
| Proposed legislation | BEPS | 03 August 2023 | KPMG report: Amount B and tax certainty. Read more. |
Poland
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Poland |
|||
Administrative and case law |
Various tax topics |
29 August 2023 |
Application of general anti-abuse rule, taxation of restricted stock, taxation of company conversion. Read more. |
| Tax legislation approved and regulatory update | Tax compliance | 29 August 2023 | Extended deadline for tax on unrealized gains, guidance on capital duty. Read more. |
| Administrative and case law | Various tax topics | 22 August 2023 | Tax-deductible costs, income from IP and credit default swaps. Read more. |
| Tax legislation approved and regulatory update | Income tax | 22 August 2023 | Reduced depreciation period for buildings and non-building structures. Read more. |
| Administrative and case law | Various tax topics | 01 August 2023 | Recordkeeping for Intellectual Property Box, cash as tax-deductible cost, residential property used in business, taxation of agricultural. Read more. |
Portugal
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Portugal |
|||
Tax legislation approved and regulatory update |
Tax compliance |
30 August 2023 |
Public Country-by-Country Reporting legislation approved. Read more. |
South Africa
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
South Africa |
|||
Proposed legislation |
Income tax |
08 August 2023 |
Non-resident employers to register and withhold employees' Tax. Read more. |
| Proposed legislation | Income tax | 07 August 2023 | Draft legislation would require non-resident employers to register with South African Revenue Service (SARS), withhold employees’ tax. Read more. |
| Proposed legislation | Income tax | 04 August 2023 | Proposed amendments to section 11D Research & Development tax incentive. Read more. |
| Proposed legislation | Income tax | 04 August 2023 | Draft legislation allowing limited deduction of expenses incurred by companies not trading. Read more. |
| Proposed legislation | Income tax | 03 August 2023 | Proposed temporary expansion of renewable energy tax incentive. Read more. |
| Proposed legislation | Transfer pricing | 02 August 2023 | Proposed Advance Pricing Agreement (APA) program. Read more. |
Spain
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Spain |
|||
Administrative and case law |
Tax compliance |
29 August 2023 |
Spanish Supreme Court establishes that burden to prove abuse lies with the Spanish tax authorities. Read more. |
Tunisia
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
Tunisia |
|||
Tax legislation approved and regulatory update |
Tax compliance |
23 August 2023 |
Instrument of ratification of Multilateral Convention deposited with OECD. Read more. |
United Kingdom
Tax area concerned |
Relevant date |
Description of measures and publication link |
|
United Kingdom |
|||
Tax legislation approved and regulatory update |
Transfer Pricing |
29 August 2023 |
His Majesty's Revenue & Customs publishes policy paper on reporting rules applicable to digital platforms. Read more. |
Tax legislation approved and regulatory update |
Income tax |
29 August 2023 |
New His Majesty's Revenue & Customs guidance on net-settled and cash cancelled employee share awards. Read more. |
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