Tax 

In Brief from International Taxation – June

Austria is considering introducing the digital service tax as of 1 January 2020. Based on the CJEU the national courts are not eligible to determine if certain requirements of a state aid regime are compatible with the fundamental freedoms. Aruba, Barbados and Bermuda were removed from the list of non-cooperative jurisdictions. German Lower Tax Courts introduces new interpretation of anti-treaty shopping rules. The Dutch appellate court decided that there is no reason for TP adjustment to a hybrid loan. Poland introduced the rules for defining a beneficial owner. 

Tax 

In Brief from International Taxation – May

The German Federal Ministry of Finance confirmed that payments for online advertising attributed to recipients residing in another state are not subject to German withholding tax. In France, an act introducing the tax on digital services for firms with worldwide sales of over EUR 750 million and sales generated in France of over EUR 25 million was passed. This information and other news can be found in the following article. 

Tax 

International taxes in brief – April

Austrian government announced a package of proposals to tax the digital economy. According to European Commission UK CFC rules constitutes illegal state aid. This is only some of the news that you will read about in the International Tax News. 

Tax 

Free Trade Between the EU and Japan

The Economic Partnership Agreement (EPA) concluded between the EU and Japan on 17 July 2018 will enter into force on 1 February 2019, which is surprisingly ahead of the planned date. 

Tax 

Jersey: new economic substance requirements

On 23 October 2018, Jersey’s Minister for External Relations presented draft legislation that would introduce increased substance requirements on certain Jersey resident companies. 

Tax 

Changes in the Implementation of Double Tax Treaties Applicable From 2019 Onwards

On 1 January 2019, the new Treaty for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital that the Czech Republic signed in 2016 with Turkmenistan will start to be implemented. 

Tax 

Spain: draft bill for tax measures

On 23 October 2018, the Spanish government released three draft bills to implement some of the tax measures proposed in the 2019 budget. 

Tax 

UK: taxation of digital services

Key measures impacting non-UK owned groups announced in the 29 October 2018 budget include the introduction of a 2% digital services tax as from April 2020, applicable to groups with global revenue from such activities exceeding £500 million a year and income generated in the UK exceeding £25 million. 

Tax 

Netherlands: confirmation of CJEU decision in fiscal unity cases by Supreme Court

The Dutch Supreme Court issued a decision on 19 October 2018 confirming the February 2018 decision of the Court of Justice of the European Union (CJEU) on the compatibility of the Dutch fiscal unity regime with EU law.