Europe & African region International Tax Newsletter
Europe and Africa regions
January 2018
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 January and 31 January 2018.
| Albania | Belgium | Bulgaria | Croatia |
| Cyprus | Czech Republic | Denmark | European Union |
| Finland | France | Hungary | Italy |
| Kosovo | Macedonia | Malta | Netherlands |
| Poland | Romania | South Africa | Sweden |
| Turkey | United Kingdom |
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.
Albania
Tax legislation approved and regulatory update
Various tax areas - 1 January 2018
KPMG in Albania has prepared a summary of tax-related amendments in a number of laws which are effective as of 1 January 2018. Changes include, among other, tax incentives for companies in tourism and tax incentives for IT companies.
Belgium
Tax legislation approved and regulatory update
Corporate income tax - 1 January 2018
KPMG in Belgium has prepared a report on the impact of the recently enacted corporate tax reform on Belgian corporate income tax reform on deferred taxes.
Corporate income tax /Tax avoidance - 2019
KPMG in Belgium has prepared a report on the corporate tax reform measures effective beginning in 2019. These include provisions on tax consolidation and anti-tax avoidance measures.
Corporate income tax - 2020
KPMG in Belgium has prepared a report on the corporate tax reform measures effective beginning in 2020. These include: corporate tax rate reduction, R&D partial exemption from wage withholding tax, tax-free reserves and interest deduction limitation.
Bulgaria
Tax legislation approved and regulatory update
Excise tax - 1 January 2018
Changes to the excise tax rules in Bulgaria, published in the official gazette are effective 1 January 2018.
Croatia
Tax legislation approved and regulatory update
Corporate income tax / VAT - 1 January 2018
Tax law amendments in Croatia, effective beginning in 2018, include a decrease of the deductible interest rate on loans between related parties and a new VAT registration threshold.
Cyprus
Administrative and case law
Czech Republic
Administrative and case law
Permanent establishments - 17 January 2018
The Advocate General Campos of the Court of Justice of the European Union issued his opinion concerning the compatibility with EU law of the Danish rules on the deductibility of losses from foreign permanent establishments. The case is: Bevola and Jens W. Trock (C-446/03).
Denmark
Administrative and case law
Withholding tax - 20 December 2017
The Advocate General Mengozzi of the Court of Justice of the European Union published his opinion, concerning the compatibility with EU law of the Danish withholding tax on dividends distributed to non-resident investment funds. The case is: C-480/16, Fidelity Funds.
European Union
Proposed legislation
VAT - 18 January 2018
The European Commission proposed new rules to give EU Member States greater flexibility to set VAT rates and to create a better tax environment to help small and medium-sized enterprises flourish.
Administrative and case law
Various tax areas - January 2018
A summary of recent Court of Justice of the European Union (“CJEU”) judgments, infringement procedures and referrals to CJEU.
Other
Tax avoidance - 23 January 2018
The Economic and Financial Affairs Council of the EU agreed to remove eight countries from the EU blacklist of non-cooperative jurisdictions.
Finland
Proposed legislation
Anti-tax avoidance - 2019
The Finnish Ministry of Finance released a draft of a proposal for new interest deduction limitation rules based on the Anti-Tax Avoidance Directive. The proposed amendments would expand the scope of the current rules significantly, and if enacted, would be effective beginning in 2019.
France
Tax legislation approved and regulatory update
Corporate income tax / Transfer pricing / WHT - 1 January 2018
Two finance laws with tax provisions were enacted. Tax measures affecting companies include:
- the progressive reduction of corporate income tax rate
- reduction of the withholding taxes and levies on dividends and capital gains earned by foreign companies
- repeal of the 3 percent tax on dividend distributions
- modification of “Amendment Carrez”
- updates to the transfer pricing documentation
Administrative and case law
State aid - 16 January 2018
The General Court of the European Union issued a judgment upholding a decision of the European Commission for France to recover approximately EUR 1.37 billion from Électricité de France. The amount recovered represents “state aid” in the form of a waiver of the tax on the reclassification of rights in capital. The case is: EDF v. Commission, T-747/15.
Hungary
Administrative and case law
VAT - 1 July 2018
The Hungarian Ministry for National Economy on confirmed that “online invoicing”—a new tool to address potential tax issues including tax avoidance—will take effect and “go live” on 1 July 2018.
Italy
Tax legislation approved and regulatory update
Corporate income tax - 1 January 2018
KPMG in Italy has prepared a summary of the changes to the corporate income tax law introduced by the Budget Law 2018.
VAT - 1 January 2018
KPMG in Italy has prepared a summary of the VAT changes introduced by the Budget Law 2018.
VAT - 1 January 2018
The Budget Law 2018 introduced new rules applicable for pharmaceutical companies concerning VAT and the “payback” regime.
Kosovo
Tax legislation approved and regulatory update
Customs duties / Excise duties - 1 January 2018
Based on two decisions of the Government of Kosovo manufacturers registered in Kosovo who benefit from the VAT deferral scheme may also be exempt from the payment of customs and excise duties for certain imports made in the course of their business activity.
Macedonia
Tax legislation approved and regulatory update
Personal income tax - 1 January 2018
The Ministry of Finance adopted a rulebook regarding the method of calculation and payment of the income and personal income tax.
Malta
Tax legislation approved and regulatory update
Tax compliance - 1 January 2018
Effective January 2018, all Maltese express trusts, foundations, associations, and corporations have new obligations—identifying, recording, and reporting their beneficial owners to the Malta Financial Services Authority.
Netherlands
Administrative and case law
Salary taxes - 31 January 2018
The Amsterdam Court of Appeals, in a case concerning whether the allocation of bonus shares falls under the fixed exemption of the work-related costs rules, held that the allocation of bonus shares to a select group of employees was “unusual” and therefore not within the standard criterion under generally accepted standards for purposes of the work-related costs rules.
Poland
Administrative and case law
Tax incentives - 15 January 2018
The European Commission announced the opening of an investigation into a Polish tax incentive for shipyards. The incentive allows shipyards operating in Poland an option to pay a 1 percent flat-rate tax on sales from the building and conversion of ships, instead of paying the generally applicable corporate income tax rate of 19 percent or the applicable individual (income tax rate of 18 percent, 19 percent or 32 percent.
Romania
Tax legislation approved and regulatory update
Tax incentives - January 2018
An exemption from the tax on salary for the software development industry has been extended to include certain employees who are currently enrolled in an accredited university. The exemption from salary tax continues to apply to employees who have completed undergraduate studies.
South Africa
Tax legislation approved and regulatory update
Anti-tax avoidance - January 2018
Proposals to expand an anti-avoidance provision when low-interest or interest-free loans are involved have been amended.
Sweden
Tax legislation approved and regulatory update
Corporate income tax - 1 January 2018
The Swedish tax agency has published new deductible amounts for business or promotional gifts. The new deductible amounts apply from 1 January 2018.
Turkey
Tax legislation approved and regulatory update
Customs duties - 28 February 2018
The rules for certificates of origin for goods imported into Turkey from the European Union have been simplified, with measures that are effective 28 February 2018.
UK
Tax legislation approved and regulatory update
Corporate income tax / Tax compliance J- anuary 2018
HMRC have published an overview of groups’ compliance obligations under the new corporate interest restriction regime.
Proposed legislation
Various tax areas - January 2018
The Finance Bill 2018 has completed Committee Stage and will now proceed to Report Stage and Third Reading.
VAT January - 2018
HMRC have released for consultation the draft Making Tax Digital VAT Regulations, together with a draft notice and some examples which outline the extent of the required digital links for businesses that currently have different digital record keeping options.
Administrative and case law
Capital gains tax - January 2018
The Court of Appeal has allowed the taxpayer’s appeal against a decision of the Upper Tribunal in this case concerning qualifying corporate bonds.
Income tax - January 2018
The Upper Tribunal has held that loan notes received by employees were not restricted securities for the purposes of Part 7 Income Tax (Earnings and Pensions) Act. The case is: Cyclops Electronics Ltd v HMRC.
Permanent establishments - January 2018
The Upper Tribunal held that a company was entitled to claim income tax relief for its permanent establishment’s (“PE”) trading losses against its non-PE letting income.
Supplementary tax charge (oil and gas) - January 2018
The First-tier Tribunal ruled that a proposed profit apportionment was just and reasonable. The case is: Maersk Oil North Sea UK Ltd and Maersk Oil UK Ltd v HMRC.
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