International Tax Round-up - April 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 guidance on tax treaties and the impact of the Covid-19 crisis
Belgium
  • Covid-19 – Tax measures
France
  • Covid-19 – Freezing of dividend distributions
  • France-Belgium double tax treaty – Real Estate
Germany
  • Covid-19 – Further tax measures
  • ATAD Implementation Act
  • Contract act for the ratification of the Multilateral Instrument (MLI)
Italy
  • Covid-19 – Italian Law Decree “Liquidità”
  • Supreme Court clarifies the scope of the “subject-to-tax” requirement for the purposes of the EU Parent-Subsidiary Directive
Netherlands
  • Advisory Committee publishes Report on Taxation of Multinationals
Portugal
  • Covid-19 – New legislation
  • The Portuguese State Budget Law for 2020
Spain
  • Covid-19 – Tax measures taken and practical aspects
Sweden
  • Legislative changes – et al. Proposed new act on withholding tax; Economic budget propositions for 2020
  • Supreme Administrative Court – Interest deduction in a community of interest
  • The Swedish Tax Agency – et al. Costs for negative interest on bank balances do not constitute an interest expense
United Kingdom
  • Covid-19 – HMRC guidance on residence and permanent establishment issues
  • Questions of input VAT recovery for supplies wrongly thought to be exempt referred to CJEU

    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.