International Tax Round-up - October 2019

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

International Developments
  • OECD on taxation of the digital economy
EU Developments
  • Update to EU blacklist
  • Advocate General opines cross-border loss relief not available following transfer of place of management
Germany
  • Disclosure rules for cross-border tax planning arrangements
  • Modernisation of corporate taxation in Germany
Italy
  • New clarifications by the Italian tax authorities on the notion of “beneficial owner”
Luxembourg
  • Old Luxembourg tax rulings no longer binding from tax year 2020
Portugal
  • Non-habitual resident tax regime – high added-value activities recognition procedure simplified
  • Portugal-Angola Treaty enters into force
  • Law implementing Directive on tax dispute resolution mechanisms
  • Deductibility of Additional Tier 1 and Tier 2 instruments
Sweden
  • Legislative changes
  • Supreme Administrative Court
  • The Swedish Tax Agency
United Kingdom
  • Offshore receipts from intangible property: consultation outcome and revised draft regulations
  • VAT grouping criteria extended from 1 November 2019

For further information please get in touch with your usual Linklaters tax contact.