International Tax Europe and Africa August 2022

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 August and 31 August 2022.

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

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

To register for the International Tax webcasts, click here.

Bulgaria

 

Tax area concerned

Relevant date

Description of measures and publication link

Bulgaria

Tax legislation approved and regulatory update

Income tax

26 August 2022

Bulgaria has yet to deposit its instrument of ratification of the MLI with the OECD's Secretary-General. Read more.

Czech Republic

 

Tax area concerned

Relevant date

Description of measures and publication link

Czech Republic

Tax legislation approved and regulatory update

Tax compliance

09 August 2022

The General Financial Directorate (GFD) releases new information on reporting obligations for cross-border arrangements under DAC6. Read more.

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Finland

 

Tax area concerned

Relevant date

Description of measures and publication link

Finland

Tax legislation approved and regulatory update

Tax compliance

25 August 2022

Updated Frequently Asked Questions published for FATCA and common reporting standard (CRS) regimes. Read more.

 

Germany

 

Tax area concerned

Relevant date

Description of measures and publication link

Germany

Tax legislation approved and regulatory update

Income tax

24 August 2022

Retroactive reduction of the interest rate for interest on back taxes and refunds to 0.15% per month for interest periods from 1 January 2019. Read more.

Administrative and case law

Income tax

24 August 2022

The German Federal Tax Court held that the premises of a real property management company can be a permanent establishment of the contracting company, even if the contracting company has no power of disposal over the premises, if the contracting company uses the premises to conduct its own business operations. Read more.

Tax legislation approved and regulatory update

Income tax

24 August 2022

The simplification procedure for non-resident tax liability when rights listed in domestic registers has been extended. Read more.

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Gibraltar

 

Tax area concerned

Relevant date

Description of measures and publication link

Gibraltar

Tax legislation approved and regulatory update

Various tax topics

04 August 2022

Following the recent Gibraltar budget, a bill has been published that provides further information on the measures affecting companies. Read more.

Hungary

 

Tax area concerned

Relevant date

Description of measures and publication link

Hungary

Tax legislation approved and regulatory update

Tax compliance

18 August 2022

An updated version of the FATCA filing instructions includes the addition of a series of codes developed by the U.S. tax agency (IRS) that can be used by reporting financial institutions when the account is missing U.S. tax identification numbers. 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

24 August 2022

The Irish Revenue Commissioners issued an updated reporting entity registration form for Irish FATCA and common reporting standard (CRS) purposes for entities that do not have an Irish tax reference number. Read more.

KPMG Publication

Income tax

12 August 2022

Overview of the various funding mechanisms for companies for research and development (R&D) in Ireland. 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

Tax compliance

10 August 2022

The Italian tax authority issued Circular No. 21/2022 detailing the criteria for selecting large multinational entity (MNE) taxpayers with gross receipts of more than €100 million for audits. Read more.

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Mauritius

 

Tax area concerned

Relevant date

Description of measures and publication link

Mauritius

Tax legislation approved and regulatory update

Income tax

30 August 2022

Finance Bill 2022 passed with minor amendments in Parliament and was signed by the president. Read more.

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Nigeria

 

Tax area concerned

Relevant date

Description of measures and publication link

Nigeria

Administrative and case law

Income tax

11 August 2022

A court decision concerning retroactive application of tax law changes. Read more.

Poland

 

Tax area concerned

Relevant date

Description of measures and publication link

Poland

KPMG Publication

Income tax

29 August 2022

Recent tax developments relating to robotization following Supreme Court decision and tax authority ruling. Read more.

Proposed legislation

Various tax topics

29 August 2022

Legislation for the extension of an excise tax exemption for plug-in electric vehicles and anti-inflation measures is considered by the Council of Ministers. Read more.

Proposed legislation

Various tax topics

29 August 2022

A draft bill amending corporate income tax provisions enacted as part of the "Polish Deal", was submitted before the Lower House of the Polish Parliament on 22 August. Read more.

Proposed legislation

Transfer pricing

29 August 2022

A draft bill including measures to repeal a requirement to follow the arm’s length principle has been submitted. Read more.

KPMG Publication

Income tax

22 August 2022

Summaries of recent court decisions. Read more.

KPMG Publication

Various tax topics

17 August 2022

Recent tax developments relating to company reorganizations. Read more.

Tax legislation approved and regulatory update

Income tax

09 August 2022

Response to parliamentary inquiry on improved access of the tax authority to certain taxpayers' banking information. Read more.

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South Africa

Tax area concerned

Relevant date

Description of measures and publication link

South Africa

KPMG Publication

Income tax

03 August 2022

New accounting standard (IFRS 17 Insurance Contracts) changes the way insurance contracts are accounted for. Read more.

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United Kingdom

 

Tax area concerned

Relevant date

Description of measures and publication link

United Kingdom

KPMG Publication

Tax compliance

08 August 2022

The First-tier Tribunal has upheld HMRC's 'claw back' of CJRS grants - what are the potential implications for other employers? Read more.

Administrative and case law

Income tax

08 August 2022

Upper Tribunal upholds ruling that a commercial transaction structured in a tax-efficient way did not have a 'main purpose' of tax avoidance. Read more.

Administrative and case law

Transfer pricing

08 August 2022

 Implications for transfer pricing and the “unallowable purpose” rule following HMRC's successful appeal in a case that examined the deductibility of interest costs incurred on an intragroup loan used for a third-party acquisition. Read more.

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