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International Tax Newsletter - Europe & African region

Europe & African region

International Tax Newsletter

International Tax Europe and Africa February 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 February 2019 and 28 February 2019.

Belgium France Luxemburg South Africa
Botswana Germany Malta Spain
Czech Republic Hungary Netherlands Sweden
Denmark Ireland Nigeria Switzerland
European Union Italy San Marino United Kingdom

 

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

Belgium

Administrative and case law Corporate income tax  14 February 2019   The General Court of the CJEU rendered judgment on the Belgian excess profit system. The case is: T-131/16. Read more

Botswana

Tax legislation approved and regulatory update Anti-avoidance / Transfer pricing   29 December 2018

An amendment to Botswana’s income tax law was promulgated. The new law includes measures that:

  • introduce transfer pricing rules
  • revise the general anti-avoidance provisions to exclude any reference to related-party transactions, that are now specifically addressed under the transfer pricing provisions
  • introduce legislation to counter “earnings stripping” by companies. 

Read more

Tax legislation approved and regulatory update Various tax areas 4 February 2019 The 2019/2020 budget proposals were presented to the National Assembly. There were no changes to the tax laws proposed in the budget speech. Read more

Czech Republic

Proposed legislation Tax reform  January 2019 The 2019 tax package is currently involved in the legislative process, with the Senate in late January 2019 returning the bill to the Chamber of Deputies with amending proposals. Read more
Administrative and case law VAT January 2019 The Supreme Administrative Court concluded that a customer’s liability VAT that was not paid by the supplier does not always take precedence over denying the customer’s entitlement to VAT deduction. Read more

Denmark

Denmark  Beneficial owner 26 February 2019 The CJEU rendered two landmark decisions on the interpretation of the beneficial owner concept under the Interest and Royalties Directive and the Parent-Subsidiary Directive. Read more

European Union

Tax legislation approved and regulatory update  Mandatory disclosure requirements February 2019 The EU Tax Centre summarizes the implementation of the new mandatory disclosure requirements into Member States’ domestic legislation to date and the state of play at the level of the EU institutions. Read more
Tax legislation approved and regulatory update VAT  1 January 2020 The European Council formally approved proposals for four “quick fixes” concerning VAT to simplify international trade. Read more
Administrative and case law Various tax areas February 2019 The EU Tax Centre prepared a summary of EU tax developments that can have both a domestic and a cross-border impact. Read more

France

Tax legislation approved and regulatory update Corporate income tax  1 January 2019

KPMG in France prepared a summary of the corporate tax measures recently enacted and effective starting January 2019, including changes to:

  •  tax consolidation regime
  • dividend distributions
  • limitations of interest deductibility
  • patent box regime. 

Read more  

Tax legislation approved and regulatory update Individual taxation  1 January 2019 KPMG in France prepared a summary of the corporate tax measures recently enacted and effective starting January 2019. Read more

Germany

Administrative and case law CFC 26 February 2019 The CJEU rendered its decision on a case concerning the derogation from the prohibition on restrictions to the free movement of capital with non-EU countries and its application to the German controlled foreign company rules. The case is: X-GmbH (C-135/17). Read more
Administrative and case law VAT 26 February 2019 The German Federal Tax Court concluded that for purposes of VAT, a “co-ownership by defined shares” is not a “VAT trader”. Read more

Hungary

Tax legislation approved and regulatory update Innovation contribution 1 January 2019Companies qualifying as micro- or small-size enterprises continue to be exempt from the “innovation contribution.” However, beginning 1 January 2019, whether SMEs qualify for exemption from the innovation contribution is no longer based solely on the financials of the individual company. Read more  

Ireland

Tax legislation approved and regulatory update Tax compliance  31 March 2019 The deadline for filing information returns with respect to employee share participation schemes for 2018 must be filed by 31 March 2019. Read more
Proposed legislation Brexit  22 February 2019 The Irish government released a bill in an effort to address uncertainty regarding “Brexit” and specifically if there is a “no deal” Brexit on 29 March 2019. Read more

Italy

Tax legislation approved and regulatory update VAT / E-commerce  February 2019  The Italian government issued a decree and a press release in an attempt to clarify application of the rules under a new law in Italy relating to VAT and e-commerce (remote) sales of electronics. Read more

Luxemburg

Tax legislation approved and regulatory update Multilateral instrument 14 February 2019 The Luxembourg Parliament passed legislation for the ratification of the Multilateral Instrument into Luxembourg domestic tax law. Read more

Malta

Proposed legislation  Corporate income tax / VAT  February 2019 KPMG in Malta prepared a summary of the corporate income tax and VAT measures proposed in the Budget Measures Implementation Act, 2018. Read more

Netherlands

Tax legislation approved and regulatory update Multilateral instrument   February 2019 The process in the Netherlands for implementing the Multilateral Instrument has advanced. Read more
Other  Brexit February 2019 A Dutch governmental agency has issued a report that examines possible near-term implications of the UK’s departure from the European Union—Brexit. Read more

Nigeria

Tax legislation approved and regulatory update Corporate governance  February 2019 The Financial Reporting Council of Nigeria released a corporate governance code that is based on six governance pillars and 28 principles. Read more
Tax legislation approved and regulatory update Excise duties  4 June 2019 Nigeria’s federal government announced that the effective date for the revised excise rates on tobacco and alcoholic beverages is 4 June 2019.
Tax legislation approved and regulatory update Tax collection  February 2019 The Federal Inland Revenue Service issued “Letters of Substitution” under provisions of Nigerian tax law to appoint certain banks to serve as tax collection agents for customers that are identified as “affected companies” and that maintain bank accounts with those banks. Read more
Tax legislation approved and regulatory update Tax collection  February 2019 The Federal Inland Revenue Service directed the banks to suspend tax liens on bank accounts of alleged tax defaulters for a period of 30 days. Read more

San Marino

Tax legislation approved and regulatory update Various tax areas  February 2019 

There have been reforms in corporate and tax law in the Republic of San Marino, along with an ever-increasing number of tax information exchange agreements and income tax treaties. Read more

South Africa

Tax legislation approved and regulatory update Budget 20 February 2019
The Minister of Finance delivered the budget speech for 2019, and while the 2019 budget proposals would not increase taxes in any category, it is proposed to increase tax collection by not adjusting for inflation and by improving the efficiency of the South African Revenue Service. Read more
Tax legislation approved and regulatory update Competition law  13 February 2019 The Competition Amendment Act introduces extensive changes to the South African competition law landscape. Read more
Tax legislation approved and regulatory update Voluntary disclosure relief February 2019 Applications filed by taxpayers seeking relief under a voluntary disclosure programme of the South African Revenue Service have been rejected when the “default” was declared in periods when no tax returns were filed. Read more
Proposed legislation Carbon tax  1 June 2019 The Finance Minister has confirmed that a carbon tax will be implemented 1 June 2019. Read more
Proposed legislation Tax incentives  February 2019 Relief is available to businesses in the form of incentives. Read more

Spain

Tax legislation approved and regulatory update Digital services tax  25 January 2019 A bill for a digital services tax has been published in the official journal of the Spanish legislature. Once enacted, would be expected to apply during the second half of 2019. Read more
Administrative and case law   State aid  26 February 2019 The CJEU released a judgment that rejected the European Commission’s decision to classify a tax regime applicable to four Spanish professional football clubs as “state aid.” The cases are: Athletic Club v. Commission, T-679/16, and Fútbol Club Barcelona v. Commission, T-865/16. Read more

Sweden

Proposed legislation  Mandatory disclosure reporting 24 April 2019 A draft proposal in Sweden for implementing EU mandatory disclosure reporting rules is subject to public consultation until 24 April 2019. Read more

Switzerland

Tax legislation approved and regulatory update Corporate income tax  2019  The Swiss tax conference released an amended and updated version of Circular 5 concerning the inter-cantonal (and international) allocation of net income and net wealth of banks for Swiss tax purposes. Read more
Proposed legislation  Tax reform  19 May 2019 Swiss voters on 19 May 2019 will vote on the “Federal Act on Tax Reform and AHV Financing”. At the same time, the implementation process is progressing at the cantonal level, with some cantons having held (or about to hold) referendums. Read more

United Kingdom

Proposed legislation  SDLT February 2019 A consultation on introducing a 1 percent SDLT surcharge for purchases of dwellings in England and Northern Ireland made by non-UK resident buyers has been published. Read more
Administrative and case law   Capital allowances February 2019 The First-tier Tribunal decides on the eligibility for capital allowances on the construction of a silo provided for temporary storage. The case is: Stephen May v HMRC. Read more
Administrative and case law   Capital allowances February 2019 The First-tier Tribunal decides the value attributable to second hand property fixtures on the sale of a property for capital allowances purposes. The case is: Glais House Care Limited (GHC) v HMRC. Read more
Administrative and case law Repayment claims February 2019 Upper Tribunal ruled on the practicalities and procedural issues for claims made for repayment of direct tax. The case is: GLL BVK International Immobilien Spezialfonds & iii-BVK Europa Immobilien Spezialfonds v HMRC. Read more
Administrative and case law Vat February 2019 The Upper Tribunal issued a decision relevant for partly exempt businesses generally and asset management businesses in particular. The case is: BlackRock Investment Management (UK) Ltd v HMRC. Read more
Treaties Double tax treaties December 2018 / January 2019 Three new double tax treaties entered into force between the UK and Guernsey, Isle of Man and Jersey. Read more

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