International Tax Round-up - September 2020

This publication gives an overview of key international tax developments across the Linklaters network. Please click here to read the publication.
 
Topics include:

France
  • 2021 Finance Bill – draft
Germany 
  • Annual Tax Act 2020 – draft
Italy 
  • Contribution of business followed by disposal of shares – new case-law and tax ruling
  • New Italian tax ruling on corporate hybrid securities accounted as equity instruments
Netherlands
  • Dutch tax plan package 2021
Sweden
  • Legislative changes – Budget Bill for 2021; Proposal regarding interest payments to non-cooperative jurisdictions
  • Supreme Administrative Court – i.e. Deductibility of interest regarding parts of a subordinated debt; Tax exemption for employee stock options
  • Council for Advance Tax Rulings – A company owned by more than half by a trust is not considered a close company
United Kingdom
  • Autumn Budget 2020 cancelled
  • Covid-19 – Winter economy plan
  • Court of Appeal finds UK rules on attribution of notional capital to permanent establishment not precluded by double tax treaty

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.