Issue

Date

Subject

2006-59

December 20, 2006

• France: Follow-up Discussion of ECJ Judgment in Denkavit Case on Outbound Dividend Taxation
• Germany: Anti-Treaty / Anti-Directive Shopping Provision; New Substance Requirement
• Italy: EC Parent-Subsidiary Directive Is Approved
• Spain: Recent VAT Law Changes

2006-58

December 14, 2006

• France-Netherlands: European Court of Justice Finds Withholding Tax Breaches EU Law (Denkavit Case)
• Germany: Contracts May Need to Be Changed to Reflect New VAT Rate
• Romania: New Corporate Governance Rules
• United Kingdom: Follow-up Discussion of ECJ Judgment in the “Franked Investment Income” Case

2006-57

December 12, 2006

• France: Proposals to Change Tax Regime Concerning Partial Recapture of Financial Expenses Within Consolidated Groups
• Luxembourg: Proposal to Repeal 1929 Holding Companies Regime
• United Kingdom: ECJ Finds Member States Must Treat Dividends Paid at National and Cross-Border Level in Same Way if Situations Are Comparable

2006-56

December 8, 2006

• European Union: EU Commission Proposes to Abolish Duty on Contributions of Capital
• Ireland: Budget 2007 Includes Proposals for Tax Changes
• Spain: Changes to the Spanish Corporate Income Tax Law Include Lower Tax Rates

2006-55

December 6, 2006

• United Kingdom: Pre-Budget Report 2006

2006-54

December 4, 2006

• Germany: Winter 2006 Update of Recent Tax Developments
• Poland: Changes to Corporate Income Tax Are Enacted; Effective Date is 1 January 2007
• Romania: Changes to VAT Registration Numbers After EU Accession
• United Kingdom: Capital Gains Tax De-Grouping Charge

Issue

Date

Subject

2006-53

November 29, 2006

• Belgium: New Income Tax Treaty Is Signed with the United States
• Germany: Recent Legislative Action on SE Introductory Act
• Luxembourg: Tax Treaty Update
• Luxembourg: Tax Proposals in the 2007 Budget
• The Netherlands: Final Vote on the Corporate Income Tax Reform Bill
• Poland: Use of Polish Financing Companies—Weighing Options in Light of Recent Developments

2006-52

November 21, 2006

• Germany: Update on Status of the 2007 Tax Act
• Poland: Changes in Excise Tax Rules for Cars, Cosmetics

2006-51

November 14, 2006

• Belgium: ECJ Decision on Tax Treatment of Inbound Dividends from Companies Established in EU Member States
• Germany: Business Tax Reform 2008: Study Group Results
• Poland: Amendments to the Corporate Income Tax 2007
• United Kingdom: Pre-Budget Report: Response to Cadbury Schweppes

2006-50

November 10, 2006

• Ireland: Transfer Pricing for VAT; Stamp Duty Issues for the Business Community
• The Netherlands: Update on the Corporate Income Tax Reform Bill

2006-49

November 2, 2006

• Belgium: Proposals for Extending Exemption from Withholding Tax on Dividends Paid to Parent Companies Located in Tax-Treaty Countries
• Germany: Update on Recent Tax Developments
• Poland: Update on Changes to Tax Residence Rules for Individual Income Tax Purposes
• United Kingdom: Update on Income Tax Treaty with Poland

Issue

Date

Subject

2006-48

October 27, 2006

• Romania: Changes to Local Real Estate Taxes and Incentives
• United Kingdom: House of Lords Finds for Taxpayer Concerning EU-Related Claim Time Limits in Deutsche Morgan Grenfell Case

2006-47

October 25, 2006

• Luxembourg: Implementation of EU Parent-Subsidiary Directive Results in Changes to Participation Exemption Rules
• Luxembourg: Tax Treaty Update
• Romania: Recent Changes to the Fiscal Procedure Code
• United Kingdom: Proposed Changes to Rules That UK-Based Investment Managers of Offshore Funds Must Satisfy to Maintain Tax-Free Status
• United Kingdom: Guide on Tax Treatment of Real Estate Investment Trusts (REITs)

2006-46

October 13, 2006

• The Netherlands: Dutch Lower House Approves Corporate Income Tax Reform Bill
• Poland: Change in Policy Concerning Withholding Tax Obligation When Interest Is Capitalized
• United Kingdom: Run-up to Pre-Budget Report

2006-45

October 9, 2006

• Czech Republic: Proposal to Amend Certain Fuel Provisions in Excise Duty Act
• Germany: ECJ Advocate General Rejects Temporal Effects of Judgment Regarding Former German System for the Taxation of Dividends
• Italy: 2007 Finance Draft Bill Includes Proposed Changes to Individual Income Tax Rates; Measures Concerning Taxation of Capital Income, Loss Carryforwards, and Other Items
• Romania: Planning for EU Accession
• Spain: Changes Proposed Concerning the Taxation of Non-Residents, and Individual Income Tax for 2007
• United Kingdom: Income Tax Treaty with Japan Enters Into Force on 12 October 2006

2006-44

October 3, 2006

• European Union: Global VAT Brief
• Germany: Update on Recent Tax Developments
• Italy: European Court of Justice Finds IRAP Is Compatible with Community Law
• Switzerland: New Rules for Foreign Nationals

Issue

Date

Subject

2006-43

September 28, 2006

• Denmark: EC Begins Investigation Concerning Denmark’s Proposed CO₂ Tax Exemptions
• Germany: Administrative Guidance on Thin Capitalization Rules and Intra-Group Purchases of Shares

2006-42

September 25, 2006

• Belgium: Update on Lump-Sum Travel Allowances
• France: Reminder: Changes to VAT Rules With Respect to Foreign Entities Were Effective September 1st
• Germany: Discussion of Selected Tax Developments for September 2006
• Poland: Draft Amendments to the “Tax on Civil Law Transactions”

2006-41

September 19, 2006

• Austria / United Kingdom: ECJ Advocate General Issues Opinions Concerning VAT With Respect to Governmental Sales of Licenses to Mobile Phone Companies
• Czech Republic: Proposed Changes to Health Insurance Contribution Rules
• Finland: ECJ Advocate General Finds Finnish Group Contribution System Rules Are Compatible with EU Principles
• Romania: Changes to Work Permit Rules
• United Kingdom: Proposed "Reverse Charge Accounting" Concerning VAT for Businesses Trading in Mobile Telephones, Computer Chips, and Other Goods

2006-40

September 13, 2006

• United Kingdom: Further Discussion of European Court of Justice Decision in Cadbury Schweppes Case
• United Kingdom: HM Revenue & Customs Appeals Special Commissioner’s Decision Concerning Treatment of Termination Payments

2006-39

September 12, 2006

• The Netherlands: European Court of Justice Issues Important Decision on Dutch Protective Assessments
• United Kingdom: European Court of Justice Issues Landmark Decision in Cadbury Schweppes Case

Issue

Date

Subject

2006-38

August 31, 2006

• Poland: Proposed Changes Concerning VAT and Individual Income Tax
• Romania: Amendments to Tax Laws Effective Beginning in 2007
• Switzerland: Federal Law on Tax Holidays
• United Kingdom: Options to Encourage Environmentally Friendly Approach to Business Mileage

2006-37

August 17, 2006

• The Netherlands: Ministry of Finance Provides Detailed Explanation of “Working on Profit” Bill and Announces Amendments
• Poland: Proposed Changes to the Corporate Income Tax for 2007
• Romania: Rules on Assigning Employees to Supply Services in Romania
• Switzerland: Changes in Swiss VAT Law

2006-36

August 10, 2006

• Czech Republic: EU Insurance Companies Can Provide Employee Pension Insurance in the Czech Republic
• Poland: Electronic Returns by Large Taxpayers Not Compulsory
• Sweden: Protocol Amending United States-Sweden Income Tax Treaty to Enter Into Force August 31, 2006

Issue

Date

Subject

2006-35

July 27, 2006

• Germany: Cabinet Approves Legislation Introducing Societas Europaea and Other Changes
• United Kingdom: Tax Treaty Update
• United Kingdom: New Double Taxation Convention with Poland

2006-34

July 25, 2006

• European Commission: Belgium, Spain, Italy, Luxembourg, the Netherlands, and Portugal Requested to End Discriminatory Taxation of Outbound Dividends
• Turkey: Increased Withholding Tax Rate on Dividends
• VAT: European Commission Launches Infringement Proceedings Against Germany, Greece, Ireland, and Italy

2006-33

July 21, 2006

• France: European Commission Refers France to ECJ for Failure to Recover Illegal State Aid
• Luxembourg: 1929 Holding Company Regime to Be Repealed
• United Kingdom: Deadline for New Rules on Disclosure of Tax Avoidance Schemes Is 1 August 2006

2006-32

July 18, 2006

• Belgium: Recent Tax Legislative Changes
• Europe: Taxation of Cross-Border Mergers and Acquisitions
• Germany: Proposals for Business Tax Reform; Draft 2007 Tax Act

2006-31

July 14, 2006

• Italy: Tax Provisions Included in Emergency Supplementary Mini-Budget
• United Kingdom: Decision in Company Residence Case Is Final

2006-30

July 11, 2006

• Italy: European Commission Begins Public Process Concerning Italian Tax Refund Procedures
• The Netherlands: Audio Discussion of Proposals to Overhaul the Corporate Income Tax
• Portugal: European Commission Refers Portugal to ECJ Concerning Discriminatory Taxation of Foreign Banks
• Romania: 6% Maximum Interest Rate Deductibility for Non-Bank Loans
• Turkey: New Corporate Tax Law for 2006

2006-29

July 7, 2006

• Czech Republic: New Double Taxation Treaty with Austria
• France: Guidance Relating to VAT Self-Assessments for Transactions Involving Suppliers That Are Not Established in France
• Germany: Discussion of Selected Tax Developments for July/August 2006
• Luxembourg: Tax Treaty Update
• United Kingdom: ECJ Advocate General’s Opinion in the Thin Capitalisation Group Litigation Case

Issue

Date

Subject

2006-28

June 14, 2006

• VAT: Global VAT News

2006-27

June 12, 2006

• Germany: ECJ Advocate General Addresses Deductibility of Decrease in Value of a Participation in Subsidiaries Established in Other EU Member States
• The Netherlands: Audio Web-Briefing on Pending Proposals to Change the Corporate Income Tax
• Poland: Proposed Changes to Polish Tax System
• Spain: Draft Legislative Proposals Include Changes to Corporate Income Tax Rates, Incentives

2006-26

June 1, 2006

• Germany: Discussion of Selected Tax Developments for June 2006
• Poland: June 30 Is Last Day for Non-Resident Entities to File VAT Refund Claim for Tax Year 2005
• Spain: Plan to Phase Out Incentives for Investment Abroad

Issue

Date

Subject

2006-25

May 26, 2006

• Germany: Draft Legislation Proposes to Revise Tax Treatment of Business Reorganizations; Proposal to Impose Wealth Surcharge on Individuals
• The Netherlands: Legislative Proposal on Changes to Corporate Income Tax Is Published

2006-24

May 22, 2006

• Finland: ECJ Considers Compatibility of Finnish Group Contribution System with EU Principles
• The Netherlands: Supreme Court Concludes No Dutch Tax on Liquidation of Dutch Private Limited Liability Company That Had Emigrated to Belgium
• United Kingdom: ECJ Judgment Concerning VAT on Management of Investment Funds

2006-23

May 8, 2006

• Luxembourg: Tax Proposals Included in State of Nation Address
• The Netherlands: Legislative Proposal on Tax-Exempt Investment Institutions

2006-22

May 2, 2006

• Germany: Discussion of Selected Tax Developments
• The Netherlands: Possible Consequences for Dutch Taxpayers of ECJ Advocate General’s Opinion in Denkavit Case
• United Kingdom: ECJ Advocate General Issues Opinion Concerning Compatibility of UK Controlled Foreign Company Rules to EU Law

Issue

Date

Subject

2006-21

April 27, 2006

• France: ECJ Advocate General Issues Opinion Concerning French Dividend Withholding Tax
• Germany: Legislation on Internationalization of Reorganization Law, Amendments to VAT Rates, and Energy Taxation; Tax Return Deadlines and Other Developments
• Guernsey: Tax Information Exchange Agreement with United States Enters into Force

2006-20

April 26, 2006

• Belgium: EU Commission Considers Belgian Tax on Collective Investment Undertakings, Decides No State Aid Is Involved
• Ireland: Discussions of Finance Act 2006, Other Developments
• The Netherlands: Update on Corporate Income Tax Act of 2007

2006-19

April 21, 2006

• The Netherlands: Dutch Supreme Court Addresses Deductibility of Costs Relating to Participations Based in Non-EU/EEA Member States
• Romania: Recent Developments Concerning Real Estate Taxes and the Mortgage Loan Market
• United Kingdom: HM Revenue & Customs’ Large Business Service Launches New Approach to Large Business

2006-18

April 13, 2006

• Belgium: ECJ Advocate General Issues Opinion on Belgian Rules Not Allowing Imputation Credit for Foreign-Source Dividends
• Czech Republic: Guidance Concerning Taxation of Czech Income of Non-Residents
• United Kingdom: Proposed Taxation of Employment-Related Options

2006-17

April 10, 2006

• Czech Republic: Recent Tax Law Changes
• United Kingdom: ECJ Advocate General’s Opinion in Group Litigation Concerning Different Tax Treatment of Domestic Dividends and Inbound Dividends
• VAT: Reminder of Deadlines for Filing Reclaims of Input VAT Paid During 2005
• Survey: KPMG’s Global Corporate Tax Rates Survey

2006-16

April 4, 2006

• Luxembourg: Tax Treaty Update
• Luxembourg: 1929 Holding Companies Subject to European Commission Investigation
• The Netherlands: ECJ Advocate General’s Opinion on Dutch Protective Assessments
• Poland: Changes in Calculation for Contributions to the Employees’ Guaranteed Benefits Fund
• United Kingdom: Overview of the Budget Process
• United Kingdom: Appeal in Case Concerning Dividends from “Husband-and-Wife Company”
• VAT: ECJ Decides Services Between Head Office and Branch Are Not Subject to VAT

Issue

Date

Subject

2006-15

March 28, 2006

• Croatia: New Double Tax Treaty with Spain
• Ireland: Employment Tax Provisions Included in Finance Bill 2006
• Malta: Tax Imputation System to Be Phased Out by the End of 2010

2006-14

March 22, 2006

• Poland: Next Round of Applications for Investments Grants in June 2006
• Romania: New Rules for When Receipts Can Be Used to Validate Certain Expenses for Tax Purposes
• United Kingdom: Budget 2006

2006-13

March 16, 2006

• Albania: Recent Changes to Tax Laws
• Italy: ECJ Advocate General Concludes Sixth VAT Directive Precludes Italy’s IRAP
• United Kingdom: ECJ Issues Judgment That “Rolled-Up Holiday Pay” Is Contrary to EU Working Time Directive

2006-12

March 8, 2006

• Germany: Discussions of Recent Tax Developments, with Focus on Impact for International Business
• Ireland: Finance Bill 2006 Reaches Report Stage
• Switzerland: Changes to Stamp Tax Act Affect Share Issuance, Securities Transfers
• United Kingdom: Reform of Leasing Transactions Anticipated in Budget 2006

2006-11

March 2, 2006

• Germany: ECJ Holds Former German Corporate Income Tax Rules on Deduction of Interest Not Compatible with EC Treaty
• Germany: Report on Recent Developments Including Non-Acquiescence to Treaty-Shopping Case, Cross-Border Mergers, Clarity in Treatment of Creditor Priority Subordinations
• The Netherlands: ECJ Finds Deemed-Residence Rule in Dutch Inheritance Tax Act Does Not Contravene EU Law
• United Kingdom: ECJ Advocate General Concludes ACT Rules Are Not Discriminatory

Issue

Date

Subject

2006-10

February 27, 2006

• Germany: Commentary on ECJ’s Decision in Ritter-Coulais Case
• United Kingdom: Changes to UK Group Relief Rules in Reaction to the Marks & Spencer Judgment

2006-09

February 22, 2006

• Germany: ECJ Judgment Finds Certain Treatment of Non-Resident Workers Under German Law Is Contrary to EC Treaty
• Ireland: European Court of Justice Confirms Right to Legitimate VAT Planning
• VAT: ECJ Addresses Scope of Sixth VAT Directive

2006-08

February 20, 2006

• Portugal: 2006 Budget Includes Changes to Thin Capitalization Rules
• United Kingdom: New Double Tax Treaty with Japan

2006-07

February 9, 2006

• Czech Republic: Draft Amendment to the Act on Residence of Foreigners
• Ireland: Finance Bill 2006
• Luxembourg: Guidelines on Domestic Withholding Tax on Interest Income for Luxembourg Residents

2006-06

February 3, 2006

• France: Recent Tax Law Changes Could Make France a More Competitive Tax Environment for Foreign Investors
• Germany: First Tax Legislation Approved by New Government; Draft Guidance on Debt-Financed Intra-Group Share Acquisitions; and Other Developments

Issue

Date

Subject

2006-05

January 27, 2006

• France: U.S. Senate Foreign Relations Committee Hearing on Protocols to Income Tax and Estate and Gift Tax Treaties with the United States
• Poland: New Rules for Reporting Information on Wages Paid to Non-Resident Individuals
• Portugal: Changes to Taxation of Dividends, and of Interest and Capital Gains on Portuguese Debt Securities
• Sweden: U.S. Senate Foreign Relations Committee Hearing on Protocol to Income Tax Treaty with the United States
• United Kingdom: Proposals for Real Estate Investment Trusts

2006-04

January 24, 2006

• France: Changes to the Thin Capitalization Rules Are Enacted
• France: Extension of the Reverse-Charge Mechanism
• Sweden: European Court of Justice Addresses Taxation of Payment to Individual Shareholders in Connection with Share Repurchase

2006-03

January 20, 2006

• France: Measures Further Enhancing the Research Tax Credit Rules Are Enacted
• Italy: Protocol Amending Income Tax Treaty with India
• VAT: Global VAT News

2006-02

January 9, 2006

• Belgium: Belgium’s Prime Minister to Visit United States in January 2006
• The Netherlands: Government Begins Preliminary Discussions of New Corporate Income Tax Act

2006-01

January 5, 2006

• Italy: Recent Changes to Corporate Tax Law
• Romania: New Health Tax Rules Apply for Non-Romanian Nationals Living in Romania

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