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.
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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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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. |
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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