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International Tax Newsletter - Europe & African region

Europe & African region

International Tax Newsletter

International Tax Europe and Africa October 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 October and 30 October 2019.

Austria France Kenya Poland United Kingdom
Belgium Germany Luxemburg Portugal Zambia
Channel Islands Gibraltar Mauritius Slovakia  
Croatia Greece Netherlands South Africa  
Denmark Ireland Nigeria Sweden  
European Union Italy Norway Switzerland  

 

For a full summary of global tax developments, visit home.kpmg/TaxNewsFlash.

To contact the International Tax Team email internationaltax@kpmg.com.

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International Tax Newsletter - Europe & African region

Austria

  Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update Digital services tax 1 January 2020

The Austrian parliament passed legislation that introduces a tax on digital services. Under this new law, a tax on digital advertising will be imposed effective 1 January 2020.

Tax legislation approved and regulatory update Various tax area
October 2019

KPMG in Austria has prepared a report providing brief summaries of tax developments for August and September 2019.

Belgium


Tax area concerned Relevant date Description of measures and publication link
Administrative and case law Annual tax on securities accounts 1 October 2019

The Belgian Constitutional Court issued a decision annulling the annual tax on securities accounts, with effect as of 1 October 2019.

Channel Islands

Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update Economic substance October 2019

Guidance from the tax authority reflects that economic substance questions are to be included in future corporate tax returns.

Croatia

Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update Beneficial Ownership / Tax compliance 31 December 2019

The deadline for organizations to submit information on their ultimate beneficial owners in a new “Register of Ultimate Beneficial Ownership” to be maintained by the Croatian financial authority is 31 December 2019. Failure to comply could result in penalties.

Denmark


Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update Various tax areas October 2019

KPMG in Denmark prepared a summary of recent tax developments.

European Union

Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update MDR 11 September 2019

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

Administrative and case-law EU blacklist October 2019

The Council adopted a revised EU blacklist of non-cooperative jurisdictions for tax purposes. The EU Finance Ministers agreed to remove the United Arab Emirates and the Marshall Islands from the list.

France

Tax area concerned Relevant date Description of measures and publication link
Proposed legislation Finance bill 2020 27 September 2019

The French government released the finance bill for 2020. The bill includes measures that may affect corporations such as a delay of the scheduled reduction of the corporate income tax “standard” rate for 2020 and 2021 for large companies; a new set of rules to address the use of hybrid instruments and entities in a cross-border context.

Germany

Tax area concerned Relevant date Description of measures and publication link
Administrative and case law VAT 10 October 2019

The European Commission announced that it had decided to send a formal notice to Germany in relation to German legislation with regard to the taxation of distance sales of goods sold through digital marketplaces.

Gibraltar


Tax area concerned Relevant date Description of measures and publication link
Treaties Double tax treaties  October 2019

Representatives of the governments of Gibraltar and the United Kingdom signed a new income tax treaty.

Greece

Tax area concerned Relevant date Description of measures and publication link
Proposed legislation Budget October 2019

A budget for 2020 was submitted to the Greek Parliament in early October 2019.

Ireland


Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update Finance bill 17 October 2019

Ireland's Finance bill 2019 was published.

Italy

Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update Digital services tax October 2019

A digital services tax was proposed in a draft law decree earlier in October 2019. However, the final version of the law decree (no. 124 of 26 October 2019) does not include the digital services tax provisions.

Proposed legislation Budget 8 October 2019

The president today presented the federal government budget proposals for 2020.

Administrative and case-law WHT October 2019

A provincial tax court concluded that Italian withholding tax imposed on dividends paid to foreign foundations is discriminatory because Italian foundations benefit from lower taxation on the same dividends.

Kenia

Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update VAT October 2019 The VAT law has been amended to allow offsetting withholding VAT credits against other tax obligations or refunds of the credits when set-offs are not possible. Read more

Luxembourg

Tax area concerned Relevant date Description of measures and publication link
Proposed legislation Budget 2020 14 October 2019

The Luxembourg government presented the 2020 draft budget law. The bill’s main tax measure relates to advance tax agreements issued before 1 January 2015.

Treaties Double tax treaties 10 October 2019

A new Protocol to amend the method of avoiding double taxation between France and Luxembourg appears to apply the tax credit method to avoid double taxation. According to the text of the new Protocol, the method used to prevent double taxation of French tax residents working in Luxembourg is a “tax credit equal to French tax.”

Other Brexit October 2019

The KPMG member firm in Luxembourg has prepared three reports that consider the possible implications of Brexit on direct tax, on VAT, and on the taxation of global employees.

Mauritius


Tax area concerned Relevant date Description of measures and publication link
Treaties MLI 1 February 2020

The multilateral instrument (MLI) negotiated under Action 15 of the OECD/G20 base erosion and profit shifting project and signed by Mauritius will enter into force 1 February 2020.

Netherlands


Tax area concerned Relevant date Description of measures and publication link
Proposed legislation Corporate income tax October 2019

The Dutch government intends to amend the liquidation and cessation loss rules for corporate income tax purposes as of 2021, in order to prevent improper use and to broaden the tax base.

Nigeria


Tax area concerned Relevant date Description of measures and publication link
Proposed legislation Budget 2020 8 October 2019

The president presented the federal government budget proposals for 2020.

Norway

Tax area concerned Relevant date Description of measures and publication link
Proposed legislation Budget 2020 7 October 2019

The Norwegian government presented 2020 budget proposals to the Norwegian Parliament, including measures that would change the Norwegian interest limitation rules.

Proposed legislation Taxation of hydropower producers 30 September 2019

An appointed expert committee in a report presented 30 September 2019 proposed changes to the current scheme for taxation of hydropower producers in Norway.

Poland

Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update VAT October 2019

Taxpayers purchasing goods—including electronics, fuels, steel, recyclable materials, car parts, or construction services—need to be aware of a requirement to settle their payments using the split-payment mechanism for VAT purposes.

Portugal


Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update Stamp duty October 2019

Guidance published in the official gazette provides rules with regard to monthly reporting and remittances of stamp tax (duty).

Administrative and case law VAT October 2019

The Court of Justice of the European Union issued a judgment in a case concerning the value added tax treatment of the assignment of a debt that had been recognized in enforcement proceedings.

Slovakia


Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update ATAD 2 September 2019

Amendments to the income tax law, approved by Parliament, aim to support small and medium-sized enterprises and the automotive industry; simplify tax calculations; reduce administrative burden; and implement the EU directive for the prevention of tax avoidance with regard to hybrid mismatches.

South Africa


Tax area concerned Relevant date Description of measures and publication link
Proposed legislation Dividend stripping October 2019

A bill would extend “dividend stripping” provisions to situations when extraordinary dividends are declared on or after 20 February 2019 and are followed by a dilution of a corporate shareholding.

Proposed legislation Tax-neutral transfers October 2019

A bill would no longer allow tax-neutral transfers of interest-bearing instruments and exchange items between group companies.

Proposed legislation WHT October 2019

A proposal would require taxpayers to pay more withholding tax if they fail to renew their declarations and undertakings every five years.

Sweden


Tax area concerned Relevant date Description of measures and publication link
Administrative and case law VAT 30 October 2019

The Swedish supreme administrative court announced it is requesting a preliminary ruling from the Court of Justice of the European Union (CJEU) regarding the value added tax (VAT) treatment of supplies from an overseas head office to its branch in Sweden, in a situation when the overseas head office is a member of a VAT group but the Swedish branch is not a member of the VAT group.

Other Brexit October 2019

Companies need to consider what would be certain implications if there is a ”no deal” Brexit—including country-specific information about Sweden.

Switzerland


Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update WHT / Stamp tax  27 September 2019

The Swiss Federal Council issued additional guidelines on a proposed reform of the Swiss withholding tax and Swiss stamp tax regimes.

United Kingdom

Tax area concerned Relevant date Description of measures and publication link
Tax legislation approved and regulatory update Hybrid mismatch rules 15 October 2019

The exclusion from the hybrid mismatch rules for regulatory capital instruments has been amended to comply with ATAD.

Administrative and case law Making Tax Digital October 2019

Notice 700/22 includes details of how to request an extension to the MTD digital links soft landing period beyond the current 12 months.

Administrative and case law WHT October 2019

The UK Court of Appeal in October 2019 issued its decision in a case concerning a claim for withholding tax on manufactured overseas dividends.

Zambia


Tax area concerned Relevant date Description of measures and publication link
Proposed legislation Budget 2020 September 2019

The Minister of Finance presented the 2020 budget. There are no changes proposed to the corporate income tax rates, to the rules for tax loss carryforwards, or to the deductions for capital allowances.

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