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  • Service: Tax & Legal, International Corporate Tax
  • Date: 6/11/2014

International Tax - Europe & Africa (1 May and 31 May 2014) 

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 May and 31 May 2014.

 

 

Bulgaria

Italy

Romania

United Kingdom

Czech Republic

Lithuania

Slovakia

 

European Union

Netherlands

South Africa

 

Germany

OECD

Sweden

 

Greece

Poland

Switzerland

 

 

To contact the International Tax Group in Russia and the CIS go to the Contacts section.

 

Tax area concerned

Relevant date/case reference

Description of measures and publication link
(Considerations in italic where necessary)

Bulgaria

Treaties

IGA - FATCA

23 April 2014

Representatives of the governments of Bulgaria and the United States in late April 2014 reached an intergovernmental agreement (IGA) “in substance” under the FATCA regime, with Bulgaria consenting to being included as a jurisdiction under the Model 1 IGA list as of 23 April 2014.
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Czech Republic

Tax legislation adopted and regulatory update

Reporting requirement for cash pooling transactions

May 2014

Certain cash pooling transactions are subject to a reporting requirement of the Czech National Bank (CNB). If these transactions are not reported to the CNB, relatively severe penalties may be imposed.
Read more

Proposed legislation

VAT

2015

The Ministry of Finance issued a statement to clarify that a new “reduced” VAT rate of 10 percent for certain types of goods, was a draft and not yet approved.
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European Union

Tax legislation adopted and regulatory update

Custom duties

17 June 2014

The European Commission released a notice to economic operators of a suspension of the autonomous common customs tariff duties on certain industrial and agricultural products.
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Proposed legislation

Digital economy

28 May 2014

The European Commission received a final report from an independent group that was assigned the task of examining key issues related to the taxation of the digital economy in the EU, and to present ideas as to how best to approach the various challenges and opportunities.
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FTT

2016

The Council of the EU on 6 May 2014 addressed a proposal for a directive on a financial transaction tax in 11 EU Member States, as proposed by the EU Commission in February 2014. Although the details of the proposal are still under discussion, it appears that participating EU Member States would like to implement a scaled-down version of the original proposal as from 2016.
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Parent-Subsidiary Directive

6 May 2014

The Council of the EU had intended to adopt part of the European Commission’s proposed amendments to the EU Parent-Subsidiary Directive—i.e., the proposals to address the use of hybrid loans.
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Germany

Proposed legislation

Corporate income tax

April 2014

Draft guidance issued in April 2014 by Germany’s Federal Ministry of Finance would replace prior guidance concerning the corporate tax loss limitation rules.
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Administrative and case law

VAT

May 2014

Germany’s federal tax court addressed the effects of the opening of insolvency proceedings against an existing VAT group.
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Greece

Tax legislation adopted and regulatory update

Capital gains taxation

29 February 2012-31 December 2013

A new policy in Greece that would have amended the rules on the taxation of capital gains realized by non-residents—including hedge funds and institutional investors—on the disposition of government and corporate bonds for the period, 29 February 2012 to 31 December 2013, has been withdrawn.
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Italy

Tax legislation adopted and regulatory update

Investment income tax, IRAP

May 2014

Amendments to the tax rates on investment income and the IRAP (Imposta regionale sulle attività produttive—or Italy’s regional tax on productive activities), as made by Law Decree no. 66 2014 (published in the official gazette no. 95) increase the tax rate on certain investment income and reduce the IRAP rate.
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Lithuania

Tax legislation adopted and regulatory update

Capital gains taxation

May 2014

The “commentaries” regarding when capital gains from the transfer shares are treated as non-taxable income have been amended, to reflect that the holding period of share ownership is not taken into consideration when the shares are transferred due to certain required legal acts.
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Netherlands

Administrative and case law

VAT

May 2014

The district court in The Hague issued a judgment concerning VAT on the re-charged fees related to a bank’s use of an external advisor in connection with providing loans to a partnership (one of the bank’s customers).
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Crisis levy

2013

A district court in The Hague issued judgments in six test cases concerning the Dutch “crisis levy.”
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Foreign employees tax relief

May 2013

The European Commission presented its position in a case pending before the Court of Justice of the European Union (CJEU) concerning the 150-kilometer limit for purposes of the “30 percent tax relief” in the Netherlands—i.e., foreign employees with specific expertise, that is deemed to be scarce in the Dutch labor market, are eligible for a 30 percent tax relief benefit.
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OECD

Proposed legislation

Transfer pricing and country-by-country reporting

19 May 2014

The OECD on 19 May 2014 conducted a public consultation to allow for further consideration of and address comments concerning transfer pricing documentation and country-by-country reporting—pursuant to a discussion draft under the BEPS Action 13.
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Poland

Tax legislation adopted and regulatory update

Interest on refund claims

30 days after May 2014 or early June 2014

Polish tax law provides specific rules for determining the rate of interest on refunds if the tax overpayment relates to a judgment of the CJEU.
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Romania

Tax legislation adopted and regulatory update

VAT

February 2014/1 April 2014

Several VAT provisions were revised in Romania.
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Slovakia

Tax legislation adopted and regulatory update

VAT

1 October 2014/1 January 2015

Changes to the VAT law in Slovakia, as proposed by the Ministry of Finance in March 2013 and submitted for consideration by the Slovak government’s advisory bodies affect a number of provisions.
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South Africa

KPMG publications

Headquarter company regime

May 2014

South Africa’s headquarter company regime is intended to promote South Africa as a location in which to establish a regional holding company.
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Sweden

Administrative and case law

VAT

Skandia America Corp. v. Skatteverket, C-7/13 (8 May 2014)

The Advocate General of the CJEU issued an opinion concluding that transactions between a foreign head office and a “fixed establishment”—e.g., permanent establishment or PE—that is part of a VAT group are outside the scope of the VAT rules.
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Switzerland

Administrative and case law

Income tax equality for EU persons moving cantons

May 2014

The Swiss Federal Supreme Court held that current tax rules applying to non-Swiss citizens moving from one canton with “higher” tax rates to another canton with “lower” tax rates is in direct violation of the non-discriminatory role of the free movement of persons under EU law.
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United Kingdom

Tax legislation adopted and regulatory update

Various tax areas

May 2014

KPMG in the UK prepared a report that includes discussions of the following topics:

OECD BEPS update webcast 26 May 2014

EU audit reforms and the impact on tax services

Felixstowe Dock consortium relief case

Consultations on employee benefits-in-kind and expenses

Employment allowance update

Economic benefits of foreign income exclusion for U.S. citizens working abroad

Improvements to HMRC’s Business Tax Dashboard

Read more

HM Revenue & Customs manuals provide guidance concerning the following tax topics:

Partnership Manual

Specialist Investigations Operational Guidance Manual

Technical Teams Operation Guidance Manual

Television Production Manual

Animation Production Company Manual

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Disclosure of offshore undeclared income

May 2014

HM Revenue & Customs has begun sending letters to some 2,000 individual taxpayers with overseas bank accounts urging them to come forward if they have any undeclared income.
Read more

Proposed legislation

Venture capital “schemes”

2014

HM Treasury published on 19 May 2014 an information note intended to clarify the scope of a proposed "Report stage" amendment to Finance Bill 2014 that would restrict companies that benefit from particular renewable subsidies using the tax-advantages venture capital "schemes."
Read more

Country-by-country reporting

May 2014

HM Revenue & Customs and HM Treasury met with a cross section of global companies to discuss the proposed revised draft of the OECD country-by-country reporting template.
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 For a full summary of global tax developments, visit kpmg.com/TaxNewsFlash.

 

Contacts

Anna Voronkova
Partner,
Head of International Tax
+7 (495) 937 44 24


Evgenia Wolfus
Partner,
International Tax
+7 (495) 937 44 19


Alexander Tokarev
Senior Manager,
International Tax
+7 (495) 937 44 77


Olga Ermolaeva
Senior Manager,
International Tax
+7 (495) 937 44 77


Elena Dolgova
Manager,
International Tax
+7 (495) 937 44 77