International Tax Europe and Africa April 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 April and 30 April 2024.

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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Austria


Tax area concerned

Relevant date

Description of measures and publication link

Austria

Proposed legislation

Transfer pricing

22 April 2024

Draft law implementing public country-by-country (CbC) reporting. Read more.

Tax legislation approved and regulatory update

Various tax topics

22 April 2024

Guidance on Value added tax exemption for board renumeration, other recent direct and indirect tax developments. Read more.

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Belgium


Tax area concerned

Relevant date

Description of measures and publication link

Belgium

Proposed legislation

BEPS Pillar 2

08 April 2024

Draft amendments to minimum taxation rules (under Pillar Two). Read more.

Proposed legislation

Income tax

03 April 2024

Proposed reform of investment deduction regime. Read more.

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Cyprus


Tax area concerned

Relevant date

Description of measures and publication link

Cyprus

Tax legislation approved and regulatory update

Indirect tax

26 April 2024

Temporary zero value added tax (VAT) on specific goods extended to 30 June 2024. Read more.

Tax legislation approved and regulatory update

Tax compliance

22 April 2024

Increased capital allowances for “green” investments. Read more.

Tax legislation approved and regulatory update

Indirect tax

19 April 2024

Reduced 5% value added tax (VAT) for purchase or construction of residence. Read more.

Tax legislation approved and regulatory update

Transfer pricing

10 April 2024

Frequently asked questions on adoption of new transfer pricing legislation. Read more.

Tax legislation approved and regulatory update

Income tax

05 April 2024

Legislation providing tax benefits for companies implementing energy upgrades passes Parliament. Read more.

Tax legislation approved and regulatory update

Tax compliance

05 April 2024

Extension of deadline for submission of data to register of beneficial owners for certain “refugee” companies. Read more.

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Czech Republic


Tax area concerned

Relevant date

Description of measures and publication link

Czech Republic

Tax legislation approved and regulatory update

Income tax

29 April 2024

Amendments to income tax provisions in consolidation package approved by lower house of Parliament. Read more.

Proposed legislation

Indirect tax

26 April 2024

Draft bill to transpose DAC8 into national law. Read more.

Administrative and case law

Income tax

19 April 2024

Taking into account estimated payables for income tax purposes (Supreme Administrative Court decisions). Read more.

Administrative and case law

Income tax

11 April 2024

Deductibility of increased interest, uncollectible debt. Read more.

Proposed legislation

Indirect tax

11 April 2024

Draft amendment to value added tax (VAT) law includes changes to treatment of construction sector. Read more.

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Estonia

 

Tax area concerned

Relevant date

Description of measures and publication link

Estonia

Tax legislation approved and regulatory update

BEPS Pillar 2

26 April 2024

Legislation approved to implement minimum taxation under Pillar Two. Read more.

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European Union


Tax area concerned

Relevant date

Description of measures and publication link

European Union

Tax legislation approved and regulatory update

Indirect tax

29 April 2024

Working paper on value added tax (VAT) treatment of “crypto art”. Read more.

Tax legislation approved and regulatory update

Transfer pricing

26 April 2024

Resolution on Transfer Pricing Directive adopted. Read more.

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France


Tax area concerned

Relevant date

Description of measures and publication link

France

Tax legislation approved and regulatory update

Income tax

26 April 2024

New rules to avoid double-taxation arising from the sale of a Controlled Foreign Corporation. Read more.

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Germany


Tax area concerned

Relevant date

Description of measures and publication link

Germany

Proposed legislation

Indirect tax

30 April 2024

Draft bill for Annual Tax Act 2024 includes value added tax (VAT)-related measures, other VAT developments. Read more.

Proposed legislation

Various tax topics

25 April 2024

Draft bill for Annual Tax Act 2024 includes Pillar Two changes, other tax developments. Read more.

Administrative and case law

Indirect tax

23 April 2024

Value added tax treatment of vouchers (CJEU judgment). Read more.

Tax legislation approved and regulatory update

Transfer pricing

19 April 2024

New transfer pricing regulations for intra-group financial transactions. Read more.

Administrative and case law

Income tax

18 April 2024

“Planned cooperation” between charitable corporations (fiscal court decision). Read more.

Tax legislation approved and regulatory update

Tax compliance

09 April 2024

FATCA reporting deadline is 31 July 2024. Read more.

Proposed legislation

Indirect tax

08 April 2024

Proposed legislation includes value added tax (VAT)-related measures, other VAT developments. Read more.

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Global


Tax area concerned

Relevant date

Description of measures and publication link

Global

KPMG publication

Indirect tax

08 April 2024

KPMG report: Global e-invoicing and digital reporting mandates. Read more.

KPMG publication

Transfer pricing

08 April 2024

KPMG report: Transfer pricing and ESG—improving governance by operationalizing transfer pricing. Read more.

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Greece


Tax area concerned

Relevant date

Description of measures and publication link

Greece

Tax legislation approved and regulatory update

BEPS Pillar 2

26 April 2024

Legislation enacted to implement minimum taxation under Pillar Two. Read more.

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Guernsey


Tax area concerned

Relevant date

Description of measures and publication link

Guernsey

Tax legislation approved and regulatory update

Tax compliance

25 April 2024

Deadline for submitting FATCA and common reporting standard (CRS) reports is 1 July 2024 (Guernsey). Read more.

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Hungary


Tax area concerned

Relevant date

Description of measures and publication link

Hungary

Tax legislation approved and regulatory update

Transfer pricing

05 April 2024

Audit plan for 2024 focuses on transfer pricing. Read more.

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Iceland


Tax area concerned

Relevant date

Description of measures and publication link

Iceland

Tax legislation approved and regulatory update

BEPS Pillar 2

26 April 2024

Fiscal Strategy Plan for 2025-2029 confirms intention to implement Pillar Two. Read more.

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Ireland


Tax area concerned

Relevant date

Description of measures and publication link

Ireland

Tax legislation approved and regulatory update

Tax compliance

19 April 2024

Updated common reporting standards (CRS) guidance. Read more.

Proposed legislation

Income tax

05 April 2024

Proposed research and development tax credit rate and refund increases. Read more.

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Italy


Tax area concerned

Relevant date

Description of measures and publication link

Italy

Tax legislation approved and regulatory update

Indirect tax

16 April 2024

Agreement with United Kingdom on value added tax (VAT) refunds. Read more.

Tax legislation approved and regulatory update

Indirect tax

11 April 2024

Scope of self-disclosure regime extended to certain value added tax (VAT)-registered companies and deadline extended to 31 May 2024. Read more.

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Liechtenstein


Tax area concerned

Relevant date

Description of measures and publication link

Liechtenstein

Tax legislation approved and regulatory update

BEPS Pillar 2

08 April 2024

Ordinance on the application of the minimum taxation rules (under Pillar Two) published. Read more.

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Luxembourg


Tax area concerned

Relevant date

Description of measures and publication link

Luxembourg

Administrative and case law

Transfer pricing

08 April 2024

Luxembourg referred to CJEU for failing to correctly transpose the interest limitation rules under Anti-Tax Avoidance Directive. Read more.

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Netherlands


Tax area concerned

Relevant date

Description of measures and publication link

Netherlands

Proposed legislation

Various tax topics

19 April 2024

Insights into upcoming 2025 Tax Plan package. Read more.

Proposed legislation

Income tax

12 April 2024

Proposed legislation to tax “carried interests” as ordinary income. Read more.

Proposed legislation

Indirect tax

11 April 2024

Consultation on proposed division exemption in real estate transfer tax. Read more.

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OECD


Tax area concerned

Relevant date

Description of measures and publication link

OECD

Tax legislation approved and regulatory update

BEPS Pillar 2

30 April 2024

Consolidated commentary on Pillar Two rules, updated Pillar Two examples. Read more.

Tax legislation approved and regulatory update

Various tax topics

29 April 2024

Tax inspectors without borders 2024 annual report, new focus on country-by-country (CbC) data and digital economy. Read more.

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Poland


Tax area concerned

Relevant date

Description of measures and publication link

Poland

Proposed legislation

BEPS Pillar 2

29 April 2024

Draft bill implementing Pillar Two global minimum tax published. Read more.

Tax legislation approved and regulatory update

Indirect tax

26 April 2024

New deadlines for e-invoicing mandate announced. Read more.

Administrative and case law

Income tax

23 April 2024

Timing of tax exemption, inheritance and donation tax exemption, insurance proceeds not exempt income. Read more.

Tax legislation approved and regulatory update

Transfer pricing

23 April 2024

Public country-by-country (CbC) reporting implemented. Read more.

Tax legislation approved and regulatory update

Indirect tax

16 April 2024

Reporting obligations for digital platform operators (DAC7) enacted, other tax-related legislative developments. Read more.

Administrative and case law

Indirect tax

16 April 2024

Value added tax (VAT) account not accessible asset in bankruptcy proceedings (CJEU Advocate General opinion). Read more.

Administrative and case law

Various tax topics

16 April 2024

Excise tax warehouse as place of import, charitable spending requirement, transfer of real estate title as security. Read more.

Administrative and case law

Various tax topics

08 April 2024

No taxable income upon lapse of statute of limitations, treatment of Norwegian value added tax (VAT), individual tax form. Read more.

Proposed legislation

Indirect tax

08 April 2024

Consultations on mandatory use of National e-Invoicing System (KSeF) and changes to issuer’s and remitter’s statement templates. Read more.

Proposed legislation

Transfer pricing

08 April 2024

Draft public Country-by-Country (CbC) reporting bill approved by lower chamber of the Parliament. Read more.

Administrative and case law

Various tax topics

03 April 2024

Employee compensation under settlement, cashless payments, value added tax (VAT) on payment for transmission easement. Read more.

Tax legislation approved and regulatory update

Indirect tax

03 April 2024

New bill implementing reporting obligations for digital platform operators (DAC7). Read more.

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Portugal


Tax area concerned

Relevant date

Description of measures and publication link

Portugal

Proposed legislation

Income tax

26 April 2024

Program of new government proposes reduction of the corporate income tax rate to 15 percent. Read more.

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Serbia


Tax area concerned

Relevant date

Description of measures and publication link

Serbia

Tax legislation approved and regulatory update

Treaties

19 April 2024

Protocol to Switzerland income tax treaty adopted by Parliament. Read more.

Tax legislation approved and regulatory update

Indirect tax

18 April 2024

Amendments to value added (VAT) rulebook. Read more.

Tax legislation approved and regulatory update

Indirect tax

10 April 2024

Amended guidance relating to “Eco Tax”. Read more.

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Slovakia


Tax area concerned

Relevant date

Description of measures and publication link

Slovakia

Tax legislation approved and regulatory update

Indirect tax

30 April 2024

Amendments to value added tax (VAT) Act approved by Parliament. Read more.

Tax legislation approved and regulatory update

Transfer pricing

30 April 2024

Guidelines on transfer pricing documentation for 2023. Read more.

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Spain


Tax area concerned

Relevant date

Description of measures and publication link

Spain

Tax legislation approved and regulatory update

Treaties

04 April 2024

Most favoured nation clause under income tax treaty activated by India. Read more.

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Sweden


Tax area concerned

Relevant date

Description of measures and publication link

Sweden

Administrative and case law

Income tax

08 April 2024

AG Collins opinion on Swedish withholding tax treatment of foreign public sector pension institutions. Read more.

Proposed legislation

BEPS Pillar 2

08 April 2024

Draft amendments to minimum taxation rules (under Pillar Two). Read more.

Tax legislation approved and regulatory update

Indirect tax

02 April 2024

Value added tax (VAT) treatment of non-fungible tokens associated with a digital work. Read more.

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United Kingdom


Tax area concerned

Relevant date

Description of measures and publication link

United Kingdom

Tax legislation approved and regulatory update

Tax compliance

30 April 2024

Amendment to common reporting standards (CRS) regulations. Read more.

Administrative and case law

Transfer pricing

24 April 2024

BlackRock: Transfer pricing and unallowable purpose - Court of Appeal. Read more.

Tax legislation approved and regulatory update

Various tax topics

24 April 2024

Tax Administration and Maintenance Day 2024. Read more.

Administrative and case law

Tax compliance

24 April 2024

Court of Appeal finds for His Majesty's Revenue & Customs in Hargreaves Property withholding tax case. Read more.

Tax legislation approved and regulatory update

Tax compliance

23 April 2024

6 July Employee Share Plan Reporting Deadline, Registering Trusts. Read more.

Administrative and case law

State aid

11 April 2024

European Commission erred in finding illegal State aid based on controlled foreign company rules in isolation. Read more.

Proposed legislation

Income tax

10 April 2024

Updated draft guidance on contracted out and overseas research and development published. Read more.

Proposed legislation

Tax compliance

10 April 2024

Labour announces plans to close the tax gap. Read more.

Tax legislation approved and regulatory update

Income tax

10 April 2024

Partnership tax salaried member rules – a shift in HM Revenue & Customs approach? Read more.

Proposed legislation

Income tax

10 April 2024

Reserved Investor Fund – release of draft legislation. Read more.

Proposed legislation

Indirect tax

10 April 2024

United Kingdom carbon border adjustment mechanism consultation published. Read more.

Proposed legislation

Income tax

10 April 2024

Consultation on additional tax relief for visual effects expenditure. Read more.

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