Portugal, Sao Tome and Principe DTA enters into force
On 8 September 2017, Portugal published a notice declaring the entry into force of the Double Taxation Agreement (DTA) with Sao Tome and Principe on 12 July 2017 and it will apply from 1 January 2018. The agreement contains Dividends rate 10% for at
See MoreIreland publishes a report on review of Corporation Tax Code
On 12 September 2017, the Minister for Finance and Public Expenditure & Reform, Mr. Paschal Donohoe T.D., has published the Review of Ireland’s Corporation Tax Code, undertaken by Mr. Seamus Coffey. Mr. Coffey was appointed as an independent
See MoreUK: HMRC publishes guidance for the corporate offences
HMRC has published guidance on the new corporate criminal offence of failing to prevent the facilitation of tax evasion and the final version has now been published and given statutory effect. The Government believes that relevant bodies should be
See MoreCzech Republic: DTA with Turkmenistan ratifies
On 8 August 2017, the Czech Republic has ratified the Double Taxation Agreement (DTA) with Turkmenistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
See MoreNetherlands: The Dutch government publishes consultation on anti-tax avoidance directive
The State Secretary of Finance provided a letter to Dutch parliament in which he indicated that an internet consultation has been opened for a draft bill on 10th July 2017. The draft bill has been formulating in order to implement the first EU
See MoreGermany releases guidance on CbC reporting requirements
The Germany Federal Ministry of Finance on 11 July 2017 issued guidance on the Country-by-Country (CbC) reporting requirements in line with BEPS Action 13 and the EU Administrative Assistance Directive as amended. The guidance clarifies the
See MoreCanada agrees to start FTA with EU
The Prime Minister, Justin Trudeau, announces that Canada agreed to commence operation of the Free Trade Agreement with the European Union (EU) on September 21, 2017. The commencement of the Comprehensive Economic and Trade Agreement (CETA) had been
See MoreEU and Japan reach agreement in principle on trade deal
An agreement in principle has been reached on a free trade deal between the European Union (EU) and Japan. The deal includes sizable tariff cuts, co-operation on standards and regulations and opening up of public procurement markets. The EU and
See MoreSweden: Proposal for major corporation tax reforms
The Swedish Government on 20 June 2017 issued a statement proposing important changes in the area of corporate taxation. The main proposals are summarised below: According to the announcement the deductibility of the net interest expense would
See MoreHungary: Parliament approved Budget Bill for 2017/18
The Hungarian Minister of Economy presented the Budget Bill to the Parliament on 2 May 2017 which was approved on 13 June 2017 with 127 votes in favour and 62 votes against. The Budget targets a GDP growth of 4.3 percent, with 4.1 percent projected
See MoreIreland: Revenue assessment in the absence of a return
On 19 June 2017, the Irish Revenue published the Tax and Duty Manual Part 41A-05-02 that has been amended in paragraph 1 in relation to the pursuit of outstanding returns and in paragraph 4 in relation to appeal provisions. According to this
See MoreItaly: Multilateral Convention on BEPS signed
Italy has signed the multilateral instrument on 7 June 2017, aiming to facilitate the implementation of tax related measures to Prevent Base Erosion and Profit Shifting (MLI). At the signing ceremony, Italy introduced its 84 tax treaties with other
See MoreIreland amends Capital Acquisitions Tax manual
On 12 June 2017 the Irish Revenue published the amended Capital Acquisitions Tax manual dealing with business relief. This involves changes to Part 12 to incorporate material from Tax Briefing No. 33 (September 1998) in relation to the treatment of
See MoreIreland: Interaction of PAYE and Self Assessment Procedures
On 12 June 2017 the Irish Revenue published the amended Part 42-04-13 of the Income Tax, Capital Gains Tax and Corporation Tax Manual. The amendments reflect the changes to the income thresholds which are applied in determining whether an
See MoreIreland: Charges on income for corporation tax purposes
On 12 June 2017, the Irish Revenue published updates to the Tax and Duty Manual Part 08-02-01 dealing with charges on income for Corporation Tax purposes. The principal updates are in relation to interest as a charge on income under section 247
See MoreFrance: Implementation of withholding tax postponed for one year
The newly elected Prime Minister of France delayed the implementation of withholding tax further by one year, which means this will now enter into force on 1 January 2019. However, the decision will be confirmed by formal vote of the French
See MoreNetherlands signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
The Netherlands signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("Multilateral Instrument" or "MLI") on 7th June 2017. About 70 Ministers and other high-level representatives
See MoreIreland: New Tax-Geared Penalties for Non-Submission of Returns
On 12 June 2017, Irish Revenue published the manual Tax-Geared Penalties for Non-Submission of Returns, that provides guidance as to the application of tax-geared penalties under section 1077E TCA 1997 in circumstances where the taxpayer has
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