International Tax Round-up - August 2020

This publication gives an overview of key international tax developments across the Linklaters network. Please click here to read the publication.
 
Topics include:

International Developments 
  • OECD model rules for platform operators in the sharing and gig economy
EU Developments 
  • Tax Package – EU Commission proposes three initiatives to simplify and modernise taxation and to fight abusive tax arrangements
  • European Commission proposes changes to EU VAT rules for Northern Ireland
Germany 
  • DAC 6 – publication of updated draft administrative circular
Italy 
  • LBO financing – new clarifications by the Italian Supreme Court on the notion of “beneficial owner” for purposes of the Interest and Royalties Directive
Luxembourg 
  • Covid-19 – Luxembourg tax authorities provide additional details on tax measures
  • Covid-19 – Belgium and France cross-border personal tax measures
  • Law implementing the deferral of DAC6, FATCA, and CRS reporting obligations
  • Update of DAC6 implementation details
Netherlands 
  • Dutch dividend withholding “exit tax” proposed by Dutch opposition party
Sweden 
  • Legislative changes – i.a. Amendments to the rules on deduction of negative net interest and the rules on group level restriction of losses carried forward
  • Supreme Administrative Court – Dental services provided through sub-contractor not exempt from VAT
  • Council for Advance Tax Rulings – i.a. Taxation of board remuneration; Real estate property considered an inventory asset
  • Swedish Tax Agency – Swedish participation exemption regime and non-resident legal persons
United Kingdom 
  • Draft clauses for Finance Bill 2020-2021
  • Finance Act 2020 – Royal Assent
  • HMRC announces delay to reporting deadlines under DAC6 in the UK

Should there be questions or in case you are interested to further discuss any of the developments, please do not hesitate to contact your local Linklaters tax team.