Germany implements legislation that restricts the tax deductibility of related-party royalty payments
The Federal Parliament and the Federal Council on 12 May 2017 and 2 June 2017 have agreed on the implementation of legislation which restricts the tax deductibility of the contributory payments under certain conditions. This royalty limitation rule
See MoreIreland: DTA negotiation with Kosovo
The first round of negotiation of Double Taxation Agreement (DTA) between Ireland and Kosovo are underway for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
See MoreAndorra approves DTA with Malta
On 25 May 2017, the general council of Andorra approved the Double Taxation Agreement (DTA) with Malta for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
See MoreGreece: Reform Law 4472/2017 published
The Government published Law 4472 on 19th of May 2017 in the Official Gazette. It includes several reform measures concerning the medium-term fiscal targets for 2018-2021 and tax cuts for legal entities. Therefore, the corporate income tax (CIT)
See MoreGermany: Government approves signing of MLI to implement tax treaty related BEPS measures
The German Federal Parliament on 21 December 2016, approved the signing of the Multilateral Instrument (MLI) to implement into bilateral tax treaties the tax treaty-related measures arising from the OECD / G20 BEPS Project to tackle base erosion and
See MorePoland publishes draft amendment to R&D tax relief
The Ministry of Science and Higher Education has published an amended draft bill regarding the R&D tax relief. The bill proposes an increase of current income tax deduction from 50% and 30% to 100% depends on the category of eligible costs and
See MoreFrance: CJEU rules on 3% contribution on distributed profits
In France, companies subject to Corporate Income Tax (CIT) are required to pay an additional CIT contribution of 3% on the distributed profits according to article 235 ter ZCA of the French general tax law. But, the Court of Justice of the European
See MoreNetherlands: Amendments to dividend withholding tax rule
On May 16, 2017, the Dutch government released a public consultation for the previously announced legislative proposals regarding changes to the DWT (dividend withholding tax) rules for holding cooperatives. The Dutch government expected to have the
See MoreHungary: Advertisement tax rate increased
The Hungarian Parliament has approved an increase in the advertisement tax rate from 5.3 percent to 7.5 percent while overcoming the European Commission's illegal state aid objections and still shielding smaller media companies from the
See MoreHungary: CbC reporting requirements adopted
Hungary released a draft law on country-by-country (CbC) reporting on 10 March 2017 which became effective 15 May 2017. As a result, Hungary fulfilled the harmonisation requirement set by Council Directive (EU) 2016/88) and implemented the
See MoreSlovenia: Proposal for more specific requirements for CbC reporting
The Slovenian Ministry of Finance on 19 April 2017 issued a proposal to amend the rules for the application of the Tax Procedures Act. The proposal provides more specific requirements for CbC reporting. In addition the proposal would introduce CbC
See MoreUAE: DTA with Slovakia applies from January 1, 2018
The Double Tax Agreement (DTA) between United Arab Emirates and Slovak Republic was signed in 2015 and was come into force on 1st of April 2017. This treaty will be applicable from 1st of January
See MoreBelgium: New CbC reporting forms and guidelines
On 19 May 2017, the Belgian Federal Public Service for Finance issued new country-by-country (CbC), local file and master file forms along with guidelines to file CbC reports under BEPS Action 13. The report submission deadline was 31 December 2016,
See MoreFrance: New tax plans by the newly elected president
French newly elected president has committed to reduce the corporate tax rate from current rate of 33.3% to 25% with the aim to bring it in line with the EU average within five years. The tax credit on research, innovation and the start-up status
See MoreBulgaria: Government approves signing of MLI to implement tax treaty related BEPS measures
The Government on 17 May 2017, approved the signing by Bulgaria of the Multilateral Instrument (MLI) to implement into bilateral tax treaties the tax treaty-related measures arising from the OECD / G20 BEPS Project to tackle base erosion and
See MoreCzech Republic: New withholding tax provisions
The Czech President signed some amendments to the Income Tax Act, which include the withholding tax (WHT) provisions. The amendments will be effective on the 15th day of its publication. There is an indication of its publication date and it is 1st
See MoreUK: Draft legislation – Corporate Interest Restriction
The Corporate Interest Restriction (CIR) legislation was included in Schedule 10 of Finance Bill 2017 but has now been removed. There has been no policy change and the government has announced it will legislate for the provisions at the earliest
See MoreCzech Republic: Government approves signing of MLI to implement tax treaty related BEPS measures
The Czech Government recently approved the signing of the Multilateral Convention to implement into bilateral tax treaties the tax treaty-related measures arising from the OECD / G20 BEPS Project to tackle Base Erosion and Profit Shifting (BEPS). A
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