Issue

Date

Subject

2007-51

December 27, 2007

• Germany: ECJ Judgment May Provide Refund Opportunities for Individual Taxpayers Who Sold Shares in 2001
• Hungary: Due Date of Special VAT Declaration Is December 31, 2007
• Sweden: ECJ Clarifies Application of Free Movement of Capital Concept Between Member States and Third Countries
• United Kingdom: HMRC Statement of Practice on Advance Thin Capitalisation Agreements

2007-50

December 11, 2007

• Belgium: Mandatory Use of 10-Digit VAT Number Begins in 2008
• Germany: ECJ Finds Replacement of Exemption Regime by Imputation Regime, When Profits of Permanent Establishment Consist of Low-Taxed Passive Income, Is Compatible with EC Treaty
• The Netherlands: “Packaging Tax” to Be Introduced in 2008

2007-49

December 6, 2007

• Hungary: Overhaul of VAT Rules
• Ireland: Budget 2008 Is Delivered
• Poland: Overview of Rules Concerning an Individuals’ Tax Residence Status; Possible Refund Opportunities for Social Security Contributions Made in Other Countries
• Romania: Recent Changes to Tax Code

2007-48

December 4, 2007

• Belgium: New Guidance on Creating, Using a VAT Group
• Germany: 2008 Tax Act Is Approved; Includes Redesigned Anti-Abuse Provision, Recapture Tax of Carryover EK 02, New Rules for Shareholder Loans
• United Kingdom: Research and Development Tax Relief—Four Months Left to File Refund Claims

Issue

Date

Subject

2007-47

November 26, 2007

• Belgium: International Taxation: Belgian Standard Model for Double Taxation Treaties
• Germany: Limitations on Deduction of Losses by Corporations
• The Netherlands: Burden of Proof for Interest-Deduction Restriction Regarding “Tainted” Loans to Become More Onerous

2007-46

November 21, 2007

• Austria: ECJ Clarifies What Is the Effect of Repeal of Capital Duty Changed to a Company on Transfer of Its Effective Place of Management
• France: Ratification of Protocol to Income Tax Treaty with Japan
• Germany: ECJ Advocate General Addresses Tax Treatment of Currency Exchange Loss on Repatriation of Start-Up Capital Granted to PE in Another EU Member State

2007-45

November 9, 2007

• Finland: ECJ Concludes Tax on Transfers of Securities as Contribution to a Company in Exchange for Its Shares Is Compatible with EC Directive
• The Netherlands: ECJ Addresses Dutch Withholding Tax on Dividends Paid to a Company Resident in Another EU Member State

2007-44

November 2, 2007

• Germany: Court Adopts Specific Asset Approach Under Change-of-Control Rules; Other Developments
• United Kingdom: New Double Tax Treaty Signed with Saudi Arabia

Issue

Date

Subject

2007-43

October 15, 2007

• France: ECJ Finds 3% Tax on Immovable Property Not Compatible with EC Treaty
• Hungary: ECJ Concludes Local Business Tax Is Not VAT and Is Compatible with EC Law
• Poland: Court Approves Use of Electronic Invoices That Satisfy EU Rules
• Portugal: ECJ Concludes Higher Rate of Tax on Capital Gains of Non-Residents Is Unjustified Restriction on Free Movement of Capital

2007-42

October 10, 2007

• France: Proposal for Reform of the French R&D Tax Credit for 2008
• Luxembourg: 2008 Budget
• United Kingdom: Commentary on Certain Proposals Contained in Pre-Budget Report

2007-41

October 9, 2007

• Belgium: Exemption from Paying Wage Withholding Tax of 0.25% for Employers in the Private Sector
• Hungary: Proposal to Revise the VAT Law
• Luxembourg: Net Wealth Tax for Resident Companies; Taxation of Capital Gains from Transactions Involving Collective Investment Units
• Poland: Capitalization of Interest and the Moment of Cost Recognition
• Switzerland: Proposal to Reduce Profits Tax Rate
• United Kingdom: Pre-Budget Report Is Delivered

2007-40

October 4, 2007

• Germany: Update on 2008 Tax Act; Guidance on Tax Exemption for German REITs and on Contributions Under the SE Introductory Act
• Italy: Draft Finance Bill for 2008 Includes Proposals for Tax Reform

Issue

Date

Subject

2007-39

September 19, 2007

• Germany: Overview of Recently Enacted Business Tax Reform 2008
• Sweden: ECJ Advocate General Examines Whether Swedish Dividend Exemption Restriction Is Compatible with EC Treaty’s Freedom of Movement of Capital
• VAT: Cancellation Charges Regarded as Non-Taxable Compensation for VAT Purposes; Relevance for Dutch Taxpayers

2007-38

September 5, 2007

• Germany: Business Tax Reform Legislation Is Enacted; German Cabinet Approves Draft 2008 Tax Act
• United Kingdom: Special Commissioners Address UK’s Controlled Foreign Company Rules and EU Law

Issue

Date

Subject

2007-37

August 15, 2007

• Belgium: New Rules Concerning Pension Amounts Received After the Taxpayer Transfers Residence Abroad
• Germany: Update on Draft 2008 Tax Legislation

Issue

Date

Subject

2007-36

July 30, 2007

• Finland: ECJ Advocate General’s Opinion Concerning Transfer Tax on Contributions to Capital
• France: Overview of Proposed Tax Reforms
• Poland: Transfer of Road to Commune for No Consideration Not Subject to VAT

2007-35

July 19, 2007

• Finland: ECJ Concludes Finnish Group Contribution System Rules Are Compatible with EU Law
• Germany: Draft of 2008 Tax Act and Other Developments
• Greece: EC Determines Tax Benefits Afforded to Companies Violates EU Law and Must Be Recovered from Taxpayers
• Poland: Reduction in Contribution Rates Under Social Security Act
• Spain: Revised Due Dates for Payment of Economic Activity Tax

2007-34

July 9, 2007

• Belgium: Tax Provisions Relating to Insurance and Pensions Violate EU Freedoms
• Denmark: ECJ Considers What Is Allowable Cash Payment with Respect to Tax-Free Exchange of Shares
• Greece: EC Refers Greece to ECJ for “Discriminatory” Tax Treatment of Dividend Income and Non-Greek Partnerships
• The Netherlands: ECJ Advocate General Considers Dutch Withholding Tax Rules as Applied to Collective Investment Funds
• United Kingdom: ECJ Addresses VAT Exemption for Management of Investment Trust Companies

Issue

Date

Subject

2007-33

June 26, 2007

• Austria, UK: State-Issued Mobile Telecommunications Licenses, by Auction, Held Not an “Economic Activity” within the Scope of the Sixth VAT Directive
• European Union: Taxation Trends in the EU Show Increase in Overall Tax Burden to 39.6% of GDP in 2005
• Hungary: VAT Treatment of Returned Goods
• The Netherlands: Tax Aspects of Pending Bill Concerning Partnership Law
• Poland: New Rules for Determining Expatriate Tax Residence of Individuals
• Sweden: Freedom of Establishment Principle Does Not Bar Restrictions, Discrimination Concerning Branches in Third Countries
• United Kingdom: Substantive Enactment of the Finance Bill—Implications for Deferred Tax Calculations

2007-32

June 11, 2007

• Germany: ECJ Addresses German Thin-Cap Rules and Compatibility with EU Treaty Principles
• Germany: Business Tax Reform Is Approved; Draft Regulations on Application of Tax Treaties to Partnerships; Other Developments
• Italy: Guidance Concerning Withholding Tax on Dividend Distributions from Italian Subsidiary to Swiss Parent Company
• Luxembourg: New Asset Holding Regime Provides Certain Tax Advantages for Individuals
• The Netherlands: ECJ Advocate General Finds Dutch Withholding Tax Breaches EU Law

Issue

Date

Subject

2007-31

May 31, 2007

• Austria: Free Movement of Capital Principle Does Not Apply to Income from Direct Investments in Non-EU Countries Under the Pre-1994 Rules
• Hungary: Changes to the Rules Concerning the “Minimum Tax”
• Italy: EC Launches Investigation of Incentive Allowing Privatized Banks to Recognize Hidden Gains at Lower Tax Rate
• Spain: New Individual Income Tax Regulations Are Approved

2007-30

May 25, 2007

• Poland: Reminder That Applications for VAT Refund Claims for 2006 Are Due June 30th
• Spain: Changes Under the Protocol to the Income Tax Treaty with Switzerland
• United Kingdom: Restriction of Capital Losses by Reference to Capital Allowances

2007-29

May 15, 2007

• Belgium: Separate Taxation of Exempt Reserves
• European Union: Considerations for Non-Resident Taxpayers in Light of Commission’s Actions to End Discriminatory Taxation of Dividends and Interest Paid to Foreign Pension Funds
• Hungary: May 31st Deadline for Taxpayers Seeking Permission to Carry Forward Losses
• The Netherlands: Summary of Recent Tax Developments

2007-28

May 10, 2007

• Belgium: Developments in Audit, Tax, Legal, Advisory and Accounting Legislation and Practice
• European Union: Direct Taxation: Commission Asks Nine Member States for Information on Discriminatory Taxation of Dividends and Interest Paid to Foreign Pension Funds

2007-27

May 3, 2007

• Czech Republic: Overview of Proposed Tax Reform for 2007-2010
• EU-VAT: Approaching Deadline for Filing Refund Claims for VAT Paid for 2006
• France: ECJ Advocate General Concludes Tax Imposed on Commercial Value of Immovable Property on Non-Residents Violates Principles Under EC Treaty
• Germany: Discussion of Administrative Guidance on Anti-Treaty / Anti-Directive Shopping Provisions

2007-26

May 1, 2007

• Belgium: Deduction for Patent Income; Deductibility of Car Expenses Linked to CO₂ Emissions
• Belgium: New Guidance Concerning Application of VAT to Real Estate Leasing Transactions
• Germany: Administrative Guidance on Anti-Treaty Shopping Provisions; REIT Legislation; Tax Treaty News
• United Kingdom: High Court Addresses When Exemption to Capital Gains Tax “De-Grouping” Tax Rules Applies

Issue

Date

Subject

2007-25

April 19, 2007

• Ireland: Discussions of Reform Provisions in Finance Bill for Financial Services Sector, Debt Factoring and VAT, and Foreign Investment by Individuals
• Romania: Relief for VAT Payments on Imports
• United Kingdom: Capital Allowances Proposals in Budget 2007
• United Kingdom: Corporation Tax and Possible Reform of the Rules Concerning the Taxation of Foreign Profits

2007-24

April 11, 2007

• France: Tax Court Issues Decisions Taking Aim at “Artificial Tax Schemes”
• Luxembourg: Court Decisions Concerning Taxation of Income and Gains from French Real Estate

2007-23

April 5, 2007

• Germany: Monthly Review of Recent Tax Developments
• Malta: New Tax System Becomes Law
• Poland: Court Determines Cash Bonuses Are Not Remuneration for Services Under Poland’s VAT Law
• Romania: April 25th Deadline for Filing VAT Recapitulative Return

Issue

Date

Subject

2007-22

March 30, 2007

• Germany: Discussion of ECJ Actions Concerning the Compatibility of Provisions in German Tax Law to the Freedom of Establishment Under the EU Treaty
• Ireland: European Commission Requests End to Discriminatory Taxation of Income Sourced in the UK
• United Kingdom: Overview of Parliamentary Process: How the Budget Becomes Law

2007-21

March 29, 2007

• Germany: ECJ Finds German Law Restricting the Deductibility of Losses of Write-Downs to Book Value of Shareholdings in Subsidiaries Is Not Compatible with European Community Law
• United Kingdom: Finance Bill 2007 Is Published

2007-20

March 27, 2007

• Germany: Guidance Concerning VAT Issues Related to Holding Corporate Shares and Other Equity Interests
• The Netherlands: Summary of Tax Rates, Contributions for 2007
• United Kingdom: Income Tax Act 2007—Effective Date Is 6 April 2007

2007-19

March 26, 2007

• Austria: European Commission Requests End to Discriminatory Rules on Individual Income Tax
• Germany: European Commission Requests End to Discriminatory Withholding Tax System Concerning Certain Non-Resident Artists and Sportsmen

2007-18

March 23, 2007

• Belgium: European Court of Justice Finds Minimal Tax Base for Non-Residents Only Is Not Compatible with EU Freedom of Establishment
• Ireland: European Commission Requests End to Discriminatory Rules on Tax Treatment of Patent Royalties
• Poland: European Commission Issues Formal Request Concerning Alignment of Electricity Tax System
• United Kingdom: Chancellor’s Budget 2007—Follow-up Commentary

2007-17

March 21, 2007

• United Kingdom: Budget 2007; Tax Card Provides Overview of Tax Rates, Allowances

2007-16

March 16, 2007

• Germany: Government Finalizes Proposal for 2008 Business Tax Reform
• Romania: New Rules Relating to VAT and Excise Duties

2007-15

March 14, 2007

• United Kingdom: Possible Action Steps for Taxpayers Following the ECJ’s Decision in the Thin Cap Group Litigation Case

2007-14

March 13, 2007

• United Kingdom: ECJ Decides “Thin Cap” Rules Can Be Applied Only to Purely Artificial Tax Arrangements

2007-13

March 9, 2007

• Germany: Follow-up Discussion of ECJ Decision in Meilicke Case: Tax Credits on Dividends from Foreign Companies
• The Netherlands: Special Tax Rate on Income in “Patents Box” Applies Retroactively to January 1, 2007

2007-12

March 6, 2007

• Germany: Recent Tax Developments
• Germany: ECJ Concludes Member State Cannot Limit a Dividends-Paid Tax Credit Only to Stock Held in Resident Companies
• Romania: New Administrative Rules Concerning the Assignment of Employees to Romania
• United Kingdom: Update of Recent Tax Developments

Issue

Date

Subject

2007-11

February 22, 2007

• Ireland: Discussions of Tax Provisions in Finance Bill 2007
• Switzerland: Implications of EC’s Decision That Swiss Company Tax Regimes Are a Form of State Aid
• United Kingdom: Review of Court of Appeal’s Decision in Marks & Spencer: Ability of UK Parent Company to Offset Losses from Foreign Subsidiaries Against UK Profit
• United Kingdom: Budget to Be Presented on March 21st

2007-10

February 20, 2007

• Germany: ECJ Addresses Whether Member States Can Limit Deductions of Expenses Incurred in Connection with Taxable Income of Nonresidents
• Spain: Changes to Transfer Tax Rules for Spanish Real Estate Investments

2007-09

February 14, 2007

• Belgium: Report of Recent Tax Developments
• Italy: Retroactive Implementation of EU Interest and Royalties Directive
• Romania: Recent Changes Concerning Permanent Establishments, Depreciation, and Taxation of Dividends and Gains on Security Transactions
• Switzerland: European Commission Requests Changes to Swiss Company Tax Regimes

2007-08

February 7, 2007

• France: Changes to the Profit-Sharing Regime
• Germany: Draft Business Tax Reform for 2008
• The Netherlands: EC Opens Investigation of Part of Proposed Dutch Groepsrentebox Tax Relief Regime, Approves Another Part

2007-07

February 6, 2007

• Denmark: Draft Bill on Danish Corporate Tax Reform
• France: Summary of Certain Recent Tax Changes Affecting Foreign Corporate Investors
• France: ECJ Clarifies Rules on Conversion into Euros Provided for by Community Law
• Germany: Report of Recent Tax Developments

Issue

Date

Subject

2007-06

January 31, 2007

• Denmark: Proposals for Danish Corporate Tax Reform Are Announced
• France: Protocol to Income Tax Treaty with Japan
• Italy: Tax Credit Refunds Claimed by French, UK Entities on Italian Dividends
• The Netherlands: Amendments to Dutch Dividend Withholding Tax Insufficient, According to the European Commission
• Romania: Extended Deadline for Share Capital Increase

2007-05

January 24, 2007

• European Commission: Belgium, Italy, the Netherlands, Portugal, and Spain Are Referred to ECJ for Discriminatory Taxation of Inbound / Outbound Dividends
• Poland: Permanent Establishment Guidance Concerning Warehousing Activities in Poland
• Spain: Update on Income Tax Treaties and Treaty Negotiations
• VAT: KPMG’s Global VAT Brief

2007-04

January 18, 2007

• Finland: Income Tax Treaty with Canada Enters into Force
• Germany: Discussion of Current Environment for Investments in Germany
• Luxembourg: VAT Changes for Investment Funds
• VAT: Discussion of Recent ECJ Cases on Intra-Community Dispatches

2007-03

January 15, 2007

• Germany: Application of CFC Rules Are Suspended in Certain Cases
• Italy: Overview of Tax Changes in Budget 2007
• Romania: New Rules for the Taxation of Micro-Enterprises
• United Kingdom: Overview of REIT Rules

2007-02

January 9, 2007

• Italy: European Commission Requests End Application of Withholding Tax on Dividends Paid to Parent Companies in the Netherlands
• Italy: European Commission Requests Interest and Royalty Directive Be Correctly Implemented
• Luxembourg: New Investment Vehicle for Private Wealth Management
• Portugal: European Commission Requests Changes to Tax Rules Relating to Services Provided by Non-Portuguese Entities
• Spain / Italy: European Commission Closes Infringement Proceedings

2007-01

January 8, 2007

• Belgium: European Commission’s Actions Concerning Alleged Discriminatory Tax Regimes
• Belgium: Summary of New Tax Provisions
• Greece: European Commission Requests End to Discrimination Against Non-Greek Partnerships
• United Kingdom: Evaluating the Changing Relationship Between HM Revenue & Customs and Taxpayers

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