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