International tax news in brief [August 2019]

The Slovakian government approved a draft law implementing ATAD 2. The Court of Justice of the European Union (CJEU) issued a decision in the Marks & Spencer case concerning the deduction of foreign subsidiary losses. France has introduced a 3% tax on digital services this year. What is new in the area of international taxation in Austria, Italy, the Netherlands and Slovenia?

Slovakian government approves draft law implementing ATAD 2

On 29 May 2019, the government approved a draft law introducing changes to the Income Tax Act including measures to implement the provisions of the EU Anti-Tax Avoidance Directive 2 (ATAD 2) as regards hybrid mismatches with third countries.

CJEU rules on cross-border use of losses

On 19 June 2019, the Court of Justice of the European Union (CJEU) issued its decision in two Swedish cases, further clarifying the application of the Marks & Spencer decision on the deduction of foreign subsidiary losses.

French parliament approves legislation creating digital services tax

On 11 July 2019, the French parliament approved draft legislation introducing a 3% digital services tax (DST) from 2019.

Austrian court rules use of Luxembourg holding companies is not abuse of parent-subsidiary directive

In a recently published decision of 27 March 2019, the Supreme Administrative Court ruled on the application of the EU parent-subsidiary directive to an interposed Luxembourg holding company concluding that the abuse of law is not relevant in this particular case.

Italian Supreme Court rules on tax residence of holding company

In a 28 May 2019 ruling, the court held that a foreign holding company cannot be deemed to be tax resident in Italy if the board of director and shareholder meetings are held in the foreign country, and the company has suitable premises in that country from which to manage its participations.

Netherlands establishes commission on taxation of multinationals

On 25 June 2019, the State Secretary for Finance announced the establishment of a commission that will make an inventory of measures that broaden the corporate tax base while also ensuring that the Netherlands remains attractive for head offices of multinational companies.

Slovenia proposes corporate tax rate increase

Proposals announced on 18 June 2019 include an increase in the standard corporate income tax rate from 19% to 20% as from 1 January 2020 and the introduction of a 7% minimum rate.

The article is part of dReport – August 2019, Tax news; Grants and investment Incentives.

Tax resident Corporate Income Tax Digital Services Tax ATAD CJEU International Taxes dReport newsletter

Upcoming events

Seminars, webcasts, business breakfasts and other events organized by Deloitte.

    Show morearrow-right