To obtain a copy of any of these issues, please send an e-mail to the US-KPMG Washington National Tax.


December 2005

Issue

Date

Subject

2005-65

December 30, 2005

  • Germany: Legislation Proposed to Address Abusive Tax Structures and to Promote Growth and Job Creation
  • Luxembourg: Withholding Tax on Interest Income of Luxembourg Residents

2005-64

December 20, 2005

  • The Netherlands: Provisions on Written-Down Loans Enter Into Effect
  • United Kingdom: EJC Hearings on Compatibility of UK CFC Rules with EU Freedoms

2005-63

December 14, 2005

  • The Netherlands: Possible Implications of Marks & Spencer Decision
  • Switzerland: Obwalden Canton Lowers Income Tax Rates for Corporations and Individuals
  • United Kingdom: Implications of the EJC’s Judgment in the Marks & Spencer Case

2005-62

December 13, 2005

  • Belgium: New Measures to Stimulate R&D and Boost Competitiveness
  • Czech Republic: New Double Taxation Treaty with Norway
  • Romania: High Risk VAT Refunds
  • United Kingdom: European Court of Justice Issues Judgment in Marks & Spencer Case Concerning UK Group Consolidation/Relief Rules
  • VAT: Global Indirect Tax Guide for 2005

2005-61

December 9, 2005

  • The Netherlands: Agreement Reached Between the Netherlands and Netherlands Antilles to Lower Dividend Withholding Tax
  • United Kingdom: Pre-Budget Report Special Edition

2005-60

December 8, 2005

  • Germany: VAT Treatment of Purchases of Standard Software on Data Media and Accompanying Customization Services
  • Ireland: Budget 2006
  • United Kingdom: Overview of Pre-Budget Report 2005

2005-59

December 2, 2005

  • Germany: Tax Policies of the New Government; Guidance Concerning Document Security Arrangements, Thin Capitalization Rules, and Tax Group Rules
  • Germany: Tax Credits for Dividends Received by Individuals from Foreign Companies
  • Poland: New VAT Payment Dates on Imports; New Rules on Taxation of Goods in Customs Warehouses

November 2005

Issue

Date

Subject

2005-58

November 21, 2005

  • Belgium: Notional Interest Deduction—Government Announces Repeal of the Condition of “Unavailability”
  • Germany: Tax Proposals in the Grand Coalition’s Agreement
  • The Netherlands: Proposal to Exempt Charities from Inheritance Tax and Gift Tax

2005-57

November 8, 2005

  • France: Intangible Assets: Toward a Relaxation of the Conditions of Amortization?
  • Germany: Model Certificate to Be Used to Document Security Arrangements Under the Thin Capitalization Rules

2005-56

November 4, 2005

  • Ireland: Update of VAT Developments
  • The Netherlands: Amsterdam Court of Appeals Refers Issues Concerning Dutch Dividend Withholding Tax to European Court of Justice
  • United Kingdom: Leasing Changes in the Pre-Budget Report?

2005-55

November 1, 2005

  • Germany: Possible Changes to Capital Gains Tax Exemption for Sales of Corporate Stock by Corporations
  • Luxembourg: Budget 2006 Includes Tax Measures; Tax Treaty with Israel
  • The Netherlands: Additional Guidance on the Application of the Dutch Expatriate Tax Ruling (the 30% Ruling)

October 2005

Issue

Date

Subject

2005-54

October 24, 2005

  • The Netherlands: Dutch Court of Appeals Finds Dividend Withholding Tax Contravenes EU Law
  • Portugal: Remittances of Income Tax and VAT from Foreign Taxpayers

2005-53

October 18, 2005

  • The Netherlands: Report of Recent Tax Developments for Companies and Business; Treaty Update
  • VAT: Transactions Between Branches of a Single Legal Entity

2005-52

October 11, 2005

  • Czech Republic: Tax Treaty Update; New R&D Guidance
  • France: Proposed Revision of the Thin-Capitalization Rules

2005-51

October 4, 2005

  • Belgium: Implementing Decree Clarifies Notional Interest Deduction
  • The Netherlands: Legislative Proposal Includes Changes for Payroll Tax, Social Security Contributions, Remittance Reductions, and the Social Security System

2005-50

October 3, 2005

  • France: Proposed Enhancements to the Research Tax Credit Rules
  • Germany: Election Update; Withholding Tax Exemption for Foreign Holding Companies; Trade Income Tax of Dual Resident Companies
  • The Netherlands: Dutch Supreme Court Decision on Allocation of Employment Income in Cross-Border Situations
  • Sweden: Protocol to United States-Sweden Income Tax Treaty Is Signed

September 2005

Issue

Date

Subject

2005-49

September 22, 2005

  • Italy: VAT Payers May Be Eligible for Refunds on Vehicle Purchases, Rentals
  • The Netherlands: 2006 Budget Includes Tax Proposals for Reduced Corporate Income Tax Rate and Repeal of the Capital Tax
  • VAT: EU Releases FAQs on Taxation of Business-to-Consumer Services

2005-48

September 19, 2005

  • Italy: Tax Authorities Reinterpret “Minimum Holding Period” for Purposes of EU Parent-Subsidiary Directive; Possible Implications for Interest and Royalties Directive
  • The Netherlands: Advocate General’s Opinion on Scope of VAT Exemption for Management of Common Funds
  • Poland: Discussion of Taxes Pending the Elections; New R&D Incentives in Poland

2005-47

September 9, 2005

  • Czech Republic: Amendment of the Value Added Tax Act
  • Czech Republic: Expanding the Binding Ruling System
  • The Netherlands: New Decree Governing the Application of the Dutch Expatriate Tax Ruling

2005-46

September 1, 2005

  • Germany: Reports on Status of Tax Legislation, More Thin Capitalization Guidance, and Other Developments
  • VAT: Global VAT Reports from 20 Countries

August 2005

Issue

Date

Subject

2005-45

August 16, 2005

  • Germany: Unofficial Translation of Recent Thin Capitalization Guidance Concerning Recourse Rights

2005-44

August 8, 2005

  • Germany: Proposal to Limit or Repeal the Tax Exemption for Gains on Sales of Corporate Stock
  • Italy: New Provisions May Affect Certain Cross-Border Lease Payments
  • United Kingdom: Activities Qualifying for R&D Tax Relief

2005-43

August 4, 2005

  • Germany: Guidance on Recourse Rights Under the Thin Capitalization Rules; Draft Guidance on Intra-Group Dispositions of Shares

July 2005

Issue

Date

Subject

2005-42

July 25, 2005

  • The Netherlands: Dual Use of Capital Assets—VAT Fully Deductible
  • Poland: Changes to Excise Tax on Electricity
  • Romania: Amendments to the Fiscal Code Norms
  • Switzerland: Guidance Concerning Intra-Group Dividend Payments Under EU-Swiss Savings Agreement

2005-41

July 21, 2005

  • Croatia: Recent Tax Law Changes Include Repeal of Withholding Tax on Dividends
  • Czech Republic-France: New Double Tax Treaty
  • United Kingdom: Finance Act Receives Royal Assent; Measures Concerning Avoidance Involving Arbitrage Are Enacted
  • United Kingdom: VAT and the Three-Year Limit on Repayments—the Condé Nast Case

2005-40

July 12, 2005

  • France: Update on Proposed Changes to Thin-Capitalization Rules
  • Germany: German Aspects of Kretztechnik ECJ Case, Guidance on the Discounting of Liabilities, and Other Developments
  • Luxembourg: Savings Taxation Update
  • The Netherlands: Decree on Hybrid Provision in United States-Netherlands Tax Treaty

2005-39

July 8, 2005

  • The Netherlands: Dutch Measures Facilitating International Share Exchanges

2005-38

July 7, 2005

  • Belgium: Notional Interest Deduction Measure Become Law
  • The Netherlands: European Court of Justice Decision in the “D” Case
  • United Kingdom: The Effect of ECJ Tax Cases on National Tax Systems

June 2005

Issue

Date

Subject

2005-37

June 30, 2005

  • Germany: Electronic Invoice Procedures Must Be Followed for Input VAT Deduction Purposes
  • The Netherlands: EU Savings Directive Applies Beginning July 1, 2005
  • United Kingdom: Continuing Saga of section 91B: Tax Avoidance Through Loans in the Form of Shares Avoidance Involving Arbitrage

2005-36

June 24, 2005

  • The Netherlands: Upper House Approves New Compulsory Health Insurance Legislation
  • Switzerland: Recent Guidance Replaces “50-50 Practice” of Lump-Sum Expense Deduction with Arm’s Length Standard

2005-35

June 21, 2005

  • Italy: Clarification of Thin Capitalization Rules for Permanent Establishments; Anticipated Changes to Tax Rules Concerning Inbound Dividends; Domestic Consolidation for Non-Residents with an Italian PE
  • Poland: Decisions of Special Tax Offices Serving Large Taxpayers Are Held Invalid

2005-34

June 13, 2005

  • Croatia: New Foreign Exchange Regulation
  • The Netherlands: EU Savings Directive—Implications for Private Investors
  • Poland: Changes to the VAT Act
  • Romania: Amendments to the Fiscal Code

2005-33

June 9, 2005

  • Belgium: Parliament Approves Legislation Providing Notional Interest Deduction; Measures Become Law with Royal Assent
  • Czech Republic: Recommendation Relating to Tax Deductions for R&D Expenditures
  • Poland: Deadline for Foreign Entities to Apply for VAT Refunds Is June 30, 2005
  • United Kingdom: New Tax on Borrowers of Connected-Party Impaired Debt

2005-32

June 2, 2005

  • Denmark: Parliament Approves Reduction of Corporate Income Tax Rate and Changes to the Joint Taxation Rules

2005-31

June 1, 2005

  • European Union: ECJ Holds Share Issuance Is Not Supply of Services Subject to VAT
  • Germany: Update on Tax Relief Legislation
  • Germany: Approaching Deadline for Claiming Refunds of Input VAT for 2004
  • Italy: EU Interest and Royalties Directive: Implementing Decree Is Approved by Ministry Council
  • Luxembourg: Levy Imposed on Equity Contributions to a Securitisation Vehicle; Treaty Update
  • The Netherlands: Anti-Abuse VAT Legislation Proposed for Leasing Arrangements

May 2005

Issue

Date

Subject

2005-30

May 27, 2005

  • United Kingdom: Avoidance Involving Arbitrage

2005-29

May 26, 2005

  • Belgium: Update on Proposed Legislation Providing Notional Interest Deduction
  • Czech Republic: Ministry of Finance’s New Opinion on Treatment of Derivatives
  • United Kingdom: HM Revenue & Customs Responds to ECJ Judgment Concerning VAT on Insurance Outsourcing
  • United Kingdom: VAT—Place of Supply of Services

2005-28

May 16, 2005

  • Czech Republic: Depreciation of Fixed Assets in 2005
  • The Netherlands: Guidance on Interpretation of United States-Netherlands Tax Treaty
  • Poland: Thin Capitalization Update

2005-27

May 10, 2005

  • European Union: ECJ Addresses Validity of Retroactive VAT Legislation in the EU
  • Germany: Recent Draft Legislation Would Provide Certain Business-Related Benefits

2005-26

May 4, 2005

  • Germany: Federal Government Approves Draft Legislation for Improving Tax Conditions

2005-25

May 3, 2005

  • The Netherlands: Explanation of the Dutch Government’s Vision of a New Corporate Income Tax System
  • United Kingdom: Marks & Spencer: A Pan-EU Perspective

2005-24

May 2, 2005

  • Germany: Possible Implications of the Marks & Spencer Opinion; Update on Thin Capitalization Rules; Other Developments
  • The Netherlands: Proposals Aim at Encouraging Investment
  • Romania: New Foreign Exchange Regulations

April 2005

Issue

Date

Subject

2005-23

April 25, 2005

  • European Union: European Commission Proposes to Extend Standard VAT Rate of 15% Through 2010
  • Germany: Discussion of Thin Capitalization Rules, Other Recent Developments
  • Luxembourg: Legislation Conforms 1929 Holding Company Regime to EU Tax Policies
  • United Kingdom: Depreciation in Stock

2005-22

April 22, 2005

  • Bulgaria: Treaty Negotiations to Begin with the United States
  • Germany: Deductibility of VAT Relating to Business-Related Meals and Entertainment Expenses
  • Germany: Filing Protective Claims Pending the ECJ’s Decision in the Marks and Spencer Case
  • Poland: Double Taxation Agreement with New Zealand
  • United Kingdom: Residence of a Company

2005-21

April 14, 2005

  • Germany: Tax Card 2005

2005-20

April 7, 2005

  • European Union: Opinion of Advocate General in the UK’s Marks and Spencer Case

2005-19

April 6, 2005

  • Bulgaria: Recent Changes to Individual Taxation
  • Germany: April 2005 Update
  • The Netherlands: Working Guide for 2005 Tax Compliance
  • United Kingdom: Possible Effects of Early Election on Finance Bill 2005
  • United Kingdom: Business Premises Renovation Allowance – Finance Bill Clauses
  • United Kingdom: Stamp Taxes – Finance Bill 2005

March 2005

Issue

Date

Subject

2005-18

March 29, 2005

  • Ireland: Finance Act 2005
  • The Netherlands: Follow-up on Proposal to Repeal Capital Contribution Tax

2005-17

March 24, 2005

  • Luxembourg: Guidance for Determining Net Rental Income
  • The Netherlands: Capital Tax to Be Repealed
  • Romania: Recent Guidance Includes Thin Capitalization Rules

2005-16

March 23, 2005

  • Italy: Advocate General Finds Italian Regional Tax Violates VAT Directive, Urges ECJ to Reopen Proceedings to Consider Retroactive Application of Tax Refund Claims

2005-15

March 21, 2005

  • Belgium: Draft Legislation Would Provide Notional Interest Deduction, Repeal of Capital Duty Tax
  • The Netherlands: Legislative Proposal with Retroactive Effect; No Dutch Tax Imposed at Debtor Level on Conversion of Debt into Equity
  • United Kingdom: ECJ Finds Against the UK in a VAT Dispute Concerning Employee Business-Purpose Fuel Reimbursements

2005-14

March 16, 2005

  • United Kingdom: 2005 Budget

2005-13

March 15, 2005

  • France: ECJ Judgment Concerning French Research Tax Credit
  • Germany: Input Tax Deduction for Costs Incurred in Connection with Issuing Shares
  • Germany: Advocate General Issues Opinion Concerning German Law and Treatment of Free Movement of Workers Under EC Treaty

2005-12

March 10, 2005

  • Czech Republic: Tax Aspects of Derivatives and Valuation Differences; Pending Legislative Changes to Excise Duties Act
  • Denmark: Proposed Reduction of Corporation Income Tax Rate and Proposed Changes to Danish Joint Taxation Rules Are Reintroduced
  • Luxembourg: Treaty Update

2005-11

March 07, 2005

  • Bulgaria: VAT Credit on Invoices for Advance Payments
  • Luxembourg: Draft Form for Use in Declaring the Amount of Tax Withheld at Source
  • Netherlands: Recent Tax Update
  • Poland: Comments Concerning Tax Due Diligence Process
  • Romania: Tax Depreciation Guidelines

February 2005

Issue

Date

Subject

2005-10

February 22, 2005

  • France: New Opportunities Under the French Research Tax Credit
  • Poland: Tribunal Rules Individual Income Tax Rate of 50% Will Not Apply in 2005
  • United Kingdom: Use of Information Powers by LBO Inspectors

2005-09

February 16, 2005

  • Bulgaria: Changes to Corporate Taxation Effective in 2005
  • Germany: Ministry of Finance Issues Draft Guidance Interpreting German Tax Group Rules (Organschaft)
  • Ireland: Finance Bill 2005
  • Romania: New Procedures for Refunds of Tax Overpayments; Guidance for Operations in Free Trade Zones
  • United Kingdom: Court of Appeal Decision Limits Tax Claims to Six Years

2005-08

February 9, 2005

  • Croatia: Tax Guide for 2005
  • The Netherlands: End of Withholding Tax for Dutch Dividends?

2005-07

February 3, 2005

  • Germany: Update on Expected Guidance Under the New Thin Capitalization Rules; Pending Court Decision to Address Application of Previous Rules to Non-EU States
  • United Kingdom: European Court of Justice Holds Hearing on Marks & Spencer Case, Concerning UK Group Consolidation/Relief Rules

2005-06

February 1, 2005

  • Czech Republic: Uncertainties Concerning the Tax Treatment of Derivative Transactions
  • Romania: Additional Tax Rate Reductions Effective for 2005; New Rules on the Tax Treatment of Mergers, De-Mergers; Advance Tax Rulings
  • Switzerland: Relief at Source From Withholding Tax on Certain Dividends
  • United Kingdom: Implementation of the European Company Statute

January 2005

Issue

Date

Subject

2005-05

January 28, 2005

  • European Union: Survey of How Tax Issues Affect Companies’ Business Decisions, and the Costs of Tax Compliance
  • France: Tax Reform Measures Aim at Enhancing France’s Tax Competitiveness
  • Poland: Tax Treaty Update, Other Tax Developments
  • United Kingdom: National Insurance Contributions on Share Options

2005-04

January 19, 2005

  • Denmark: Proposed Tax Bills—Including Proposed Changes to Danish Joint Taxation Rules—Lapse Under Call for General Election
  • European Union: EcoFin Reaches Agreement Concerning Changes to Merger Directive, Adopts Code of Conduct Report Concerning Harmful Tax Measures
  • Germany: European Court of Justice to Address Whether Prior Version of German Thin Capitalization Rules Is Valid Restriction on Free Movement of Capital in Non-EU Situations
  • Northern Ireland: Update on Taxation of Companies and Businesses

2005-03

January 17, 2005

  • Belgium: Proposed Legislation Would Allow a Notional Interest Deduction Related to Equity and Retained Earnings
  • United Kingdom: When Will the Budget 2005 Take Place?
  • United Kingdom: Potential VAT Cost to Insurance Outsourcing

2005-02

January 12, 2005

  • Germany: New Law Provides Exemption for Capital Gains of Certain Taxpayers From Imposition of the Trade Tax
  • Germany: Several Changes to VAT Law Are Effective Beginning in 2005

2005-01

January 11, 2005

  • Croatia: Changes to Corporate Profit Tax Law, Effective in 2005
  • Czech Republic: Clarification of Guidance for Tax Transparent Entities, New R&D Deductions, and Other Developments
  • The Netherlands: Recent Decrees Concerning the EU Parent-Subsidiary Directive, Qualification for Non-Dutch Entities, and Participation Exemption for Hybrid Entities

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