International Tax Europe and Africa December 2024
This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Europe and Africa Regions between 1 December and 31 December 2024.
For a full summary of global tax developments, visit kpmg.com/TaxNewsFlash.
To contact the International Tax Team email internationaltax@kpmg.com.
To register for the International Tax webcasts, click here.
Austria
Austria | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 12 December 2024 | Regulation published on transitional country by country reporting Safe Harbour under Pillar Two. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 12 December 2024 | Input Value Added Tax (VAT) deduction of import VAT for leased machinery (Federal Finance Court decision), other recent direct and indirect tax developments. Read more. |
Belgium
Belgium | |||
Tax legislation approved and regulatory update | Income tax | 23 December 2024 | Guidance on new controlled foreign company rules Two circular letters clarify certain aspects of new controlled foreign company. Read more. |
Tax legislation approved and regulatory update | Income tax | 17 December 2024 | Reformed investment deduction regime effective from 2025. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 06 December 2024 | Changes to value added tax compliance, refund processes, and procedural rules beginning January 1, 2025. Read more. |
Proposed legislation | Tax compliance | 06 December 2024 | Proposed changes to various automatic exchange of information rules (DAC6 and DAC7). Read more. |
Bosnia and Herzegovina
Bosnia and Herzegovina | |||
Tax legislation approved and regulatory update | Income tax | 17 December 2024 | New form for reporting profit tax losses. Read more. |
Proposed legislation | Indirect tax | 17 December 2024 | Proposed value added tax refund on first supply of new residential property passed by lower house of Parliament. Read more. |
Croatia
Croatia | |||
Proposed legislation | Indirect tax | 17 December 2024 | Proposed amendments to value added tax law. Read more. |
Cyprus
Cyprus | |||
Tax legislation approved and regulatory update | Income tax | 20 December 2024 | Changes to framework of register of beneficial owners. Read more. |
Czech Republic
Czech Republic | |||
Administrative and case law | Various tax topics | 10 December 2024 | Denial of mineral oil excise tax refund upheld (Supreme Administrative Court decision). Read more. |
Denmark
Denmark | |||
Proposed legislation | Income tax | 12 December 2024 | Consultation launched on implementation of DAC8. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 09 December 2024 | Digital bookkeeping system capable of handling electronic invoices required as of January 1, 2025. Read more. |
Estonia
Estonia | |||
Tax legislation approved and regulatory update | Various tax topics | 20 December 2024 | Upcoming changes to direct and indirect tax laws. Read more. |
European Union
European Union | |||
Administrative and case law | Income tax | 19 December 2024 | Repayment of State aid and interest following EU Court of Justice annulment of European Commission decision. Read more. |
KPMG publications | Various tax topics | 19 December 2024 | Year-end overview of 2024 tax developments. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 18 December 2024 | Value added tax gap statistics for 2022. Read more. |
Tax legislation approved and regulatory update | Tax compliance | 12 December 2024 | UN Second Committee approves terms of reference for framework convention on international tax cooperation. Read more. |
Tax legislation approved and regulatory update | Tax compliance | 12 December 2024 | Initiative launched to provide standard DAC7 reporting forms for EU countries to share statistical data. Read more. |
Tax legislation approved and regulatory update | Income tax | 12 December 2024 | Council adopts new rules for harmonized withholding tax procedures. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 12 December 2024 | New directive to introduce electronic tax certificate for value added tax exemptions. Read more. |
Administrative and case law | BEPS | 12 December 2024 | European Court of Auditors report on Anti-Tax Avoidance Directive, mandatory disclosure rules (DAC6), and tax dispute resolution directive. Read more. |
Tax legislation approved and regulatory update | Transfer Pricing | 12 December 2024 | Final public country-by-country reporting forms published. Read more. |
Tax legislation approved and regulatory update | Transfer Pricing | 12 December 2024 | Economic and Financial Affairs Council report on various tax initiatives. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 04 December 2024 | Value Added Tax Committee proposes clarification on treatment of sales of “skins” on secondary market. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 04 December 2024 | Value Added Tax Committee proposes clarification on sourcing rules for resales of single-purpose vouchers. Read more. |
Finland
Finland | |||
Administrative and case law | Income tax | 23 December 2024 | Finnish Supreme Administrative Court Upholds First In First Out Method for Calculating Bitcoin Gains. Read more. |
France
France | |||
Tax legislation approved and regulatory update | Income tax | 17 December 2024 | St. Barthélemy companies may belong to French tax group. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 12 December 2024 | Guidance on Pillar Two global minimum tax filing and notification obligations. Read more. |
Georgia
Georgia | |||
Tax legislation approved and regulatory update | Transfer pricing | 17 December 2024 | Amended transfer pricing regulations. Read more. |
Germany
Germany | |||
Tax legislation approved and regulatory update | Tax compliance | 20 December 2024 | Updated common reporting standards guidance. Read more. |
Administrative and case law | Income tax | 12 December 2024 | German Fiscal Court decision on CFC rules – Functional Approach / Violation of the free movement of capital in third-country cases. Read more. |
Proposed legislation | BEPS Pillar 2 | 12 December 2024 | Revised draft law proposing amendments to Pillar Two law. Read more. |
Tax legislation approved and regulatory update | Tax compliance | 04 December 2024 | Guidance on further extension of temporary relief for U.S. Taxpayer Identification Number codes. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 02 December 2024 | Value added tax (VAT)-related changes in Annual Tax Act 2024, other VAT developments. Read more. |
Gibraltar
Gibraltar | |||
Proposed legislation | Income tax | 16 December 2024 | Draft legislation on new restriction on the use of tax losses in relation regulated financial services and licensable gambling activities. Read more. |
Proposed legislation | BEPS Pillar 2 | 16 December 2024 | Draft legislation implementing Pillar Two global minimum tax rules. Read more. |
Proposed legislation | BEPS Pillar 2 | 12 December 2024 | Draft Pillar Two legislation published. Read more. |
Greece
Greece | |||
Tax legislation approved and regulatory update | Various tax topics | 10 December 2024 | New law introduces tax incentives for innovation and corporate transformations. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 03 December 2024 | Extended deadline for implementation of electronic delivery notes and digital tracking of goods shipment. Read more. |
Guernsey
Guernsey | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 12 December 2024 | Regulation to implemented Pillar Two rules enacted. Read more. |
Tax legislation approved and regulatory update | Tax compliance | 05 December 2024 | Channel Islands: Guidance on further extension of temporary relief for U.S. tax identification number codes (Guernsey). Read more. |
Hungary
Hungary | |||
Tax legislation approved and regulatory update | Income tax | 19 December 2024 | Guidance amending extra-profit taxes. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 19 December 2024 | Changes to autumn tax package, including Pillar Two rules, agreed by Parliament. Read more. |
Ireland
Ireland | |||
Tax legislation approved and regulatory update | Various tax topics | 12 December 2024 | Finance Act 2024 enacted. Read more. |
Isle of man
Isle of Man | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 12 December 2024 | Pillar Two law enacted. Read more. |
Italy
Italy | |||
Tax legislation approved and regulatory update | Indirect tax | 20 December 2024 | Guidance on new rules for fiscal representatives of non-EU companies. Read more. |
Tax legislation approved and regulatory update | Tax compliance | 18 December 2024 | Guidance on documentation required for special penalty protection for hybrid mismatches Guidance clarifies contents, deadlines, and methodology. Read more. |
Tax legislation approved and regulatory update | Income tax | 12 December 2024 | Guidance on permanent establishment investment management exemption published. Read more. |
Administrative and case law | Income tax | 12 December 2024 | EU Court of Justice referral on the compatibility of the Italian tax consolidation regime with EU law. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 10 December 2024 | New value added tax place of supply rules for virtual events. Read more. |
KPMG publications | Transfer pricing | 04 December 2024 | KPMG article: Managing Italian transfer pricing audits. Read more. |
Jersey
Jersey | |||
Proposed legislation | Tax compliance | 10 December 2024 | Channel Islands: Consultation on cryptoasset reporting framework and common reporting standards amendments (Jersey). Read more. |
Liechtenstein
Liechtenstein | |||
Tax legislation approved and regulatory update | Tax compliance | 11 December 2024 | Registration of trustee-documented trusts for common reporting standards purposes. Read more. |
Lithuania
Lithuania | |||
Tax legislation approved and regulatory update | Transfer pricing | 06 December 2024 | New country-by-country reporting notification requirements. Read more. |
Luxembourg
Luxembourg | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 20 December 2024 | Overview of tax measures for 2025, including amended Pillar Two law. Read more. |
Administrative and case law | Indirect tax | 18 December 2024 | Guidance on court decision on application of value added tax to remuneration received by board of directors member. Read more. |
Tax legislation approved and regulatory update | Income tax | 17 December 2024 | Tax relief package passed by Parliament includes tax cuts for both corporate and individual taxpayers. Read more. |
Malta
Malta | |||
Proposed legislation | Various tax topics | 04 December 2024 | Bill implementing some measures in 2025 budget. Read more. |
Moldova
Moldova | |||
Tax legislation approved and regulatory update | Various tax topics | 02 December 2024 | Guidance on various transfer pricing, value added tax, and income tax issues. Read more. |
Netherlands
Netherlands | |||
Proposed legislation | BEPS Pillar 2 | 18 December 2024 | Upper house passes entire 2025 Tax Plan package, including amendments to Pillar Two rules. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 16 December 2024 | Amended guidelines on recovery of value added tax on costs relating to share transactions. Read more. |
Tax legislation approved and regulatory update | Income tax | 11 December 2024 | Guidance on application of new framework for determining tax characterization of foreign legal forms. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 1 | 05 December 2024 | Guidance on how Pillar One Amount B will affect domestic taxpayers. Read more. |
Proposed legislation | Tax compliance | 04 December 2024 | Draft bill implementing directive on tax transparency rules for cryptoasset service providers (DAC8). Read more. |
Nigeria
Nigeria | |||
Proposed legislation | Income tax | 18 December 2024 | Proposed tax incentives for oil and gas sector. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 09 December 2024 | Guidelines on advance pricing agreements. Read more. |
Norway
Norway | |||
Tax legislation approved and regulatory update | Income tax | 18 December 2024 | New legislation mandates registration of beneficial owners. Read more. |
Proposed legislation | Income tax | 12 December 2024 | Consultation launched on draft legislation to introduce reporting obligations for crypto-asset service providers. Read more. |
Tax legislation approved and regulatory update | Income tax | 12 December 2024 | Updated standard audit file for tax reporting standard. Read more. |
OECD
OECD | |||
Tax legislation approved and regulatory update | BEPS Pillar 2 | 19 December 2024 | Fact sheets and pricing tool for implementation of Amount B simplified approach. Read more. |
Tax legislation approved and regulatory update | BEPS | 17 December 2024 | Exchange of information on tax rulings under Base Erosion Profit Shifting Action 5. Read more. |
Tax legislation approved and regulatory update | Various tax topics | 12 December 2024 | G20 Rio de Janeiro leaders’ declaration published. Read more. |
KPMG publications | Transfer pricing | 10 December 2024 | KPMG article: OECD advance pricing agreement statistics for 2023. Read more. |
Tax legislation approved and regulatory update | Transfer pricing | 05 December 2024 | Updated International Compliance Assurance Programme (ICAP) frequently asked questions (December 2024). Read more. |
KPMG publications | Transfer pricing | 04 December 2024 | KPMG report: Update on future of Base Erosion Profit Shifting guidance from Organisation for Economic Cooperation and Development (OECD). Read more. |
Poland
Poland | |||
Administrative and case law | Income tax | 19 December 2024 | Refund of income tax paid by Maltese subsidiary considered income (Supreme Administrative Court decision). Read more. |
Tax legislation approved and regulatory update | Income tax | 19 December 2024 | Exemption from requirement to electronically submit asset data. Read more. |
Proposed legislation | Income tax | 12 December 2024 | Draft regulation to update national list of tax haven jurisdictions. Read more. |
Tax legislation approved and regulatory update | Income tax | 12 December 2024 | General ruling on the requirement of effective taxation of interest and royalties for withholding tax purposes. Read more. |
Tax legislation approved and regulatory update | Income tax | 12 December 2024 | General ruling on the requirement of effective taxation of dividends for withholding tax purposes. Read more. |
Administrative and case law | Income tax | 05 December 2024 | Minister of Finance issues ruling on tax exemptions for interest and royalties. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 02 December 2024 | Real estate tax and value added tax amendments. Read more. |
Administrative and case law | Various tax topics | 02 December 2024 | Depreciation deductions on assets acquired by inheritance, reimbursed taxi expenses, electric vehicle recharging services (court decisions). Read more. |
Portugal
Portugal | |||
Administrative and case law | Transfer pricing | 30 December 2024 | Relatedness determined on transaction date, improper rejection of transfer pricing method (Supreme Administrative Court decisions). Read more. |
Tax legislation approved and regulatory update | Various tax topics | 30 December 2024 | Direct and indirect tax measures in 2025 budget bill. Read more. |
Romania
Romania | |||
Administrative and case law | Various tax topics | 12 December 2024 | Compatibility of windfall tax on energy producers with EU law. Read more. |
Saudi Arabia
Saudi Arabia | |||
Tax legislation approved and regulatory update | Indirect tax | 03 December 2024 | E-invoicing requirement extended to 18th group of taxpayers from August 31, 2025. Read more. |
Serbia
Serbia | |||
Tax legislation approved and regulatory update | Indirect tax | 23 December 2024 | Law on electronic goods delivery notes enacted. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 05 December 2024 | Value added tax amendments enacted. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 05 December 2024 | Amendments to e-invoicing law enacted. Read more. |
Tax legislation approved and regulatory update | Income tax | 02 December 2024 | Corporate income tax law amendments passed by Parliament. Read more. |
Slovakia
Slovakia | |||
Proposed legislation | Income tax | 12 December 2024 | Consultation on draft bill to implement DAC8. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 12 December 2024 | Amendments to minimum taxation rules (under Pillar Two) adopted by Parliament. Read more. |
Tax legislation approved and regulatory update | Indirect tax | 09 December 2024 | Amendment to value added tax law approved by Parliament. Read more. |
Tax legislation approved and regulatory update | Various tax topics | 09 December 2024 | Amendment to Financial Transactions Tax Act approved by Parliament. Read more. |
Slovenia
Slovenia | |||
Tax legislation approved and regulatory update | Income tax | 12 December 2024 | Act on amendments to the income tax act published. Read more. |
South Africa
South Africa | |||
Tax legislation approved and regulatory update | Income tax | 09 December 2024 | Discussion document on taxation of collective investment schemes. Read more. |
Tax legislation approved and regulatory update | Tax compliance | 05 December 2024 | Updated automatic exchange of information guidance. Read more. |
Proposed legislation | Indirect tax | 02 December 2024 | Proposed environmental tax amendments. Read more. |
Spain
Spain | |||
Tax legislation approved and regulatory update | Indirect tax | 31 December 2024 | New tax on financial institutions, new excise duty on tobacco products, measures to combat value added tax fraud with respect to fuels. Read more. |
Proposed legislation | BEPS Pillar 2 | 12 December 2024 | Minimum taxation rules (under Pillar Two) submitted to Senate. Read more. |
Tax legislation approved and regulatory update | BEPS Pillar 2 | 04 December 2024 | Legislation implementing Pillar Two global minimum tax passed by lower house of Parliament. Read more. |
Tax legislation approved and regulatory update | Income tax | 02 December 2024 | Legislation introducing complementary tax for large groups, second package of relief for taxpayers affected by flooding Legislation introducing complementary tax passed by lower house of Parliament and additional tax relief. Read more. |
Sweden
Sweden | |||
Administrative and case law | Income tax | 05 December 2024 | Winter car testing activities do not create permanent establishment, tax authority’s appeal of lower court decision denied (Supreme Administrative Court decision). Read more. |
Switzerland
Switzerland | |||
Administrative and case law | Treaties | 12 December 2024 | Federal Supreme Court decision on the beneficial ownership concept (Double Tax Treaty). Read more. |
United Kingdom
United Kingdom | |||
Administrative and case law | Income tax | 19 December 2024 | Anti-abuse rule applied to deny “refreshed” losses, taxpayer’s claim qualified under small and medium-sized enterprise research and development regime. Read more. |
Proposed legislation | Income tax | 19 December 2024 | Tax measures in draft budgets for Scotland and Wales. Read more. |
Tax legislation approved and regulatory update | Income tax | 12 December 2024 | New guidelines on patent box computations. Read more. |
Tax legislation approved and regulatory update | Income tax | 12 December 2024 | Guidance published on top-up tax payments and new online service for changing the filing entity. Read more. |
