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International Tax Newsletter - Europe & African region

Europe & African region

International Tax Newsletter

International Tax Europe and Africa January 2020

This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Europe and Africa Regions 1 January 2020 and 31 January 2020.

Africa EU Netherlands UK
Algeria France Nigeria  
Austria Ireland Senegal  
Belgium Italy South Africa  
Croatia Lithuania Sweden  
Czech Republic Mauritius Switzerland  


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

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

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International Tax Newsletter - Europe & African region

Africa / Europe

  Tax area concerned Relevant date Description of measures and publication link
Africa  / Europe  
KPMG Publications  2019 Global Withholding Taxes  January 2020 

This guide presents tables that summarize the taxation of income and gains from listed securities in 115 markets around the world as of December 31, 2019.

Algeria


Tax area concerned Relevant date Description of measures and publication link
Algeria   
Proposed legislation  Finance Law January 2020

KPMG in Algeria prepared a summary of tax-related provisions in the Finance Law 2020.

Austria

Tax area concerned Relevant date Description of measures and publication link
Austria     
Proposed legislation  Various tax areas   January 2020 

The new government published its plans for governing. Among the tax changes that could be proposed are the following

- A reduction of the rate of corporate income tax from 25% to 21%

- A taxpayer right to request a tax audit.

Belgium

Tax area concerned Relevant date Description of measures and publication link
Belgium    
Tax legislation approved and regulatory update  Earnings stripping rules 27 December 2019

A Royal Decree implements the “earnings stripping rules”—that is, the rules that limit certain interest deductions pursuant to legislation enacted in late 2017. The Royal Decree clarifies certain aspects of the earnings stripping rules, but some issues remain unresolved.

Proposed legislation  Financial sector  2020 

Taxpayers in the financial services sector may anticipate that the year 2020 will bring various tax changes in legislation, administrative practice, and case law.

Croatia


Tax area concerned Relevant date Description of measures and publication link
Croatia   
Tax legislation approved and regulatory update Corporate income tax  1 January 2020

Tax amendments effective 1 January 2020 concern corporate profit (income) tax, individual (personal) income tax, and the value added tax (VAT) regimes.

Czech Republic

Tax area concerned Relevant date Description of measures and publication link
Czech Republic
Tax legislation approved and regulatory update Insurance tax  1 January 2020

Changes to the taxation of insurance companies are among the tax legislative items that were effective beginning January 2020.

Treaties  Double tax treaties  1 January 2020 

A new income tax treaty between the Czech Republic and South Korea entered into force at the end of 2019.

EU

Tax area concerned Relevant date Description of measures and publication link
EU 
Tax legislation approved and regulatory update Various tax areas January 2020 

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

Tax legislation approved and regulatory update MDR 8 January 202

This seventh Special Edition Euro Tax Flash summarizes the most recent status of the implementation of the new rules into Member States’ domestic legislation.

Proposed legislation  Beneficial owners January 2020

EU Member States must make the registers of beneficial owners of companies publicly accessible following implementation of the fifth EU Anti-Money Laundering Directive.

France

Tax area concerned Relevant date Description of measures and publication link
France 
Tax legislation approved and regulatory update Corporate income tax  January 2020

KPMG Avocats prepared an overview of certain corporate tax provisions included in the Finance Law for 2020—in particular, measures that may affect foreign taxpayers and their business operations in France.

Other  Digital services tax January 2020

There are reports indicating that France will delay collection of the digital services tax payments due in April and October 2020.

Ireland


Tax area concerned Relevant date Description of measures and publication link
Ireland  
Tax legislation approved and regulatory update  Employee share participation schemes 31 March 2020

Returns of information for employee share participation schemes with respect to 2019 must be filed by 31 March 2020.

Italy

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

The Budget Law for 2020, enacted in late December 2019, introduces a digital services tax. The rate of the digital services tax is 3%.

Tax legislation approved and regulatory update Budget Law  January 2020

KPMG in Italy prepared a summary of the tax measures included in the Budget Law for 2020.

Lithuania


Tax area concerned Relevant date Description of measures and publication link
Lithuania
Tax legislation approved and regulatory update  Corporate income tax / Credit institutions  1 January 2020

Amendments to the corporate income tax concern the increased taxation of credit institutions’ profits earned during the tax periods 2020-2022 in Lithuania.

Mauritius

Tax area concerned Relevant date Description of measures and publication link
Mauritius
Treaties  Double tax treaties  January 2020 

Representatives of the governments of Mauritius and Kenya in April 2019 signed an income tax treaty and a protocol for the avoidance of double taxation. The treaty agreements were ratified by Mauritius in late 2019.

Netherlands

Tax area concerned Relevant date Description of measures and publication link
Netherlands  
Tax legislation approved and regulatory update Tax compliance  January 2020 

A bill referred to as the Digital Government Act  sets out foundations for further digitization, including regulation of digital government and, more specifically, facilities within the governmental “generic digital infrastructure”.

Administrative and case-law WHT  30 January 

The Court of Justice of the European Union rendered its opinion concerning the compatibility with EU law of the Dutch withholding tax on dividends distributed to non-resident investment funds. The case is: Köln-Aktienfonds Deka case (C-156/17).  

Nigeria

Tax area concerned Relevant date Description of measures and publication link
Nigeria
Tax legislation approved and regulatory update VAT  1 February 2020 

The Minister of Finance announced that implementation of the VAT rate of 7.5% will be effective beginning 1 February 2020.

KPMG publications  Nigeria's Tax and Regulatory Landscape January 2020

KPMG in Nigeria has produced a report providing a summary of developments concerning tax and regulations in Nigeria in 2019 and expectations for 2020.

Senegal


Tax area concerned Relevant date Description of measures and publication link
Senegal  
Tax legislation approved and regulatory update Tax incentives  January 2020

Amendments to tax provisions in the Finance Bill for 2019 mostly concern the hydrocarbon sector. The Finance Bill for 2020 introduced tax incentives for small and medium-sized enterprises in the digital sector.

South Africa


Tax area concerned Relevant date Description of measures and publication link
South Africa  
Tax legislation approved and regulatory update Carbon tax  July 2020

The first carbon tax payment will be due by the end of July 2020.

Oher  R&D  January 2020

KPMG in South Africa has prepared a video discussion of the research and development tax incentive in South Africa.

Sweden


Tax area concerned Relevant date Description of measures and publication link
Sweden
Proposed legislation  R&D  January 2020   

The Swedish government has proposed legislation relating to research and development and specifically to provide enhanced relief relating to social security contributions for salary and wages paid to eligible employees involved in R&D projects.

Switzerland

Tax area concerned Relevant date Description of measures and publication link
Switzerland
Tax legislation approved and regulatory update Corporate income tax  1 January 2020

The deadline for the referendum against the new Ticino tax law expired on 7 January 2020; thus, the corporate tax law adjustments are effective retroactively to 1 January 2020.

Tax legislation approved and regulatory update Individual taxation  January 2020

The Swiss federal law on tax reform and AHV financing —while mainly focusing on corporate taxation—has implications for certain individual taxpayers.

Administrative and case-law Dividend stripping / WHT  December 2019

The Swiss federal high court issued a decision in a case concerning what is referred to as a “perceived dividend stripping transaction.”.

Other  MLI / Holding structures  December 2019

New anti-abuse rules question the legitimacy of considering tax issues when deciding where to establish a holding company and put such structures at risk.

United Kingdom

  Tax area concerned elevant date Description of measures and publication link
United Kingdom
Tax legislation approved and regulatory update DAC 6 January 2020

The final UK regulations to implement the EU Directive on administrative cooperation in the field of taxation (DAC 6) were issued in January 2020.

Tax legislation approved and regulatory update Stamp duty  January 2020

HM Revenue & Customs updated guidance under the section 75A anti-avoidance legislation.

Proposed legislation  Budget 2020   11 March 2020

It has been announced that the 2020 budget is scheduled to be presented on 11 March 2020.  

Administrative and case-law Late-payment interest  January 2020

HM Revenue & Customs confirmed that it will no longer seek to raise charges for late-payment interest on unpaid withholding tax on intra-EU transactions.

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