International Tax Europe and Africa November 2024
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 November and 30 November 2024.
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
Bulgaria | |||
Administrative and case law | Indirect tax | 27 November 2024 | Scope of supply of services under Value Added Tax (VAT) Directive. Read more. |
Croatia
Croatia | |||
Administrative and case law | Indirect tax | 06 November 2024 | Establishment of new company to maintain benefit of Value Added Tax (VAT) exemption scheme for small enterprises constitutes abusive practice. Read more. |
Cyprus
Cyprus | |||
Tax legislation approved and regulatory update | Indirect tax | 04 November 2024 | Zero Value Added Tax (VAT) rate on certain goods extended to December 31, 2025. Read more. |
Czech Republic
Czech Republic | |||
Proposed legislation | Income tax | 12 November 2024 | New Accounting Act expected to take effect in 2026. Read more. |
Denmark
Denmark | |||
Proposed legislation | Transfer pricing | 14 November 2024 | Proposed changes to tax law in legislative program. Read more. |
Estonia
| Estonia | |||
Proposed legislation | Income tax | 20 November 2024 | Proposed 2% corporate income tax rate for resident companies and permanent establishments. Read more. |
Proposed legislation | Various tax topics | 05 November 2024 | Proposed expansion of scope of security tax and increased Value Added Tax (VAT) rate, amendments to taxation of income earned through business accounts. Read more. |
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European Union
European Union | |||
Tax legislation approved and regulatory update | Tax Compliance | 25 November 2024 | European Commission accepts Greece's measures to bring its tonnage tax scheme in compliance with State aid rules. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 21 November 2024 | Legislation implementing global minimum tax effective January 1, 2025. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 19 November 2024 | Updated public country-by-country reporting forms published. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 12 November 2024 | Value Added Tax (VAT) guidance on new rules for small businesses. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 05 November 2024 | Member states agree on Value Added Tax (VAT) in the digital age package. Read more. |
Germany
Germany | |||
Tax legislation approved and regulatory update | Transfer pricing | 29 November 2024 | Changes to transfer pricing documentation requirements effective January 1, 2025. Read more. |
Tax legislation approved and regulatory update | Income tax | 26 November 2024 | Further update on tax policy consequences from end of governing coalition, other tax developments. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 25 November 2024 | New ZUGFeRD version 2.3.2, frequently asked questions for e-invoicing mandate. Read more. |
Proposed legislation | Tax compliance | 20 November 2024 | Draft law introduced to implement DAC8 regulations and amend common reporting standards. Read more. |
Tax legislation approved and regulatory update | Income tax | 11 November 2024 | Tax policy consequences from end of governing coalition. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 05 November 2024 | Relief for Value Added Tax (VAT) related obligations, other VAT developments. Read more. |
Tax legislation approved and regulatory update | Income tax | 01 November 2024 | Annual Tax Act 2024 would postpone new rules on withholding tax payment and reporting. Read more. |
Greece
Greece | |||
Proposed legislation | Income tax | 20 November 2024 | Ministry of Finance proposes various direct tax amendments. Read more. |
Hungary
Hungary | |||
Proposed legislation | Transfer pricing | 27 November 2024 | Draft declaration form for taxpayers subject to global minimum tax. Read more. |
Proposed legislation | Various tax topics | 22 November 2024 | Amended autumn tax package submitted to Parliament. Read more. |
Proposed legislation | Indirect tax | 15 November 2024 | Proposed extension of retail sales tax to online marketplaces. Read more. |
Proposed legislation | Transfer pricing | 07 November 2024 | Reporting obligation of taxpayers subject to global minimum tax. Read more. |
Ireland
Ireland | |||
Tax legislation approved and regulatory update | Tax compliance | 19 November 2024 | Updated FATCA and automatic exchange of information guidance. Read more. |
Italy
Italy | |||
Administrative and case law | Income tax | 20 November 2024 | Beneficial ownership of dividend income based on parent-subsidiary directive (Supreme Court decision). Read more. |
Tax legislation approved and regulatory update | Indirect tax | 12 November 2024 | New Value Added Tax (VAT) treatment for supply of staff. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 04 November 2024 | Guidance on substance based income exclusion provisions under Pillar Two rules. Read more. |
Kenya
Kenya | |||
Administrative and case law | Income tax | 06 November 2024 | Supreme Court holds Finance Act, 2023 constitutional, overturns Court of Appeal. Read more. |
Latvia
Latvia | |||
Tax legislation approved and regulatory update | Transfer pricing | 04 November 2024 | Updated list of low-tax or tax-free jurisdictions. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 01 November 2024 | Implementation of mandatory e-invoicing from January 1, 2026. Read more. |
Liechtenstein
Liechtenstein | |||
Tax legislation approved and regulatory update | Indirect tax | 27 November 2024 | Legislation includes Value Added Tax (VAT) amendments. Read more. |
Lithuania
Lithuania | |||
Proposed legislation | Transfer pricing | 19 November 2024 | Proposed tax changes concerning double taxation, DAC8, submission of tax information, and solidarity contribution. Read more. |
Luxembourg
Luxembourg | |||
Proposed legislation | BEPS Pillar 2 | 08 November 2024 | Revised draft law amending Pillar Two law. Read more. |
Moldova
Moldova | |||
Tax legislation approved and regulatory update | Income tax | 19 November 2024 | Residents of innovation technology parks cannot deduct donations. Read more. |
Montenegro
Montenegro | |||
Tax legislation approved and regulatory update | Transfer pricing | 12 November 2024 | Multilateral agreement on exchange of country-by-country reports. Read more. |
Netherlands
Netherlands | |||
Tax legislation approved and regulatory update | Tax compliance | 25 November 2024 | New framework for determining characterization for tax purposes of foreign legal forms. Read more. |
Tax legislation approved and regulatory update | Various tax topics | 18 November 2024 | Lower house passes 2025 Tax Plan with amendments. Read more. |
Tax legislation approved and regulatory update | Income tax | 08 November 2024 | Time to restructure to a "repurchase fund" extended for one year. Read more. |
Administrative and case law | Income tax | 08 November 2024 | Withholding tax on dividends received by United Kingdom company potentially impermissible under European Union law (CJEU judgment). Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 04 November 2024 | Letter submitted to Parliament on Pillar Two effect on Dutch tax incentives. Read more. |
Norway
Norway | |||
Tax legislation approved and regulatory update | Indirect tax | 05 November 2024 | Carbon border adjustment mechanism (CBAM) for imports from 2026. Read more. |
Proposed legislation | Transfer pricing | 04 November 2024 | Budget would introduce undertaxed profits rule from 2025. Read more. |
OECD
OECD | |||
Tax legislation approved and regulatory update | Tax compliance | 27 November 2024 | Global Forum releases 2024 automatic exchange of information peer review report. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 18 November 2024 | Mutual agreement procedure and advance pricing agreement statistics for 2023. Read more. |
Poland
Poland | |||
Tax legislation approved and regulatory update | Income tax | 26 November 2024 | General ruling on qualification for dividend withholding tax exemption. Read more. |
Proposed legislation | Various tax topics | 13 November 2024 | Final round of consultations on national e-invoicing system, other tax developments. Read more. |
Proposed legislation | BEPS Pillar 2 | 13 November 2024 | Legislation implementing Pillar Two global minimum tax rules passed by upper house of Parliament. Read more. |
Proposed legislation | Indirect tax | 12 November 2024 | Proposed legislation to enhance electromobility and reduce emissions. Read more. |
Administrative and case law | Indirect tax | 07 November 2024 | Optional cash method for small enterprises, postponement of mandatory e-invoicing system. Read more. |
Administrative and case law | Various tax topics | 07 November 2024 | Authority of head of tax office, English version of tax treaties controls, deduction for unduly paid Value Added Tax (VAT), taxation of employer-paid insurance premiums. Read more. |
Proposed legislation | BEPS Pillar 2 | 04 November 2024 | Proposed reforms to tax incentives system in light of Pillar Two. Read more. |
Portugal
Portugal | |||
Proposed legislation | BEPS Pillar 2 | 04 November 2024 | Bill implementing Pillar Two passed by Parliament. Read more. |
Slovakia
Slovakia | |||
Tax legislation approved and regulatory update | Various tax topics | 13 November 2024 | Tax collection and reporting guidelines in Financial Transactions Tax Act. Read more. |
Administrative and case law | Transfer pricing | 13 November 2024 | Transfer pricing for manufacturing companies (court decisions). Read more. |
Slovenia
Slovenia | |||
Proposed legislation | Income tax | 20 November 2024 | Proposed amendments to income tax law. Read more. |
South Africa
South Africa | |||
Proposed legislation | BEPS Pillar 2 | 20 November 2024 | Updated legislation implementing Pillar Two global minimum tax rules submitted to Parliament. Read more. |
Administrative and case law | Income tax | 12 November 2024 | Conduit principle does not apply when capital gains are realized by a trust. Read more. |
Proposed legislation | Various tax topics | 04 November 2024 | Proposal to apply official rate of interest rule to loans to trusts. Read more. |
Spain
Spain | |||
Tax legislation approved and regulatory update | Income tax | 08 November 2024 | Special tax regime of the Balearic Islands, relief for taxpayers affected by flooding. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 07 November 2024 | Guidance on required specifications for electronic invoicing systems. Read more. |
Sweden
Sweden | |||
Administrative and case law | Treaties | 25 November 2024 | Administrative courts have jurisdiction to review claims for corresponding adjustment under income tax treaty (Supreme Administrative Court decision). Read more. |
United Kingdom
United Kingdom | |||
Proposed legislation | BEPS Pillar 2 | 21 November 2024 | Amendments to Pillar Two rules in Finance Bill 2024-2025. Read more. |
Administrative and case law | Income tax | 19 November 2024 | Exit tax must conform with European Union freedom of establishment principle (Upper Tribunal decision). Read more. |
Proposed legislation | Tax compliance | 11 November 2024 | Outcomes of consultation on cryptoasset reporting framework and common reporting standards amendments. Read more. |
Administrative and case law | Various tax topics | 07 November 2024 | Unallowable purpose rule for loans, small and medium-sized enterprise research and development regime, stamp duty land tax payment and filing obligations. Read more. |
