Europe & Africa region - International Tax Newsletter

A timely outlook on international tax developments being reported globally.

International Tax Europe and Africa March 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 March and 31 March 2024.

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.

Rodney Lawrence

Head of Consulting for Strategic Corporates, Tax & Legal

KPMG International

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Angola

	Tax area concerned	Relevant date	Description of measures and publication link
Angola
Tax legislation approved and regulatory update	Indirect tax	06 March 2024	Revisions to Value Added Tax (VAT) law, including taxation of e-commerce transactions. Read more.

Anguilla

	Tax area concerned	Relevant date	Description of measures and publication link
Anguilla
Tax legislation approved and regulatory update	Tax compliance	20 March 2024	FATCA and common reporting standards (CRS) reporting deadline remains 31 May 2024. Read more.

Azerbaijan

	Tax area concerned	Relevant date	Description of measures and publication link
Azerbaijan
Tax legislation approved and regulatory update	Tax compliance	01 March 2024	Electronic accounting required for certain entities. Read more.
Tax legislation approved and regulatory update	Various tax topics	01 March 2024	Designation of strategic investment projects qualifying for tax benefits. Read more.

Belgium

	Tax area concerned	Relevant date	Description of measures and publication link
Belgium
Administrative and case law	Tax compliance	04 March 2024	Advocate General opinion on the validity of DAC6 and the applicability of the professional privilege waiver to non-lawyers. Read more.

Cyprus

	Tax area concerned	Relevant date	Description of measures and publication link
Cyprus
Tax legislation approved and regulatory update	Various tax topics	29 March 2024	End of reduced excise taxes on certain fuels, Value Added Tax (VAT) on certain products. Read more.
Proposed legislation	Indirect tax	22 March 2024	Consultations on draft legislation on carbon tax on energy products, daily accommodation fee. Read more.
Tax legislation approved and regulatory update	Tax Compliance	15 March 2024	Guidance on submission of data to register of beneficial owners. Read more.
Tax legislation approved and regulatory update	Indirect Tax	15 March 2024	Compliance campaign for stamp tax liability. Read more.
Proposed legislation	BEPS Pillar 2	14 March 2024	Draft legislation implementing Pillar Two global minimum tax rules. Read more.
Tax legislation approved and regulatory update	Income tax	12 March 2024	Notional interest deduction “reference rates” for 2024. Read more.
Tax legislation approved and regulatory update	Income tax	08 March 2024	Submission of statements of dividend and interest withholding forms expected soon. Read more.

Czech Republic

	Tax area concerned	Relevant date	Description of measures and publication link
Czech Republic
Administrative and case law	Indirect tax	11 March 2024	Beneficial ownership of royalties, Value Added Tax (VAT) exemption for intra-community supply, proof of “essential costs”. Read more.
Proposed legislation	Indirect tax	11 March 2024	Draft amendments to Value Added Tax (VAT) law include narrowing of exemptions for financial activities. Read more.
Administrative and case law	Indirect tax	05 March 2024	No exemption under European Union Value Added Tax (VAT) common system when proof not provided that recipient is taxable person. Read more.

Estonia

	Tax area concerned	Relevant date	Description of measures and publication link
Estonia
Administrative and case law	Income tax	27 March 2024	Penalties on taxpayer who failed to appear in person to provide explanations to tax authority upheld. Read more.
Tax legislation approved and regulatory update	Treaties	27 March 2024	Income tax treaty with Qatar signed, treaty with Pakistan reaches second reading in Parliament. Read more.
Proposed legislation	Transfer pricing	15 March 2024	Draft bill implementing the European Union (EU) Public Country-by-Country (CbyC) Reporting Directive submitted to Parliament. Read more.

European Union

	Tax area concerned	Relevant date	Description of measures and publication link
European Union
Tax legislation approved and regulatory update	Income tax	15 March 2024	The Committee on Economic and Monetary Affairs (ECON) adopts its opinion on Faster and Safer Relief of Excess Withholding Taxes (FASTER) proposal. Read more.
Tax legislation approved and regulatory update	Transfer pricing	15 March 2024	The Committee on Economic and Monetary Affairs (ECON) adopts report on Transfer Pricing Directive. Read more.
Administrative and case law	Transfer pricing	15 March 2024	Taxpayer appeals the General’s Court dismissal of the challenge against the European Union (EU) Minimum Tax Directive. Read more.
Tax legislation approved and regulatory update	Income tax	13 March 2024	European Economic and Social Committee (EESC) weighs in on Taxation of Teleworkers. Read more.
Administrative and case law	Indirect tax	11 March 2024	Value Added Tax (VAT) obligations of digital platforms pre-2015 (Court of Justice of the European Union (CJEU) referral). Read more.
Tax legislation approved and regulatory update	Indirect tax	05 March 2024	European public prosecutor's office estimates serious Value Added Tax (VAT) fraud amounting to EUR11.5 billion. Read more.

Finland

	Tax area concerned	Relevant date	Description of measures and publication link
Finland
Tax legislation approved and regulatory update	BEPS Pillar 2	21 March 2024	Legislation implementing Pillar Two global minimum tax. Read more.
Tax legislation approved and regulatory update	Tax compliance	21 March 2024	Updated FATCA and common reporting standards (CRS) technical guidance. Read More.

France

	Tax area concerned	Relevant date	Description of measures and publication link
France
Tax legislation approved and regulatory update	Tax compliance	29 March 2024	Updated common reporting standards (CRS) technical guidance. Read more.
Tax legislation approved and regulatory update	Indirect tax	15 March 2024	Value Added Tax (VAT) recovery for Olympics operators with new expenses in France. Read more.
Tax legislation approved and regulatory update	Tax compliance	07 March 2024	Updated FATCA reporting technical guidance. Read more.

Germany

	Tax area concerned	Relevant date	Description of measures and publication link
Germany
Proposed legislation	Various tax topics	26 March 2024	Tax reform bill enacted, other tax developments. Read more.
Tax legislation approved and regulatory update	Indirect tax	25 March 2024	Parliament approves legislation introducing e-invoicing mandate. Read more.
Tax legislation approved and regulatory update	Tax compliance	19 March 2024	Guidance on shareholder data reporting requirement for listed companies beginning 2025. Read more.
Tax legislation approved and regulatory update	Tax compliance	19 March 2024	Updated common reporting standards (CRS) communication manual. Read more.
Tax legislation approved and regulatory update	Transfer pricing	15 March 2024	Updated guidance on criteria for permanent establishment (PE) published. Read more.

Greece

	Tax area concerned	Relevant date	Description of measures and publication link
Greece
Tax legislation approved and regulatory update	Tax compliance	20 March 2024	Extension of deadlines for updating retail payment systems. Read more.

Guernsey

	Tax area concerned	Relevant date	Description of measures and publication link
Guernsey
Tax legislation approved and regulatory update	Tax compliance	06 March 2024	FATCA and common reporting standards (CRS) deadlines and reporting requirements (Guernsey). Read more.

Ireland

	Tax area concerned	Relevant date	Description of measures and publication link
Ireland
Tax legislation approved and regulatory update	BEPS Pillar 2	25 March 2024	Tax changes for the asset management and funds industry, including Pillar Two rules. Read more.

Isle of Man

	Tax area concerned	Relevant date	Description of measures and publication link
Isle of Man
Tax legislation approved and regulatory update	Tax compliance	04 March 2024	Guidance on tax treatment of dividends from domestic companies. Read more.

Italy

	Tax area concerned	Relevant date	Description of measures and publication link
Italy
Tax legislation approved and regulatory update	Income tax	15 March 2024	New tax credit for energy saving investments. Read more.
Tax legislation approved and regulatory update	Transfer pricing	11 March 2024	Transfer pricing requirements for investment manager exemption. Read more.

Kenya

	Tax area concerned	Relevant date	Description of measures and publication link
Kenya
Tax legislation approved and regulatory update	Indirect tax	28 March 2024	Affordable Housing Act signed by president. Read more.
Tax legislation approved and regulatory update	Indirect tax	13 March 2024	New platform for non-Value Added Tax (VAT) registered taxpayers to electronically generate and send invoices. Read more.

Latvia

	Tax area concerned	Relevant date	Description of measures and publication link
Latvia
Tax legislation approved and regulatory update	Tax compliance	15 March 2024	Ministry of Finance updated domestic list of low-tax or tax-free jurisdictions. Read more.

Liechtenstein

	Tax area concerned	Relevant date	Description of measures and publication link
Liechtenstein
Tax legislation approved and regulatory update	Tax compliance	12 March 2024	Updated Automatic Exchange of Information (AEOI) correction and deletion procedures. Read more.

Luxembourg

	Tax area concerned	Relevant date	Description of measures and publication link
Luxembourg
Tax legislation approved and regulatory update	BEPS Pillar 2	28 March 2024	Guidance under Pillar Two law relating to inclusion of deferred tax assets and liabilities in computing effective tax rate. Read more.
Tax legislation approved and regulatory update	Tax compliance	19 March 2024	Tax authorities begin FATCA and common reporting standards audits. Read more.

Malta

	Tax area concerned	Relevant date	Description of measures and publication link
Malta
Tax legislation approved and regulatory update	BEPS Pillar 2	14 March 2024	Guidance on implementation of Pillar Two global minimum tax. Read more.
Tax legislation approved and regulatory update	Tax compliance	04 March 2024	Updated automatic exchange of information (AEOI) implementing guidelines. Read more.

Morocco

	Tax area concerned	Relevant date	Description of measures and publication link
Morocco
Tax legislation approved and regulatory update	Indirect tax	04 March 2024	Value Added Tax (VAT) on cross-border provision of digital services. Read more.

Namibia

	Tax area concerned	Relevant date	Description of measures and publication link
Namibia
Proposed legislation	Various tax topics	13 March 2024	Tax measures in budget 2024-2025. Read more.

Netherlands

	Tax area concerned	Relevant date	Description of measures and publication link
Netherlands
Tax legislation approved and regulatory update	Transfer pricing	29 March 2024	Public country-by-country (CbyC) reporting implemented. Read more.
Administrative and case law	Income tax	27 March 2024	Interest deduction denied under fraud provision of corporate income tax law. Read more.
Administrative and case law	Transfer pricing	20 March 2024	European Union (EU) Court Advocate General concludes that Dutch interest deduction limitation anti-profit shifting rule is compatible with EU law and urges Court of Justice of the European Union to revisit previous judgment. Read more.
Administrative and case law	Indirect tax	18 March 2024	Pension funds not treated as special investment funds eligible for Value Added Tax (VAT) exemption. Read more.
Administrative and case law	Indirect tax	18 March 2024	Old taxpayer portal used for filing Value Added Tax (VAT) returns will close 1 July 2024. Read more.
Proposed legislation	Indirect tax	08 March 2024	Consultation on draft bill on Value Added Tax (VAT) adjustment on services to immovable property. Read more.
Tax legislation approved and regulatory update	Indirect tax	05 March 2024	KPMG report: Shipping and offshore tax update (March 2024). Read more.

Nigeria

	Tax area concerned	Relevant date	Description of measures and publication link
Nigeria
Tax legislation approved and regulatory update	Indirect tax	21 March 2024	Executive orders relating to petroleum sector include new tax incentives. Read more.
Tax legislation approved and regulatory update	Income tax	12 March 2024	Introduction of self-registration module on electronic platform. Read more.

OECD

	Tax area concerned	Relevant date	Description of measures and publication link
OECD
Tax legislation approved and regulatory update	BEPS Pillar 1	19 March 2024	Amount B compliance challenges. Read more.
Tax legislation approved and regulatory update	Transfer pricing	19 March 2024	KPMG report: Implications of International Compliance Assurance Programme statistics. Read more.

Poland

	Tax area concerned	Relevant date	Description of measures and publication link
Poland
Administrative and case law	Indirect tax	26 March 2024	Cash register receipts alone are valid evidence of overstated Value Added Tax (VAT) (CJEU judgment). Read more.
Proposed legislation	Indirect tax	22 March 2024	Update on consultations on national e-invoicing system (KSeF). Read more.
Tax legislation approved and regulatory update	Indirect tax	19 March 2024	Temporary zero Value Added Tax (VAT) rate on food products not extended. Read more.
Administrative and case law	Various tax topics	19 March 2024	Interpretation of retail sales tax law, lump-sum car allowance taxable, expenses for B2B team-building meetings not deductible. Read more.
Administrative and case law	Income tax	12 March 2024	General working time not eligible for Research & Development (R&D) relief. Read more.
Tax legislation approved and regulatory update	Income tax	12 March 2024	Certain European Union (EU) non-cooperative jurisdictions not included in list of countries applying harmful tax competition. Read more.
Proposed legislation	Income tax	05 March 2024	Bill introducing option for small enterprises to elect cash method. Read more.
Proposed legislation	Indirect tax	05 March 2024	Proposed reduction in Value Added Tax (VAT) rate on beauty treatment services. Read more.
Proposed legislation	BEPS Pillar 2	05 March 2024	Bill implementing Pillar Two global minimum tax. Read more.

Serbia

	Tax area concerned	Relevant date	Description of measures and publication link
Serbia
Tax legislation approved and regulatory update	Indirect tax	07 March 2024	Value Added Tax (VAT) refund for 2023 to foreign taxpayers. Read more.

South Africa

	Tax area concerned	Relevant date	Description of measures and publication link
South Africa
Administrative and case law	Transfer pricing	28 March 2024	Comparable uncontrolled price method held most reliable method. Read more.
Tax legislation approved and regulatory update	Tax compliance	28 March 2024	FATCA and Common Reporting Standards third party data submission period. Read more.

Spain

	Tax area concerned	Relevant date	Description of measures and publication link
Spain
Tax legislation approved and regulatory update	Tax compliance	05 March 2024	Digital platform operators must file returns under DAC7 by 8 April 2024. Read more.

Sweden

	Tax area concerned	Relevant date	Description of measures and publication link
Sweden
Tax legislation approved and regulatory update	Income tax	19 March 2024	Expert Tax Relief Is Extended. Read more.
Administrative and case law	Tax compliance	19 March 2024	Taxpayer entitled to penalty relief for incorrectly claimed interest deductions. Read more.
Administrative and case law	Income tax	07 March 2024	Further guidance on application of “3:12 rules” in cases of significant outside ownership. Read more.

Switzerland

	Tax area concerned	Relevant date	Description of measures and publication link
Switzerland
Proposed legislation	Income tax	01 March 2024	Draft law to reduce wealth tax on shares of unlisted companies held by entrepreneurs (Geneva). Read more.
Tax legislation approved and regulatory update	Tax compliance	01 March 2024	Suspension of tax information with Hong Kong and Singapore. Read more.

United Kingdom

	Tax area concerned	Relevant date	Description of measures and publication link
United Kingdom
Tax legislation approved and regulatory update	Transfer pricing	29 March 2024	KPMG report: New United Kingdom transfer pricing guidance on allocation of risk in controlled transactions. Read more.
Proposed legislation	Various tax topics	25 March 2024	Finance (No. 2) Bill 2024 published. Read more.
Proposed legislation	Income tax	25 March 2024	Payroll reporting changes - His Majesty's Revenue & Customs consult on draft legislation. Read more.
Proposed legislation	Tax compliance	15 March 2024	Consultation on cryptoasset reporting framework (CARF) and common reporting standard (CRS) amendments. Read more.
Tax legislation approved and regulatory update	BEPS Pillar 2	15 March 2024	Finance Act 2024 implemented including amendments to minimum taxation (under Pillar Two). Read more.
Proposed legislation	Various tax topics	07 March 2024	Spring Budget 2024. Read more.

Zambia

	Tax area concerned	Relevant date	Description of measures and publication link
Zambia
Tax legislation approved and regulatory update	Indirect tax	21 March 2024	Value Added Tax (VAT) on cross-border provision of digital services. Read more.