International Tax Round-up - May 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 Model Tax Convention 2017: full version released
France
  • Management Package and Social Security Changes - Groupe Lucien Barrière case
Germany
  • The German Annual Tax Act 2019
Luxembourg
  • Multilateral Convention – Multilateral Instrument
  • Bill no. 7431 transposing into national law Council Directive (EU) 2017/1852 dated 10 October 2017 on tax dispute resolution mechanisms in the European Union
  • Luxembourg Budget Law 2019 voted
Netherlands
  • New Decree on international tax rulings
Portugal
  • ATAD - Transposition into Portuguese Law
Portugal-Sweden
  • Amendments to the tax treaty between Sweden and Portugal
Sweden
  • Proposal on the implementation of the tax dispute resolution mechanisms in the EU
  • Reduced VAT on e-publications
  • Ruling from the Swedish Supreme Administrative Court on depreciation deductions after a merger
  • Ruling on interest deduction
United Kingdom
  • Exemption from UK CFC rules found to be State Aid in part
  • CJEU reference in United Biscuits litigation concerning whether pension fund management services are insurance transactions