International Tax Round-up - September 2018

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

Topics include:

  • Crown Dependencies publish consultations on substance requirements
  • Further OECD guidance on CBCR published
  • Two more jurisdictions deposit BEPS MLI instruments of ratification
  • CJEU holds irrecoverable late payment interest charged on withholding tax pending treaty relief is contrary to EU law
  • CJEU confirms dental payment plan services are not VAT exempt
  • Belgian salary withholding tax and reporting obligations in case of a grant of stock options/shares by foreign affiliated companies to employees of
  • Belgian companies
  • Entry into force of new interest deduction limitation rule in Belgium as of income year 2019 (instead of income year 2020 as previously announced)
  • The German Annual Tax Act 2018: Act preventing loss of VAT revenue on trade in goods on the internet and amending further tax provisions
  • Draft circular from the German Federal Ministry of Finance on the CJEU judgment in the Skandia America case
  • Netherlands Tax Plan 2019 legislative proposals
  • Angola and Portugal sign Tax Treaty
  • Central Registry of Beneficial Ownership regime in Portugal
  • CJEU decision: Patrício Teixeira (Case C-184/18) concerning capital gains on immovable property and third country residents
  • CJEU decision (VAT): TGE Gas Engineering (Case C-16/17) concerning the right to deduct, cost recharges and branches
  • What legislative changes to expect following Swedish election deadlock
  • Decision on interest on reimbursed withholding tax from the Swedish Supreme Administrative Court
  • Decision on German transfer pricing rules by the CJEU and the applicability to Swedish law
  • New reporting requirements for employers in Sweden
  • UK tax authority publishes guidance on VAT in the event of no Brexit deal
  • European Commission notice on VAT post-Brexit
  • Taxation (Cross-border Trade) Act 2018 receives Royal Assent in UK
  • UK Supreme Court finds requirement to pay disputed VAT prior to appeal is EU law compliant