International Tax Europe and Africa April 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 April and 30 April 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.

Albania

 

Tax area concerned

Relevant date

Description of measures and publication link

Albania

Tax legislation approved and regulatory update

Income tax

18 April 2022

The Albanian government has amended the national-level minimum salary and adopted a new taxation method for employment income. 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

Tax compliance

06 April 2022

A publication dated 31 March 2022 extends the date for filing income tax returns by companies and "self-employed with accounts" for the year 2020. Read more.

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European Union

 

Tax area concerned

Relevant date

Description of measures and publication link

European Union

KPMG Publication

Income tax

06 April 2022

On April 5, 2022, KPMG member firms in the EU submitted a response to the European Commission's (EC's) public consultation on the proposed EU Directive on rules to prevent the misuse of shell entities for tax purposes. Read more.

KPMG Publication

Transfer pricing

05 April 2022

The Economic and Financial Affairs Council of the EU did not reach political agreement on the revised compromise text for an EU Minimum Tax Directive in its April 5, 2022 meeting, due to reservations from Poland. Read more.

Finland

 

Tax area concerned

Relevant date

Description of measures and publication link

Finland

Administrative and case law

Income tax

07 April 2022

French corporate-form fund held comparable with contractual-based fund; refund opportunities (CJEU judgment)Read more.

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Germany

 

Tax area concerned

Relevant date

Description of measures and publication link

Germany

Tax legislation approved and regulatory update

Income tax

26 April 2022

Revision of coordinated decree of federal states on trade tax add-backs. Read more.

Administrative and case law

Income tax

26 April 2022

Disallowance of final losses incurred by UK permanent establishment held valid (CJEU Advocate General opinion). Read more.

Administrative and case law

Income tax

26 April 2022

Contribution gain II due to change of legal form (court decision). Read more.

Tax legislation approved and regulatory update

COVID-19 recovery

26 April 2022

Various consultation agreements between Germany and neighboring countries have been extended for the last time until 30 June 2022 Read more.

Tax legislation approved and regulatory update

Tax compliance

05 April 2022

Germany's federal central tax office released guidance (CRS Newsletter 03/2022) with updated information concerning the common reporting standard (CRS) regime and implications for refugees from Ukraine. Read more.

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Gibraltar

 

Tax area concerned

Relevant date

Description of measures and publication link

Gibraltar

Administrative and case law

Various tax topics

22 April 2022

On April 6, 2022, the General Court of the European Union gave its decision in a case concerning the compatibility with EU law of Gibraltar's corporate income tax exemption regime for royalties and of related individual tax rulings Read more.

Guernsey

 

Tax area concerned

Relevant date

Description of measures and publication link

Guernsey

Tax legislation approved and regulatory update

Tax compliance

21 April 2022

All reporting Guernsey financial institutions must submit their 2021 FATCA and CRS reports on or before 30 June 2022. Read more.

Tax legislation approved and regulatory update

Income tax

05 April 2022

The tax authority in Guernsey issued guidance relating to the FATCA and common reporting standard (CRS) regimes. Read more.

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Kenya

 

Tax area concerned

Relevant date

Description of measures and publication link

Kenya

Proposed legislation

Various tax topics

21 April 2022

The Finance Bill 2022 includes transfer pricing and other tax-related measures. Read more.

Proposed legislation

Tax compliance

11 April 2022

The budget statement for 2022-2023includes a proposal that MNEs with operations in Kenya would be required to report their activities both within Kenya and in other jurisdictions to the Kenya Revenue Authority. Read more.

Latvia

 

Tax area concerned

Relevant date

Description of measures and publication link

Latvia

Tax legislation approved and regulatory update

Income tax

11 April 2022

Corporate income tax changes include measures for “doubtful debts,” interest expense limits. Read more.

KPMG Publication

Tax compliance

11 April 2022

Implications of EU “public” country-by-country reporting for Latvian groups. Read more.

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Lithuania

 

Tax area concerned

Relevant date

Description of measures and publication link

Lithuania

KPMG Publication

Various tax topics

01 April 2022

This card was prepared as a quick-reference tool for the most common tax rates and amounts. Read more.

Luxembourg

 

Tax area concerned

Relevant date

Description of measures and publication link

Luxembourg

Administrative and case law

Income tax

28 April 2022

Tax exemption under participation regime, beneficial ownership and withholding tax refunds (court decisions)Read more.

Tax legislation approved and regulatory update

Income tax

15 April 2022

The Luxembourg tax authority issued a newsletter about the implementation of updated provisions related to the tax identification number field for FATCA reporting purposes. Read more.

Tax legislation approved and regulatory update

Income tax

13 April 2022

The Luxembourg tax authority issued an updated set of FAQs related to the common reporting standard regime. Read more.

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Netherlands

Tax area concerned

Relevant date

Description of measures and publication link

Netherlands

Proposed legislation

Income tax

19 April 2022

Deputy Minister of Finance on 15 April 2022 sent two letters about "Box 3" (the wealth tax regime) to the Lower House of Parliament. Read more.

Proposed legislation

Income tax

06 April 2022

The Deputy Minister of Finance announced on 4 April 2022 that the effective date of the employee share options rights tax measure proposed as part of the 2022 Tax Plan package will be postponed until 1 January 2023, but the proposal remains otherwise unchanged. Read more.

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Norway

 

Tax area concerned

Relevant date

Description of measures and publication link

Norway

Proposed legislation

Income tax

13 April 2022

The Norwegian government on 8 April 2022 unveiled proposals that would amend the current petroleum tax system and move it toward a cash flow-oriented tax system. Read more.

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OECD

 

Tax area concerned

Relevant date

Description of measures and publication link

OECD

Proposed legislation

Transfer pricing

22 April 2022

The Organisation for Economic Cooperation and Development today released comments received on draft model rules for domestic legislation on scope under Amount A of Pillar One. Read more.

Proposed legislation

Transfer pricing

14 April 2022

The Organisation for Economic Cooperation and Development today issued a release seeking public comments on the extractives exclusion under Amount A of Pillar One. Read more.

Proposed legislation

Transfer pricing

14 April 2022

The Organisation for Economic Cooperation and Development on 14 March 2022 published commentary on the Pillar Two model rules which were released 20 December 2021 and provide a precise template for governments to move forward with Pillar Two of the two-pillar solution to address the tax challenges arising from digitalisation and globalisation of the economy. The OECD simultaneously issued a release seeking comments on the implementation framework of the global minimum tax. Read more.

Proposed legislation

Transfer pricing

14 April 2022

The Organisation for Economic Cooperation and Development (OECD) released comments received on the implementation framework of the global minimum tax. Read more.

Proposed legislation

Income tax

05 April 2022

The Organisation for Economic Cooperation and Development today released the first phase of a new global Inventory of Tax Technology Initiatives which contains information on the use of leading technology tools and digitalization solutions implemented by 76 tax administrations across the world. Read more.

Proposed legislation

Transfer pricing

04 April 2022

The Organisation for Economic Cooperation and Development today issued a release seeking public comments on the draft model rules for domestic legislation on scope under Amount A of Pillar One - part of the ongoing work of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) in implementing the two-pillar solution to address the tax challenges arising from the digitalisation of the economy. Read more.

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Poland


Tax area concerned

Relevant date

Description of measures and publication link

Poland

Proposed legislation

Various tax topics

15 April 2022

Closure of public consultation regarding new amendments to “Polish Deal”. Read more.

Administrative and case law

Income tax

14 April 2022

Individual ruling on depreciation for real estate companies under provisions in force until 1 January 2022. Read more.

Tax legislation approved and regulatory update

Tax compliance

14 April 2022

New list of states, territories subject to CRS reporting obligation for 2021. Read more.

KPMG Publication

Various tax topics

04 April 2022

Reports on recent tax developments in Poland Read more.

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Spain


Tax area concerned

Relevant date

Description of measures and publication link

Spain

Proposed legislation

Tax compliance

28 April 2022

A draft Royal Decree implements certain requirements for electronic or computer software and systems, to promote electronic invoicing systems.

. Read more.

Tax legislation approved and regulatory update

Indirect tax

28 April 2022

Law 7/2022, published in the official gazette on 9 April 2022, implements excise tax measures regarding non-reusable plastic packaging and landfills and incineration of waste. Read more.

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Switzerland

 

Tax area concerned

Relevant date

Description of measures and publication link

Switzerland

KPMG Publication

Transfer pricing

20 April 2022

KPMG report: Transfer pricing and the audit committee agenda. Read more.

KPMG Publication

Income tax

12 April 2022

Swiss implications of the OECD’s proposed crypto-asset reporting framework. Read more.

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United Kingdom

 

Tax area concerned

Relevant date

Description of measures and publication link

United Kingdom

KPMG Publication

Income tax

14 April 2022

HMRC's Residential Property Developer Tax guidance was published in March and is expected to evolve as the tax is implemented by business. Read more.

KPMG Publication

Transfer pricing

14 April 2022

In January 2022 HM Treasury and HMRC launched a consultation on the UK application and implementation of the OECD Model Rules on Pillar Two. This article summarizes the key themes of KPMG in the UK's response to the consultation which closed on 4 April 2022. Read more.

KPMG Publication

Various tax topics

01 April 2022

The Chancellor contemplates reforms to R&D tax incentives and capital allowances in his Tax Plan. Read more.

KPMG Publication

Income tax

01 April 2022

Chancellor unveils new Tax Plan in his 2022 Spring Statement including an unexpected cut in the basic rate of income tax in 2024. Read more.

KPMG Publication

Income tax

01 April 2022

No changes will be made to made to the Enterprise Management Incentives (EMI) regime following the Government's recent review. However, tax-advantaged Company Share Option Plans (CSOPs) will now be reviewed to establish whether the CSOP regime should be reformed to support companies that cease to qualify for EMI. This article discusses what this might mean for employers. Read more.

Administrative and case law

Income tax

01 April 2022

HMRC lost their appeal in NCL Investments Ltd, meaning that IFRS 2 debits were deductible as trading expenses for certain accounting periods. Read more.

Administrative and case law

Income tax

01 April 2022

The CA followed the FTT and UT in rejecting the classification of gas storage cavities as plant and qualifying for writing down allowances. Read more.

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Zambia

 

Tax area concerned

Relevant date

Description of measures and publication link

Zambia

KPMG Publication

Tax compliance

12 April 2022

Country-by-country reporting regulations were introduced in Zambia effective 1 January 2021 and applicable for years of assessment ending on or after 31 December 2021. Read more.

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Zimbabwe


Tax area concerned

Relevant date

Description of measures and publication link

Zimbabwe

Tax legislation approved and regulatory update

Tax compliance

20 April 2022

Extended deadlines for corporate income tax and transfer pricing returns for 2021Read more.

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