International Tax Round-up - June 2019

This publication gives an overview of key international tax developments across the Linklaters network. 

Topics include: 

International Developments
  • Digital Taxation – Interim Report
EU Developments
  • CJEU finds Dutch court not allowed to grant refund on the basis of free movement of capital where refund would constitute state aid
  • CJEU considers scope of “final losses” available for cross-border group relief
  • EU list of non-cooperative jurisdictions for tax purposes updated
Germany
  • Carry Taxation in Germany
  • Government drafts for a German land tax reform
Netherlands
  • Consultation on new corporate income tax group arrangement commenced
  • Changes to Dutch anti-abuse provisions following Danish beneficial ownership cases
Portugal
  • DAC 6 – Bill of Law released for public discussion
Sweden
  • Liability for VAT when hiring out medical personnel
  • Ruling on withholding tax and yield tax
  • Request for preliminary ruling from the CJEU
  • Decision regarding deductibility of VAT relating to an IPO and a new share issue
  • Ruling on immediate deductibility of costs relating to a real estate upgrade
United Kingdom
  • Upper Tribunal overturns First-tier Tribunal decision in Development Securities case concerning corporate residence
  • Amendments to rules taxing offshore receipts in respect of intangible property
  • Tribunal refuses to order disclosure of documents relating to “mutual agreement procedure” under treaty
United States
  • Treasury and IRS release proposed regulations on the withholding of gains derived from the transfer of certain partnership interests
  • Proposed “Qualified Foreign Pension Fund” Regulations released
For further information please get in touch with your usual Linklaters tax contact.

Please click here to read the publication.