Issue

Date

Subject

2004-40

December 27, 2004

• France: Legislative Proposal Would Provide a Tax Exemption for Capital Gains on Dispositions of Qualifying Shareholdings
• Germany: Overview of Tax Law Changes 2004/2005
• Poland: Corporate Tax Changes for 2005
• Romania: Corporate Tax Amendments Taking Effect in 2005

2004-39

December 20, 2004

• Denmark: Details of Legislation to Reduce the Corporate Income Tax Rate, and Amend the Danish Joint Taxation Rules<
• France: Opportunities for French Subsidiaries of U.S. Multinational Companies Under Dividends-Received Deduction Provision of Recent U.S. Legislation
• Spain: ECJ Holds Spanish Income Tax Measure Was Not Compatible With Principles Under the EC Treaty
• United Kingdom: Deadline Approaches for Making Amortization Election Relating to Intangibles

2004-38

December 9, 2004

• Croatia: Increase in Nontaxable Amounts Payable to Employees
• Czech Republic: New Securities Classification Rules for Banks and Financial Institutions; Other Developments
• France: Protocols to the Income Tax and the Estate, Inheritance, and Gift Tax Treaties With the United States
• Ireland: VAT Update
• Romania: New Tax Measures for Small and Medium Enterprises

2004-37

December 6, 2004

• Poland: New Tax Treaty with Germany
• United Kingdom: 2004 Pre-Budget Report

2004-36

December 2, 2004

• Denmark: Proposals to Reduce the Corporate Income Tax Rate, and to Amend the Danish Joint Taxation Rules
• Ireland: Budget 2005 and Current Tax Developments
• Luxembourg: Court of Appeal Addresses Calculation of "Fictitious" Foreign Tax Credits
• Norway: Compatibility of Norwegian Withholding Tax on Dividends Paid to Shareholders Resident in the EU/EEA With the Free Movement of Capital

Issue

Date

Subject

2004-35

November 15, 2004

• The Netherlands: Effect of ECJ Case Law on Free Movement Capital
• Romania: Tax Changes Included in Recent Proposed Amendments to the Fiscal Code

2004-34

November 10, 2004

• Czech Republic: Update on Legislation to Amend the Income Tax Act, and Other Pending Legislation
• Poland: Status of European Company Legislation

2004-33

November 4, 2004

• United Kingdom: Pre-Budget Report

Issue

Date

Subject

2004-32

October 22, 2004

• Bulgaria: Recent Tax Rulings
• Germany: Autumn 2004 Edition of German News
• Ireland: Autumn 2004 Taxing Times
• Luxembourg: Capital Duty Rate on Equity Contributions to a SICAR
• Poland: Overview of Investment Incentives
• United Kingdom: Exemption from Withholding Tax for Interest Payments Between EU Companies

Issue

Date

Subject

2004-31

September 30, 2004

• Ireland: New Holding Company Regime

2004-30

September 22, 2004

• Germany: New Rules Relating to Remittances of Withholding Tax on Dividends Take Effect Beginning in 2005
• Luxembourg: Administrative Court Holds Circular Letters Provide No Legal Basis for Rejecting Taxpayer’s Deduction of Loan Interest
• The Netherlands-United States: JCT Explanation of Protocol Is Released in Advance of U.S. Senate Committee Hearing
• The Netherlands: Proposed Reduction in Corporate Income Tax Rate to 30%
• OECD: Recommendations on Tax Treatment of Share Options
• Switzerland: Update on Recent Developments
• United Kingdom: VAT on the Sale of a Partnership Property Interest

2004-29

September 16, 2004

• France: Possible Changes to the Thin Capitalization, CFC Rules
• France: New Accounting Rules for Mergers and Related Transactions; Restructuring Decisions to Be Taken by September 2004
• Hungary: Tax Reforms Include Proposal to Eliminate Dividend Withholding Tax
• Luxembourg: Societas Europaea Legislation Is Introduced
• Poland: Thin Capitalization Rules

2004-28

September 10, 2004

• Austria-Poland: New Double Taxation Treaty
• Belgium: Minister of Finance Responds to ECJ Judgment Concerning Taxes on Stock Exchange Transactions and on Delivery of Bearer Securities
• Czech Republic: Application of the Double Taxation Treaty between the Czech Republic and Germany in relation to a GmbH&Co. KG
• European Union: Overview of Societas Europaea (SE)
• Poland: New Binding Ruling Regime in Poland
• Poland: Proposed Income Tax Changes

Issue

Date

Subject

2004-27

August 24, 2004

• OECD: Changes to OECD Model Rules on Exchange of Information Between Tax Authorities
• United Kingdom: Residence of Offshore Companies

Issue

Date

Subject

2004-26

July 24, 2004

• Austria: Austrian Individual Income Tax on Revenue From Foreign Capital Found to Restrict Free Movement of Capital
• Belgium: ECJ Decides Belgian Taxes on Stock Exchange Transactions and on Delivery of Bearer Securities Are Prohibited Under EU Directive
• Belgium: ECJ Holds Belgian Tax on Capital Gains Realized on Transfer of Substantial Shareholding by Individual Taxpayer to Foreign Company Is Contrary to EC Treaty Principles
• European Union: Update on Developments in Recent Accession States
• Luxembourg: Special Tax Relief for Expenses on Acquisition of Shares Restricts Free Movement of Capital Under EC Treaty
• The Netherlands: Update on Legislative Proposals on Written-Down Loans and Write-Down of Participations

2004-25

July 15, 2004

• Czech Republic: Update on Proposed Changes to Income Tax Act
• Germany: Tax Authorities Release Final Version of Guidance Under New German Thin Capitalization Rules

Issue

Date

Subject

2004-24

June 30, 2004

• Netherlands: Protocol to Netherlands-United States Income Tax Treaty Is Approved by Parliament
• United Kingdom: Calculation of Interest on Remittances of Advance Corporation Tax

2004-23

June 23, 2004

• European Union: Report on the Takeover Directive
• European Union: European Court of Justice to Decide Whether CFC Rules Violate Freedoms Under EC Treaty
• Luxembourg: Webcast Discussion on SICAR
• Poland: Application Deadline for VAT Refunds for 2003 Is Fast Approaching
• United Kingdom: Progress Report on Finance Bill 2004
• United Kingdom: Revised Draft Inland Revenue Guidance on Expenses of Management

2004-22

June 16, 2004

• Finland: Reduced Corporate Income Tax Rate Included in Proposals for Tax Reform 2005
• Latvia: Corporate Income Tax Changes Allowing Exemption From Withholding Tax for Certain Dividend Payments
• The Netherlands: Overview of Recent Tax Developments
• United Kingdom: CFC Rules Referred to the European Court of Justice

2004-21

June 7, 2004

• Czech Republic: Proposed Changes to Income Tax Act
• European Union: Post-Accession Report Includes Updated Tax Rates in New Member States
• Ireland: Personal Tax Guide 2004
• Luxembourg: SICAR - A New Vehicle for Venture Capital Investments
• Poland: Treaty Update
• United Kingdom: Court of Appeal Issues Taxpayer-Favourable Decision for Claims Procedure in EU Loss Relief Group Litigation

2004-20

June 1, 2004

• France: Special Tax Regime for International Headquarters Conducting Research and Development in France
• Poland: Changes Affecting Imports and Exports
• Sweden: New CFC Legislation in Sweden
• United Kingdom: Protocol to the UK/Canada Double Tax Treaty

Issue

Date

Subject

2004-19

May 26, 2004

• Croatia-Serbia/Montenegro: New Double Tax Treaty
• Germany: Continuing Discussion of Initial Draft Guidance Under New German Thin Capitalization Rules
• Ireland: Commentary on the Finance Bill 2004
• United Kingdom: Tax-Related Penalties for Adjustments to Corporation Tax Returns
• VAT: Recent Decisions of the European Court of Justice

2004-18

May 18, 2004

• Denmark: EU Package on Corporate Taxation Is Adopted; New Rules on Thin Capitalization, Transparency, Joint Taxation, and Other Measures
• United Kingdom: Transfer Pricing and Finance Bill 2004 – Application of a Cost-Plus Method to Centrally Provided Services

2004-17

May 14, 2004

• Germany: Tax Authorities Release Draft of First Guidance Under New German Thin Capitalization Rules

2004-16

May 12, 2004

• Europe: KPMG Hosts "Beyond Our Borders" Seminars: In Cleveland, May 18^th; in Minneapolis, May 19^th and in Dallas, May 26^th
• Bulgaria: Recent Developments Include New Product Fees Payable by Producers and Importers of Packaged Goods, Changes in VAT Regulations
• Croatia-Belgium: New Tax Treaty
• Czech Republic: Miscellaneous Tax and Business Developments
• Germany: Deadline Approaches for Filing a 2003 VAT Refund Claim
• Poland: Interest and Royalties Directive Update and Other Developments

2004-15

May 1, 2004

• Czech Republic: New VAT Act Implements EU VAT Directives; Other Legislative Developments
• Luxembourg: New Securitisation Vehicle
• Norway: Government Report on Tax Reform
• Poland: New Value Added Tax Act Regulations for Financial Services
• United Kingdom: Update on Progress of Finance Bill 2004
• United Kingdom: Employee Share Incentive Proposals Introduced by Finance Bill 2004
• United Kingdom: Tax Treatment of Construction Industry Subcontractors – Employed vs. Self-Employed?

Issue

Date

Subject

2004-14

April 20, 2004

• European Union: Accession -- Expatriates and Personal Tax; Focus on Malta; Comparison of Direct Taxes in the Accession States
• Germany: Impact of Recent Tax Legislation on Business Taxpayers
• United Kingdom: Proposed Changes to Transfer Pricing Rules, Thin Capitalisation Rules
• United Kingdom: Relief for Expense of Managing Investments

2004-13

April 8, 2004

• Austria: Tax Reform 2005
• France: French Exit Tax Held to Be Incompatible With Freedom of Establishment Principle
• France: ECJ Holds French Treatment of Foreign-Source Interest Income Is Incompatible with EC Treaty

2004-12

April 8, 2004

• Belgium: Arm's Length Principle Proposal
• European Union: Accession and the Financial Services Industry
• Luxembourg: Recent Legislation Addresses Securitization Transactions; ECJ Addresses Free Movement of Capital
• Poland: Update on EU Accession
• United Kingdom: UK Tax Implications of International Accounting Standards

Issue

Date

Subject

2004-11

March 17, 2004

• United Kingdom: Summary of Tax Proposals in Budget 2004

2004-10

March 12, 2004

• Czech Republic: Recent Action on Legislative Amendments
• Denmark: Recent Guidance Concerning VAT Implications of Financial Sector Outsourcing
• European Union: European Court of Justice Addresses Implications of French Exit Tax on Freedom of Establishment
• The Netherlands: Implications in the Netherlands of Recent European Court of Justice's Judgment Concerning Exit Taxes

2004-09

March 9, 2004

• Austria: Tax Reform 2005 Includes Proposals Favorable to Corporations
• Belgium: Simplified Rules for Determining Valuation of Benefits from Personal Use of Company Cars
• Croatia: Two New Tax Treaties Enter Into Force
• Ireland: Tax Incentive Proposals Are Intended to Attract Investments
• Luxembourg: Treaty Update
• United Kingdom: Possible Budget Implications for Individuals

Issue

Date

Subject

2004-08

February 26, 2004

• Czech Republic: New Value Added Tax Act Is Approved by Chamber of Deputies
• Ireland: Finance Bill 2004 Changes Relevant to Financial Services Industry, and to the Participation Exemption Rules
• Italy: New Group Consolidation Rules

2004-07

February 24, 2004

• European Union: Customs Duty and Trade Opportunities -- Risks with EU Enlargement
• Poland: Information Return Filing Requirements for Salaries Paid to Foreign Workers
• Romania: Tax Law Changes Effective in 2004
• United Kingdom: Update on Revenue's Appeal and Proposed Legislation Concerning Limitations for Refunds of Advance Corporation Tax
• United Kingdom: Budget Predictions Focus on Employee-Related Issues
• United Kingdom-France: New Tax Convention

2004-06

February 12, 2004

• Czech Republic: Recent Tax and Accounting Changes
• Italy: Thin Capitalization Rules Are Enacted
• The Netherlands: Overview of New Tax Rules of Interest to Multinational Businesses
• Nordic Countries: Reports of Tax Developments from Sweden, Denmark, Norway, Iceland, and Finland
• Spain: Overview of Changes in 2004 Budget
• Switzerland: Merger Act to Become Effective in July 2004
• United Kingdom: Guidelines for Employer Computer Loan Programs

2004-05

February 3, 2004

• Croatia: New Research and Development Tax Regulations
• The Netherlands: Update on European Tax Developments
• Poland: Changes to Tax on Civil Activities
• Romania: Changes to Social Contributions in 2004
• Switzerland: Federal Supreme Court Upholds Tax-Free Transfer of Old Investments/Subsidiaries by Swiss Company to Foreign Group Company
• Switzerland: Agreement Resolves Certain Tax Policy Issues with OECD, Including "Black List" Designation
• United Kingdom: Court of Appeal Addresses Deductibility of Contributions to Employee Benefit Trusts
• United Kingdom: Interest and Royalties Directive – European Commission Proposes Broadening of Scope

Issue

Date

Subject

2004-04

January 23, 2004

• Denmark: Introduction of "EU Package" Legislation; Includes Thin Capitalization Withholding Tax Amendments
• France: Overview of 2004 Finance Bill, and 2003 Revised Finance Bill
• France: Supreme Tax Court Addresses Thin Capitalization Debt-to-Equity Ratio for EU Parent Companies
• United Kingdom: More Companies Expected to Benefit from First-Year Plant and Machinery Allowances
• United Kingdom: Additional Relief for Oil Exploration in the North Sea

2004-03

January 21, 2004

• European Union: New Parent-Subsidiary Directive; Proposals to Change Merger and Mutual Assistance Directives
• European Union: Update on Implementation of EU Savings Directive
• European Union: Practical Information About New VAT Legislation in 10 Accession Countries
• Spain: Taxation of Preferred Shares and Other Debt Instruments
• Spain: 2004 Changes to the Corporate Income Tax Law

2004-02

January 14, 2004

• United Kingdom: Proposals Concerning Tax Treatment of Trusts
• United Kingdom: Non-Residents Working in the UK for Short Periods
• United Kingdom: Implementation of EU Directive on the Taxation of Savings
• United Kingdom: Consultation Document to Address VAT Group Abuses

2004-01

January 8, 2004

• Belgium: Interest and Royalty Directive Implemented as Part of Belgian Law
• Czech Republic: Implementation of EU e-Commerce Rules
• Germany: Effective Use of Advance Pricing Agreements in Routine Tax Examinations
• Poland: Corporate Income Tax Changes for 2004
• Romania: Harmonization of Banking Law with EU Regulations

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