International Tax Europe and Africa August 2019

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 2019

Ghana Luxembourg
Czech Republic Greece Nigeria Spain
EU Ireland Norway Switzerland
France Italy Poland United Kingdom
Germany Lithuania Serbia Zimbabwe

For a full summary of global tax developments, visit TaxNewsFlash- Global.

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“Snapshot” of tax reform in Switzerland

Tax reform in Switzerland aims to provide for an internationally accepted corporate tax regime that, in turn, will maintain the attractiveness of Switzerland as a business location. The tax reform measures have an effective date of 1 January 2020. Read more

International Tax Newsletter - Europe & African region


Tax legislation approved and regulatory update VAT
9 July 2019  

The tax authorities issued guidance with respect to the rules that apply for VAT purposes. The guidance includes examples intended to illustrate application of the VAT rules.

Czech Republic

Tax legislation approved and regulatory update  VAT August 2019

The tax authority in the Czech Republic issued guidance clarifying the application of VAT on various types of vouchers.

Proposed legislation Dispute resolution
August 2019

A bill on international cooperation in resolution of tax-related disputes in the EU has been submitted to the Chamber of Deputies.

European Union

Tax legislation approved and regulatory update MDR
August 2019

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

Administrative and case law Various tax areas August 2019

The EU Tax Centre prepared a summary of EU tax developments that can have both a domestic and a cross-border impact.


Proposed legislation  Tax compliance August 2019

The current French tax rules include several compliance obligations for online platforms, and there is a proposal to expand the tax-related reporting requirements for online platforms.


Tax legislation approved and regulatory update
Refund claims for dividends
31 December 2019

The German Ministry of Finance, in early August 2019, granted an extension of the deadline for investment funds to file a refund claim on behalf of tax-exempt investors with a German paying agent or sub-custodian.

Administrative and case law Contributions of business segments August 2019

The German Federal Tax Court, in a late 2018 decision, held that an application for retroactive consideration of a transfer (contribution) for tax purposes is not time-limited, but that such an application cannot be changed retroactively.


Proposed legislation
Budget statement
July 2019

The mid-year budget statement was presented to Parliament and includes provisions to:

  • repeal the luxury vehicle tax
  • increase the communication service tax
  • increase energy sector levies
  • provide tax incentives for certain companies



Tax legislation approved and regulatory update Special solidarity contribution
August 2019

A foreign tax credit may be available for Greece’s “special solidarity contributions” on foreign-sourced income under certain existing income tax treaties.


Tax legislation approved and regulatory update  Beneficial ownership / Tax compliance
July 2019 / 22 November 2019 

The central register of beneficial ownership, as provided for in the EU (Anti-Money Laundering Beneficial Ownership of Corporate Entities) Regulations 2019, is effective in Ireland as of late July 2019. The deadline to file information with the central register is 22 November 2019.

KPMG publications
Employee share incentive plans
August 2019

KPMG in Ireland has prepared a report that examines the tax benefits, together with the conditions and restrictions of the different types of employee share incentive plans.


Tax legislation approved and regulatory update
Tax compliance
July 2019 / 31 October 2019
The Italian tax authorities issued an implementing decree regarding the tax reporting requirements for remote (distance) sales. The first deadline under the new reporting requirements is 31 October 2019. Read more


Tax legislation approved and regulatory VAT    1 September 2019

Effective 1 September 2019, the list of goods subject to the VAT reverse-charge mechanism will be expanded.


Proposed legislation
ATAD 2   9 August 2019 

A bill to transpose the EU Anti-Tax Avoidance Directive 2 into Luxembourg domestic tax law was published by the Luxembourg Chamber of Deputies. The bill is now subject to the parliamentary process before being enacted.

Proposed legislation MDR
August 2019

Text of a bill to transpose an EU Directive on administrative cooperation in the field of taxation (DAC 6)—also known as the EU Directive implementing mandatory disclosure rules for intermediaries—has been provided by the Chamber of Deputies.


Tax legislation approved and regulatory update VAT / WHT    14 August 2019

The Federal Inland Revenue Service issued a notice concerning the withholding tax and VAT treatment of “compensation” made by companies to distributors, dealers, and agents.

Tax legislation approved and regulatory update Tax collection 19 August 2019

The Federal Inland Revenue Service (“FIRS”) issued a notice informing companies with bank accounts currently under a tax lien “freeze” of the need to regularize their tax status within 30 days. The FIRS stated that it will proceed to enforce payment of the company’s tax liabilities from the company directors, managers, secretaries, and other principal officers without further notice following expiration of the 30-day window.

Administrative and case law Drilling rigs and vessels August 2019

Courts in Nigeria issued judgments in cases concerning the taxation of drilling rigs and vessels used with respect to oil and gas production activities.


Proposed legislation  VAT / Online retailers and marketplaces
August 2019

A proposal to amend the Norwegian regulations relating to low-value shipments would include a new registration process. The aim is to simplify customs clearances of eligible shipments as well as to provide a simplified VAT system.


Tax legislation approved and regulatory update
Beneficial ownership
13 April 2020

Existing companies must report certain information to a central register about their ultimate beneficial owners by 13 April 2020.

Proposed legislation Cooperation between taxpayers and tax administration
July 2019

A draft law, concerns settlement of disputes regarding double taxation and with respect to advance pricing agreements and would introduce a new mechanism for cooperation between taxpayers and the national tax administration.


Tax legislation approved and regulatory update  Individual income tax / Share-based payments  August 2019

A “rulebook” concerns the exemption from individual (personal) income tax for share-based payments made by employers to employees.


Proposed legislation  VAT August 2019

Proposed changes to VAT law in Slovakia include the following measures:

  • quick fixes” as regard “call-off” stock simplification, chain transactions and intra-community supplies of goods
  • new rules concerning a VAT exemption for taxable supplies relating to the international trade in customs and special warehouses
  • extension of a requirement concerning adjustments to the input VAT deduction to purchases of services related to these goods. 



Treaties  Double tax treaty  27 November 2019

The U.S. Treasury Department announced that a Protocol to the income tax treaty between the United States and Spain will enter into force on 27 November 2019.


Tax legislation approved and regulatory update Tax reform
1 January 2020

Tax reform in Switzerland aims to provide for an internationally accepted corporate tax regime that, in turn, will maintain the attractiveness of Switzerland as a business location. The tax reform measures have an effective date of 1 January 2020.

Treaties Double tax treaty 17 July 2019

The U.S. Senate approved Protocols amending the existing income tax treaties with Switzerland, Luxembourg, and Japan.

United Kingdom

Tax legislation approved and regulatory update
Structures and buildings allowances
August 2019
MRC have recently published guidance on the newly introduced Structures and Buildings Allowances.Read more
Proposed legislation  MDR August 2019

HMRC have provided insight on how the UK’s implementation of the EU’s Mandatory Disclosure rules will look and operate in practice.

Administrative and case law
CFC / State aid
August 2019

The UK’s appeal against the European Commission claim that the UK Controlled Foreign Company regime constitutes EU State Aid has now been published in the Official Journal of the EU.

Administrative and case law Capital allowances August 2019

A recent First-tier Tribunal decision held that expenditure on caverns used for storing gas is not expenditure on plant for capital allowances purposes. The case is: The Cheshire Cavity Storage 1 Ltd and another v Revenue and Customs Commissioners.

Administrative and case law Entrepreneurs’ relief August 2019

The First-tier Tribunal concluded that an individual only needs to be a qualifying beneficiary at the time of the disposal of qualifying assets by a settlement for trustees to potentially qualify for Entrepreneurs’ Relief. The case is: The Quentin Skinner Settlements v The Commissioners of HMRC.

Administrative and case law Income tax August 2019

The Upper Tribunal has published its decision in Ingenious Games LLP, Inside Track Productions LLP and Ingenious Film Partners 2 LLP v HMRC, dismissing the taxpayer’s appeal.

Other OTS Annual Report August 2019

The Office of Tax Simplification (OTS) has released its Annual Report for 2018-19.


Tax legislation approved and regulatory update Taxation of e-commerce
August 2019

The Finance Act No. 1 of 2019 introduced measures providing for the taxation of non-resident e-commerce platforms and satellite broadcasting service providers.

Proposed legislation Various tax areas August 2019

The Minister of Finance and Economic Development presented the 2019 mid-term fiscal policy review statement. Measures include:

  • proposed repeal of measures, to allow foreign investors to own more than 51% of businesses in the diamond and platinum sectors
  • revised tax thresholds and rates for the “Pay As You Earn” (PAYE) regime
  • established rate of capital gains tax on immovable property acquired before 22 February 2019 at 5% of the gross selling price or assessed value. 


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