International Tax Round-up - March 2019

This publication gives an overview of key international tax developments across the Linklaters network. Click here to read more.

Topics include:

International Developments
  • Digital Taxation
EU Developments
  • CJEU considers “beneficial owner” and “abuse of rights” concepts in EU Directives
  • Revised EU blacklist of non-cooperative jurisdictions
Germany
  • Compatibility of the CFC rules with the free movement of capital
  • Brexit Accompanying Tax Act
Netherlands
  • Introduction of a thin-capitalisation rule for banks and insurers
Portugal
  • Multilateral Instrument to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) approved by Portuguese Council of Ministers
  • European Parliament approved the TAX3’s Report which made a reference to the investigation that the European Commission has been conducting on the effective compliance of the Madeira Free Zone tax regime conditions
Sweden
  • Three Proposals to reintroduce the tax reduction for gifts; to decrease the VAT rate for electronic publications; to introduce new tax rules for transfer of ownership in close companies
  • Several rulings from the Swedish Supreme Administrative Court on the deductibility of interest expenses between affiliated companies
  • Advanced ruling regarding energy tax on solar cells on attached buildings
United Kingdom
  • Withholding tax in the event of a no-deal Brexit
  • Brexit: Input VAT recovery available for financial services exported within the EU
  • Spring Statement 2019 has limited tax content
  • Supreme Court confirms that payment of statutory interest in an administration can be “yearly interest” for withholding tax purposes