On 27 January 2021, the Government submitted a draft bill L 150, which proposes to introduce two defensive measures against the countries on the EU list of non-cooperating tax jurisdictions. According to the proposal, the Law will enter into force on 1 July 2021.
Firstly, there must be a denial of deduction for certain payments, so that individuals and companies etc. must not be able to deduct payments to related recipients in countries on the blacklist, just as such payments must not be included in any other way in the calculation of the taxpayer income.
Secondly, there must be a tightening of dividend taxation, so that persons and companies domiciled in countries on the blacklist and who receive dividends from main shareholder shares, subsidiary shares or group company shares, must in principle pay a final gross tax of 44 per cent. of such dividends paid by deduction.
The bill implements the Council of the European Union’s decision of December 2019 that all Member States, with effect from 2021, must introduce at least one of four possible measures on defensive measures in national law against countries on the EU blacklist.
