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International Tax Newsletter - Europe & African region

Europe & African region

International Tax Newsletter

Europe and Africa regions

February 2018

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 and 28 February 2018.

 

Austria Belgium Botswana Croatia
Cyprus Czech Republic Denmark France
Germany Ireland Isle of Man Italy
Netherlands Nigeria OECD Romania
Serbia South Africa Sweden Switzerland
United Kingdom      



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.

International Tax Newsletter - Europe & African region

Austria

Administrative and case law

Corporate income tax / Tax losses - 15 February 2018

The Austrian Federal Finance Court issued a decision concerning the ability of a company to carry forward its tax losses in instances when there is a change in the organizational structure of the company. 

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Belgium

Tax legislation approved and regulatory update

Individual taxation - 30 September 2018

The Belgian Parliament passed legislation introducing an annual tax at a rate of 0.15 percent on the value of certain securities accounts of individuals (both Belgian tax residents and non-residents).

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Administrative and case law

Labor law - 21 February 2018

The Court of Justice of the European Union issued a judgment concluding that the stand-by time of a worker at home who is obliged to respond to calls from the employer within a short period must be regarded as “working time” as defined by EU law. The case is: Ville de Nivelles v. Matzak (C-518/15).

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Botswana

Proposed legislation

Corporate income tax / Transfer pricing  - 2018

The 2018-2019 budget was presented to the national assembly. Among other, amendments would introduce transfer pricing rules and would aim to address a perception that Botswana is a “tax haven.”

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Crotia

Tax legislation approved and regulatory update

Corporate income tax - 1 January 2018

Tax provisions in Croatia, effective beginning 1 January 2018, include:

  • the maximum tax deductible interest rate on loans received by a taxpayer from a foreign related party, decreased from 4.97 percent per annum to 4.55 percent per annum
  • the minimum taxable interest rate on loans provided by a taxpayer to a foreign related party, decreased from 4.97 percent per annum to 4.55 percent per annum.

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Cyprus

Tax legislation approved and regulatory update

VAT - 22 January 2018

The Cyprus Tax Department issued a circular on the treatment of services for servicing the immediate needs of ships.

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VAT - 8 February 2018

KPMG in Cyprus provides an update on the special VAT scheme for tour operators.

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Czech Republic

Proposed legislation

Corporate income tax / Individual taxation -  2019

The first draft of an amendment to the income tax law, would implement certain tax law changes expected to be effective in 2019. Changes would affect:

  • individual (personal) income tax 
  • deductibility of borrowing costs 
  • controlled foreign companies rules 
  • exit tax
  • hybrid mismatches
  • abuse of right.

Read more

 

VAT - 1 January 2019

The Czech Ministry of Finance submitted a draft amendment to the VAT law that would be effective January 2019.

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Denmark

Administrative and case law

Corporate income tax / Permanent establishment - 21 February 2018

Advocate General Campos of the Court of Justice of the European Union issued his Opinion on a case concerning the compatibility with EU law of the Danish rules on the deductibility of losses from a Danish permanent establishment whose head office is not tax resident in Denmark. The case is: NN A/S (C-28/17).

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France

Administrative and case law

Anti-tax avoidance - February 2018

The French Constitutional Court is expected to issue a decision that will address whether an anti-avoidance tax provision of French tax law—concerning the rules on the recapture of financial expenses of a French tax group in instances of corporation acquisitions—is constitutional.

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Germany

Tax legislation approved and regulatory update

VAT - 2021

The Council of the EU in December 2017 adopted measures intended to simplify the VAT system for online businesses in the EU.

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Administrative and case law

Corporate income tax - 7 February 2018

The Advocate General of the Court of Justice of the European Union issued his opinion on a case concerning the compatibility of the German participation exemption regime applicable to dividends originating in third countries with the free movement of capital. The case is: EV v Finanzamt Lippstadt (C-685/16).

Read more

Ireland

Administrative and case law

VAT - February 2018

KPMG in Ireland prepared a summary of recent VAT developments and case law.

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Isle of Man

Proposed legislation

Various tax areas  - 20 February 2018

The Treasury Minister delivered his second Manx Budget introducing several tax measure.

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Italy

Tax legislation approved and regulatory update

Individual taxation - February 2018

The Budget Law 2018 includes measures that may affect the taxation of high net-worth individuals.

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Netherlands

Tax legislation approved and regulatory update

Individual taxation/ Labor law - 14 February 2018

Dutch government officials sent a letter to the Lower House of Parliament announcing a delay to an “employment relationships deregulation” law.

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Proposed legislation

Beneficial owner - January 2018

A draft decree provides definitions of who is an “ultimate beneficial owner” (UBO) and clarifies the categories of persons regarded as the UBO for purposes of the UBO register.

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Administrative and case law update

Corporate income tax / Fiscal unity - February 2018

The Court of Justice of the European Union rendered its decision in two cases on the Dutch fiscal unity regime. The cases are: C-398/16 and C-399/16.

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Nigeria

Proposed legislation

Various tax areas -  February 2018

KPMG in Nigeria prepared a report which reviews the budget proposals for 2018 and highlights how the proposed policy changes will affect the Nigerian business environment from business, regulatory and tax perspectives.

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KPMG Publications

Nigerian Tax Journal 2018 - February 2018

The second edition of the Nigerian Tax Journal contains a summary of significant decisions on tax cases (that became publicly available) in 2017.

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Other

Tax amnesty - December 2017

KPMG in Nigeria prepared a factsheet on the Nigerian tax amnesty.

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OECD

Other

Energy taxation - 14 February 2018

An OECD report describes patterns of energy taxation in 42 OECD and G20 countries (representing approximately 80 percent of global energy use), by fuels and sectors over the 2012-2015 period.

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Romania

Tax legislation approved and regulatory update

Environment fund - 7 February 2018

The new instructions for completing and submitting the declaration on obligations to the Environment Fund form now allow this to be submitted in electronic format.

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Serbia

Tax legislation approved and regulatory update

Individual taxation - 15 May 2018

In Serbia, the deadline for filing annual individual income tax returns for 2017 is 15 May 2018.

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South Africa

Tax legislation approved and regulatory update

Corporate income tax / Tax compliance - 26 February 2018

The South African Revenue Service announced enhancements to the income tax return for companies.

Read more

 

VAT - 1 April 2018

The Minister of Finance announced an increase in the rate of VAT to 15 percent, effective beginning from 1 April 2018.

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Proposed legislation

Carbon tax - 5 February 2018

A second draft of a carbon tax bill has been released for public comment and introduced in Parliament.

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Various tax areas - 21 February 2018

The Finance Minister delivered the 2018 budget for South Africa, which includes tax and revenue raising proposals.

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Sweden

KPMG publication

Gambling - February 2018

KPMG in Sweden prepared a report summarizing a proposal to regulate the gambling market and strengthen the protection of the players.

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Switzerland

Proposed legislation

Various tax areas - March 2018

The Swiss Federal Council has decided not to make significant changes to the “Tax Proposal 17” from the version provided for consultation, and the final legislative proposal is expected at the end of March 2018.

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United Kingdom

Tax legislation approved and regulatory update

Various tax areas - 2 February 2018

New or revised HMRC guidance has been published covering changes to the rules for non-doms, offshore trusts and business investment relief.

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Hybrid mismatches - 2 February 2018

KPMG in the UK takes a detailed look at the updated hybrids guidance and legislative amendments in Finance Bill 2018.

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Inheritance tax - 9 February 2018

HMRC guidance published covering changes to the inheritance tax deemed domicile rules and new rules extending scope of inheritance tax to UK residential property.

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Corporate interest restriction - 31 March 2018

A 31 March 2018 deadline is looming for many groups to take certain steps in relation to the new corporate interest restriction regime.

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Trade - 31 July 2018

New HMRC guidance on the application of End Use relief will impact businesses who import goods when the use or end destination is not known.

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Other

Corporate income tax / Intangible fixed assets regime - 23 February 2018

The Government is seeking comments on how the UK’s intangible fixed assets regime could be amended to help support the competitiveness of UK businesses.

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