International Tax Round-up - January 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 releases further guidance on CbC reporting alongside jurisdiction-by-jurisdiction summary of requirements
  • Year in Review, Year to Come
EU Developments
  • Discussions on digital taxation
  • Revised draft of a financial transaction tax (FTT)
Belgium
  • Amendments to the 30% EBITDA interest limitation rule
  • Entry into force of Belgian law implementing DAC 6
France
  • Transposition of ATAD 2
  • Reduction of CIT rates
  • Tax residency of management executives of French companies
  • New French-Luxembourg tax treaty
  • Entry into force of DAC 6 – mandatory disclosure
Germany
  • Draft bill for the implementation of ATAD
  • Double taxation treaty Germany – the Netherlands
  • Entry into force of DAC 6 – mandatory disclosure
Luxembourg
  • Entry into force of the ATAD 2 anti-hybrid mismatch provisions
Netherlands
  • Dutch corporate income and dividend withholding tax – substance requirements no longer a safe harbour
  • Entry into force of ATAD 2
  • Multilateral Instrument (MLI)
  • Entry into force of DAC 6 – mandatory disclosure
  • Conditional withholding tax on interest and royalties
Sweden
  • Legislative changes: e.g. Implementation of DAC 6; Protocol to Nordic Convention in force
  • Supreme Administrative Court: Taxation of board fee; Disposal of qualified shares
  • The Council of Advance Tax Rulings: Limitations of the deductions for interest; Share-for-share exchanges
United Kingdom
  • UK Budget scheduled for 11 March 2020
  • DAC 6 – implementing regulations made in the UK
  • UK tax authority publishes guidance on location of cryptoassets

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.