Italy: Changes in international ruling procedure
Italy has modified its international tax ruling procedure, through Art. 7 of Law Decree No. 145/2013. Under this, non-resident entities operating in Italy may obtain an advance ruling on whether their activities in Italy give rise to a PE under
See MoreFrance- Transfer Pricing Rules
Draft legislation introducing a presumption that profits are received if functions and risks are transferred to a foreign related party, unless arm's length remuneration is paid, has been struck down by the Supreme Court and will not be implemented
See MoreSlovenia-Uzbekistan:DTA enters into force
The new Double Tax Agreement (DTA) between Slovenia and Uzbekistan entered into force on 8 November 2013, following publication in the Official Gazette of the Republic of Slovenia on 13 January 2014. The new Treaty will apply to all income
See MorePolish 2014 VAT Law brings in widespread changes
On 13 January 2014 it has been reported that there has been a major overhaul of the Polish VAT compliance regime following the approval of the 2014 Polish VAT Act. The changes are aimed at bringing the Polish Value Added Tax regime more into
See MoreLuxembourg: Government announces key fiscal policy agenda
The new Luxembourg government published components of its future fiscal policy on 2 December 2013. The government will focus on structural reforms in three major areas: an examination of public expenditure, measures to promote economic growth, and
See MoreAustria: Special taxes increased
Austria published draft legislation to increase the tax rate for the special bank levy to 0.09% for assets above EUR 1 billion and 0.11% for those above EUR 20 billion. The draft, which has yet to be agreed upon in parliament, also includes other
See MoreEU: Uniform Customs Code effective from 1 May 2016
The European Commission has notified that the substantive provisions of the Uniform Customs Code have entered into force 30 October 2013, and will be effective from 1 May 2016. Until then, the Community Customs Code and its implementing provisions
See MoreEU: Royalties, license fees dutiable from 1 May 2016
The European Commission has pointed out that the process for determining the transaction value would be amended under the Uniform Customs Code (UCC), due to enter into force on 1 May 2016, resulting in royalties being more often included in the
See MoreEU – Forms for customs enforcement of IP rights
The European Commission has issued new forms which should be used from 1 January 2014 in order to ensure customs enforcement of intellectual property rights. The new implementing regulation that introduces such standard forms, and rules for
See MoreEU: Certain reduced duty rates ending in 2015
The European Commission has notified that EU imports of goods originating from China, Ecuador, the Maldives, and Thailand will no longer benefit from a zero or reduced EU customs duty rate from 1 January 2015. These countries have been determined to
See MoreUnited Kingdom: Dispute resolution, CFC financing, investment “white list”
HM Revenue & Customs have updated some key documents regarding resolution of tax disputes, and have provided new guidance on CFCs. The dispute resolution documents are the Code of Governance for resolving tax disputes; and Commentary on the
See MoreItaly: Financial Transaction Tax (FTT) annual return model published
The Italian tax administration has issued the final Financial Transaction Tax (FTT) annual return model and the related instructions under Protocol No. 2013/154577. The FTT return should be filed by 31 March of every year, subject to a de minimis
See MoreBelgium: New tax rules on notional interest, small companies and withholding tax
The Official Gazette issue of 31 December 2013 notifies some new tax rules. The first measure aligns the rules relating to notional interest deductions (NID) with the judgment of the European Court of Justice in the Argenta Spaarbank case. The NID
See MoreAustria: “Provisional” Budget submitted
The Austrian Government has submitted a provisional budget for 2014 to the Austrian National Council; the proposals broadly follow the coalition accord. Tax rises are proposed in the motor vehicle insurance tax and on alcohol and tobacco, and for
See MoreFinland: decree on blacklist countries updated
The Ministry of Finance of Finland published Decree No. 1284/2013 on 31 December 2013. This covers countries where the tax burden differs significantly from that in Finland; the blacklist applies in implementation of the controlled foreign company
See MoreFinland-Panama: TIEA enters into force
The Finland – Panama Exchange of Tax Information Agreement (2012) entered into force on 20 December 2013 and applies from that
See MoreBulgaria: Companies located in “preferential” jurisdictions banned from certain transactions
Bulgaria has enacted a new law, effective from 1 January 2014 which prevents companies located in “preferential tax regime jurisdictions” (and persons related to such companies) from receiving public funds, participating in privatizations in
See MoreNetherlands: Relief, clarifications under FATCA
The Netherlands government has announced completion of a memorandum of understanding (MOU) to provide relief and clarify the intergovernmental agreement (IGA) for automatic exchange of data between the Netherlands Belastingdienst and the US IRS. The
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