International Tax Round-up - February 2019
This publication gives an overview of key international tax developments across the Linklaters network. Click here to read more.
Topics include:
International Developments
- OECD consultation on taxing the digital economy
EU Developments
- CJEU finds input VAT recovery of branch affected by exempt supplies made by head office
- CJEU finds jurisdiction of policyholder determines taxing rights over W&I insurance
Germany
- Brexit Accompanying Tax Act
- Exemption from German real estate transfer tax for intra-group restructuring not illegal state aid
Netherlands
- The Netherlands draws up its own blacklist to combat tax avoidance
- Dutch State Secretary for Finance announces transitional measures in case of a no-deal Brexit
Portugal
- New REITs Regime
- Portugal-Angola Tax Treaty Ratification
- ATAD 1 and 2 Bill of Law
Sweden
- Swedish proposal to implement DAC 6 into Swedish law
- Swedish proposal to implement the EU tax dispute resolution mechanisms
- Swedish proposal to implement further anti-hybrid regulations
- Official statement from the Swedish Tax Agency on servers as permanent establishments
- Advanced ruling regarding shares in a US corporation with an elected DISC status
- Advanced ruling regarding shares in a company domiciled in the Bahamas
- Opinion of the Advocate General on absence of cross-border relief for “final” losses
United Kingdom
- Disclosure facility for MNEs potentially within the scope of DPT
- Consultation on SDLT surcharge for non-UK residents
- Court of Appeal finds information notice issued to non-resident valid