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This e-newsletter gives you an overview of international corporate tax developments being reported globally by KPMG member firms in the Europe and Africa regions between 1 June and 30 June 2013

Algeria Hungary The Netherlands Spain
Austria Ireland Nigeria Sweden
Belgium Italy OECD Switzerland
Bulgaria Kenya Poland Tanzania
Czech Republic Kosovo Portugal Uganda
European Union Luxembourg Rwanda Ukraine
Finland Macedonia Serbia United Kingdom
France Malta Slovakia  
Germany Montenegro Slovenia  

For a full summary of global tax developments, visit kpmg.com/TaxNewsFlash.

To contact the Global International Corporate Tax Group, email go-fmglobalict@kpmg.com.

  Tax area concerned Relevant date/case reference Description of measures and publication link
(Considerations in italic where necessary)
Algeria
KPMG publications Investing or conducting business in Algeria 2013 KPMG in Algeria has produced a 2013 guide for entities investing in or conducting business in Algeria.
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Austria
Administrative and case law VAT Finanzamt Freistadt Rohrbach Urfahr v Unabhängiger Finanzsenat Außenstelle Linz, C-219/12 (20 June 2013) The Court of Justice of the European Union (CJEU) held that an individual/operator of a private photovoltaic system on the roof of his house may be entitled to deduct input VAT.
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Belgium
Tax legislation adopted and regulatory update Corporate income tax/ VAT 2013/2014/2015 A new law containing tax and financial measures was published in the Belgian Official Gazette. Among the corporate income tax provisions in the new law are measures concerning:
a patent income deduction for SMEs (effective in assessment year 2014)
an increase in the R&D exemption (to 80 percent) under the wage withholding tax for businesses paying wages to individuals holding a “specific degree” and employed in research projects (effective for the wage withholding tax due from 1 July 2013)
clarification when the “secret commissions tax” does not apply
a change to the calculation of the notional interest deduction (with the rate for assessment year 2014 being 2.742 percent)
mandatory use of the BIZTAX system with respect to corporate income tax, legal entities income tax, and non-resident (corporate) income tax (effective from assessment year 2015, but subject to an earlier effective date by Royal Decree)
a change to the tax shelter regime for audiovisual works
a change to several levies on the financial sector.
The law also contains individual income tax changes and measures concerning tax procedures.
Among VAT law revisions is a measure that effectively implements into Belgian law the holding of a judgment of the European Court of Justice (the Vlaamse Oliemaatschappij case) regarding warehousing, and providing that persons of good faith or who prove that they have made no mistakes or have not been negligent are released from joint liability (effective 8 July 2013).
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Bulgaria
KPMG publications Various taxes 2013 KPMG in Bulgaria has prepared a “tax card” that provides an easy-to-read overview of the tax system in Bulgaria for 2013.
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Other Customs June 2013 The European Commission this week referred Bulgaria to the CJEU for failing to repeal certain customs duty and tax relief provisions under an agreement between Bulgaria and the United States.
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Czech Republic
Administrative and case law Transfer pricing No. 1 Afs 99/2012-52 (13 March 2013) The Supreme Administrative Court (Nejvyšší správní soud) addressed burden-of-proof issues when a taxpayer filed amended tax returns that revised the amounts of tax based on transfer pricing revisions.
Furthermore the Court addressed when the cost-plus method can be applied to determine transfer prices between related parties.
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KPMG publications Various taxes June 2013 This month’s report from the KPMG member firm in the Czech Republic includes issues such as the liability for VAT, application of the solidarity tax increase to foreign-sourced income, and a court case on transfer pricing.
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European Union
Tax legislation adopted and regulatory update Customs 27 June 2013 The European Union’s Taxation and Customs Union on 27 June announced that the ports of Barcelona, Valencia, and Hong Kong will be included as participants of the "smart and secure trade lanes" (SSTL) pilot project between the EU and China.
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Extractive and logging sector/
reporting requirements
June 2013 The European Parliament approved country-by-country reporting requirements for companies active in the large extractive and logging industries and that are based in the EU or listed on EU regulated markets.
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Financial sector/
reporting requirements
1 January 2015 The EU Council on 20 June 2013 approved stricter capital requirements for banks and investment firms, and country-by-country reporting of tax payments by certain EU financial institutions.
Unless the reporting requirements are deferred by the European Commission, the country-by-country tax payment reporting requirements would apply from 1 January 2015.
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Banks and investments firms 1 January 2014 The EU Council on 20 June 2013 approved stricter capital requirements for banks and investment firms. The new measures (the “CRD 4 package”) would:
enshrine in EU law a comprehensive set of international standards known as Basel III
increase financial stability, by making banks more resilient in the face of financial shocks
encourage sustainable economic growth, by introducing harmonized single-market rules and also providing credit for the “real economy”.
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Tax evasion 2013 The European Commission this week requested that five EU Member States—Belgium, Greece, Finland (the province of Åland), Italy, and Poland—adopt (and transpose into each country’s national laws) rules to increase transparency, improve tax information exchange, and tighten cross-border cooperation.
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Proposal legislation VAT June 2013 The EU is in the process of fundamentally modifying the structure of its VAT to harmonize the imposition of the VAT with the operation of business in a technology-driven age.
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VAT/exchange of information June 2013 The EU Council of Ministers agreed to a draft regulation that would amend the VAT rules on the place of supply of certain services—i.e., telecommunications, broadcasting and electronic services, real estate services, and the distribution of tickets for entry to cultural, artistic, sporting, scientific, educational, entertainment and similar events.
Also, the EU Council—in light of the European Commission proposal for administrative cooperation in the field of direct taxation and for extending the scope for mandatory automatic exchange of information—called for a working group to start technical work on the proposal.
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Exchange of information 12 June 2013 The European Commission proposed extending the automatic exchange of information between EU tax administrations to dividends, capital gains, and other financial income as part of the efforts to counter tax evasion.
The proposal would strengthen and enlarge the scope of the EU Savings Tax Directive and would revise the Administrative Cooperation Directive so that automatic information exchange will also apply to dividends, capital gains, other financial income and account balances.
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  12 June 2013 The European Commission proposed to accelerate the scope of automatic information exchange within the EU to information on dividends, capital gains, and any other income from assets and financial accounts held by EU individuals.
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  1 January 2015 The European Commission proposed extending the automatic exchange of information between EU Member States to dividends, capital gains, and all other forms of financial income and account balances—what is referred to as a “FATCA-type” proposal for the EU. Under the proposal, information would be exchanged as of 1 January 2015 in respect to tax periods as from 1 January 2014.
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Finland
Proposed legislation Corporate and capital income taxation 2014-2017 Under the proposed plan of Finland’s government for 2014–2017, changes proposed to corporate and capital income taxation include:
a reduction in the rate of corporate income tax to 20 percent, effective for the 2014 tax year
repeal of tax incentives enacted for 2013-2015 concerning additional deductions for R&D costs and additional depreciation on production-related investments, with repeal to be effective at the end of 2014
repeal of a deduction currently allowed companies for up to 50 percent of their representation costs
rules requiring itemization of depreciation of long-term investments
limitation of company’s right to deduction interest expenses
changes to the taxation of dividends received by individuals, including a proposal that 85 percent of dividends received from listed companies being taxed as capital income
introduction of a windfall tax in 2014
changes to earned income and to the inheritance and gift tax regimes.
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Administrative and case law VAT European Commission v. Finland, C-75/11 (25 April 2013) The CJEU rejected, in part, the EC’s infringement proceedings against the Finnish VAT group registration rules that apply only for the financial and insurance sectors.
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France
Tax legislation adopted and regulatory update Tax evasion/ Transfer pricing June 2013 The French tax authorities’ report on tax evasion and transfer pricing compares France’s transfer pricing system with the systems in Canada, Germany, the Netherlands, the United Kingdom, and the United States. The report concludes that France’s transfer pricing rules are not fully aligned with these international counterparts.
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Proposed legislation Transfer pricing June 2013 Legislation currently pending in France would amend the transfer pricing documentation rules, to require taxpayers to submit and file their transfer pricing documentation reports at the same time they file their annual corporate income tax returns.
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Tax evasion June 2013 The chairman of the French Senate’s finance committee on 26 June 2013 stated that proposed legislation would be introduced to counter tax evasion and fraud by large multinational enterprises. The proposal would:
provide that a transfer of functions and risks outside France would be viewed and treated as an “abnormal” transfer of profits abroad, unless the taxpayer could rebut this presumption (thus, the burden of proof would shift to the taxpayer)
strengthen the anti-abuse law procedure by expanding its scope to transactions found to be essentially “tax driven” (as opposed to the current law, which looks at exclusively tax driven constructions).
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Administrative and case law Special charge on electronic communications Commission v. France, C-485/11 (27 June 2013) France imposes a special charge on electronic communications operators, with the charge being levied on the amount of subscription charges and other sums paid by users to operators for the provision of electronic communications services. The CJEU found: (1) that the administrative charges covered by the directive represent remuneration; and (2) that the only purpose of the charges is to cover the administrative costs incurred in the issue, management, control and enforcement of the general authorisation plan for electronic communications. Therefore, the CJEU concluded that the Authorisation Directive does not restrict the authority of EU Member States to impose non-administrative charges in respect of providing electronic communication services.
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Germany
Tax legislation and regulatory update Tax record retention June 2013 A “conciliation committee” will meet in early June 2013 to address differences in proposals of the lower house (Bundestag) and upper house (Bundesrat) concerning changes to the rules for tax record retention.
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VAT June 2013 Recent decisions concerning VAT from the CJEU concern:
availability of VAT deductions when invoices are improper or inaccurate
correction of VAT that is invoiced improperly.
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Real estate transfer tax and dividend taxation June 2013 The upper and lower houses of the German Parliament in June 2013 approved tax legislation that is now expected to be enacted. In particular, legislative changes or provisions concerning the following items could affect multinationals investing in Germany.
real estate transfer tax blocker structures
extension of the real estate transfer tax group exemption
extension of the correspondent taxation in the context of dividend taxation
transposition of OECD transfer pricing approach into German law
treaty override with respect to the taxation of income derived by a foreign partner from relationships with a German partnership (e.g. licensing, granting of loans, etc.).
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Hungary
Tax legislation and regulatory update Transfer pricing 18 June 2013 Hungary’s Ministry of Finance this week issued guidance (decree 20/2013, 18 June 2013) that clarifies the transfer pricing documentation rules.
To reduce the administrative burden, the definitions of transactions for which taxpayers are not required to prepare transfer pricing documentation are modified and defined more precisely. The new guidance also modifies the range of accepted arm’s length profit margins for low value-added intercompany services.
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Ireland
KPMG publications Conducting business in China 2013 KPMG in Ireland has prepared a presentation that looks at issues that Irish and other western country businesses may encounter in doing business in China.
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Italy
Tax legislation and regulatory update VAT 1 October 2013 An increase in the rate of VAT in Italy is scheduled to be effective 1 October 2013. The standard VAT rate will be 22 percent (i.e., increased by 1 percent from the current standard rate of VAT of 21 percent).
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Kenya
Proposed legislation Budget 2013/2014 Tax proposals in the 2013/14 budget in Kenya include provisions that would:
impose withholding tax on gains from gaming and betting
impose tax on capital gains
harmonize the tax regimes and tax procedures
introduce a VAT regime
revise the excise tax and customs tariff rates for certain goods
recognize that group life insurance and group personal accident insurance premiums are not taxable income to employees
extend to five years (from three years) the exemption for certain income paid to persons with disabilities.
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Kosovo
KPMG publications Various taxes 2013 KPMG in Kosovo has prepared a “tax card” that provides an easy-to-read overview of the tax system in Kosovo for 2013.
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Luxembourg
Proposed legislation Exchange of information 2013 The European Commission proposed extending the automatic exchange of information between EU Member States to dividends, capital gains, and all other forms of financial income and account balances—what is referred to as a “FATCA-type” proposal for the EU.
The government of Luxembourg has not yet officially responded to the proposal. However, any extension of the scope of the EU Administrative Cooperation Directive requires unanimity. If the proposal were to be adopted, it would present a challenge for the Luxembourg financial sector. Yet, given the anticipated future signing of a FATCA agreement between Luxembourg and the United States, it appears that the general trend would support the EC proposal.
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Macedonia
KPMG publications Various taxes 2013 KPMG in Macedonia has prepared a “tax card” that provides an easy-to-read overview of the tax system in Macedonia for 2013.
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Malta
Administrative and case law Excise tax Vodafone Malta Ltd. v. Avukat Generali, C-71/12 (27 June 2013) The CJEU issued a judgment finding that the Authorisation Directive does not preclude an excise duty (tax) imposed on mobile telephony services in Malta.  
The CJEU concluded that the trigger for the excise duty is linked not to a general authorisation procedure for access to the electronic telecommunications services market, but to the use of mobile telephony services provided by operators and is borne by the user of such services. The CJEU found this did not constitute an administrative charge within the meaning of the directive.
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Montenegro
Tax legislation adopted and regulatory update VAT 30 June 2013 The “general” rate of VAT in Montenegro increases to 19 percent (up from the current VAT rate of 17 percent), effective 30 June 2013.
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The Netherlands
Proposed legislation Pension plan 2013 Under a to-be-drafted proposal, it would be possible to activate an early retirement plan for years before the individual reaches the state pension age without triggering the 52 percent penalty levy.
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Administrative and case law VAT Staatssecretaris van Financiën v. X BV, C-651/11 (30 May 2013) The CJEU concluded that for VAT purposes, the sale of a participation is not simply to be regarded as a transfer of a “going concern” whereby the assets and liabilities are continued.
When the assets and liabilities of a company are sold to a purchaser who continues the business (i.e., a “transfer of a going concern”), no VAT is due pursuant to Article 37d of the Dutch VAT law. The input VAT on services purchased for the transfer is recoverable by the vendor, insofar as the business operations or the transferred business gives an entitlement thereto.
When shares in a company that operates a business are transferred, the VAT exemption of Article 11(1)(i) of the Dutch VAT law may apply. The application of this exemption means that the recovery of input VAT on the transaction costs may, in principle, be limited for the vendor.
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Treaties DTT June 2013 A Protocol to amend the Netherlands-Norway income tax treaty (1990) was signed in late April 2013. Once ratified by both countries, the Protocol will enter into force.
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31 May 2013 Representatives of the governments of the Netherlands and China on 31 May 2013 signed a new income tax treaty.
The new treaty, once ratified, would replace the existing income tax treaty (1987) and  would update a number of issues, including:
Allowing participation dividends to be distributed to a parent company resident in the other country at a reduced rate of 5 percent
Focusing on the prevention of tax avoidance, under anti-abuse provisions and a new provision on the exchange of information between China and the Netherlands.
The treaty will apply to income received on or after January 1 of the year following the year in which all the ratification formalities between China and the Netherlands have been finalized. It is expected that the effective date of the treaty will be 1 January 2015 at the earliest.
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Nigeria
Other Government measures 2013 Reappointments of commissioners to Nigeria’s tax dispute tribunal have been approved, and with this action, it is anticipated that the backlog of tax hearings may now be addressed and cleared.
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OECD
Tax legislation adopted and regulatory update Base erosion and profit shifting 2013 The OECD at a 29-30 May 2013 ministerial council meeting in Paris adopted a declaration on base erosion and profit shifting (BEPS).The BEPS declaration emphasizes the “pressing need” for governments to work together to develop methods of addressing asymmetries in domestic and international tax rules that can result in very low effective taxation.
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Transfer Pricing May 2013 The OECD on 21 May 2013 reported that the OECD Council had approved a revision concerning safe harbours contained in the OECD Transfer Pricing Guidelines.
The safe harbour revision includes new guidance that:
provides opportunities for countries to offer relief from compliance burdens and greater certainty for situations involving smaller taxpayers or less complex transactions
provides a basis for countries—especially developing countries—to design a transfer pricing compliance environment that makes optimal use of the limited resources available.
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Proposed legislation Employment termination-related payments September 2013 The OECD this month released a “discussion draft” of proposed model treaty provisions concerning the tax treatment of certain payments made to persons following the termination of their employment. Comments on the discussion draft are requested before 13 September 2013, so that they may be considered at a September 2013 meeting.
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Poland
Tax legislation adopted and regulatory update R&D 1 -30 July 2013 An application round for those seeking government grants with respect to financing R&D projects opens 1 July 2013 and ends 30 July 2013. Grants will be made available for industrial research and high-tech research projects.
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Proposed legislation Advanced pricing agreements 2013 Poland’s Ministry of Finance has proposed changes that, if enacted, would amend the provisions concerning advance pricing agreements (APAs). Among the proposed changes are measures that would:
expand the scope of transactions that could be subject to APAs (by repealing current law provision that limits an APA to one type of transaction between the related parties)
revise the required items to be include in an APA, thus allowing the APA to be tailored to meet a taxpayer’s particular transaction
allow greater flexibility for the tax authorities to apply a different method if the method proposed by the taxpayer cannot be applied
require the tax authorities to indicate in an APA annulment decision what were the obstacles to the APA
provide guidance for expedited renewal of an APA when there are no significant changes to the conditions of the existing APA
allow for retroactive application of an APA (i.e., retroactively from the date when the APA application is filed).
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Treaties DTT 21 June 2013 The lower chamber (Sejm) of Poland’s Parliament on 21 June 2013, approved legislation for ratification of a new income tax treaty* between the United States and Poland.
The next step in the ratification process in Poland is for the ratification legislation to be considered by the upper chamber and, if approved, to be submitted to the president of Poland for signature.
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Portugal
Tax legislation adopted and regulatory update Incentives June 2013 In Portugal, a package of tax incentives includes measures that:
introduce an “extraordinary” tax credit for investments, with a tax deduction equal to 20 percent of the amounts invested between 1 June and 31 December 2013 (up to a maximum of €5 million), and also provide a carryforward of unused amounts of the tax credit for five subsequent tax periods
expand to 2017 (from 2013) the time for applying for application of the Regime Fiscal de Apoio ao Investimento (RFAI), and increase the maximum tax deduction under the RFAI regime to 50 percent (from 25 percent) of the amount of corporate income tax assessed
reduce to €3 million (from the current minimum investment threshold of €5 million) for investments in order to invoke the tax contractual incentives regime
reduce the maximum response time for “urgent tax binding rulings” by 30 days
create a tax office to provide support for international investors.
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Rwanda
Proposed legislation Budget 2013 The Rwanda government has released its 2013 budget proposals, including various tax measures, among which are the following provisions:
introduction of a royalty tax regime for minerals, with rates of 4 percent of the value of extracted minerals on basic metals and 6 percent on precious metals and precious stones
an increase to 25 percent in the rate of the customs import duties on certain telecommunication equipment and construction material (up from 0 percent and up from a range between 0 percent-10 percent, respectively)
a VAT exemption for construction material not locally available
a reduction in tariff rates for grains, wheat products, road tractors for semi-trailers, buses, and other motor vehicles
introduction of various electronic tax and customs procedure applications, including e-filing, e-payment, electronic cargo tracking equipment, mobile technology in payment and filing of taxes, and electronic billing machines (under the new VAT law).
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Serbia
Tax legislation adopted and regulatory update Excise tax 30 May 2013 A new law in Serbia introduced an excise tax on biofuels and bioliquids, with an effective date of 30 May 2013. Depending on the intended use of the biofuels and bioliquids, the buyer may be entitled to a refund of a portion of the excise taxes paid. The law includes measures concerning when manufacturers, importers, wholesalers and/or retailers must remit the taxes, and rules when the products are stored in a customs warehouse.
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Slovakia
Administrative and case law VAT 8Sžf/9/2012 The Slovak Supreme Court held that if the tax authority proves that the goods in question could not have been delivered by the supplier as identified in the invoices, the burden of proof then shifts to the taxpayer who then must (1) prove that the conclusions of the tax authority are incorrect, or (2) identify the actual supplier based on new evidence.
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Slovenia
Tax legislation adopted and regulatory update VAT 1 July 2013 The rates of VAT in Slovenia will increase effective 1 July 2013.
the “standard” VAT rate will increase to 22 percent(from the current 20 percent rate).
the “reduced” VAT rate will increase to 9.5 percent (from the current 8.5 percent rate).
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Proposed legislation Corporate income tax/ Thin capitalization rules 2013 There are proposals in Slovenia to amend a scheduled phase-down reduction in the rate of corporate income tax, and to amend the thin capitalization rules.
The corporate income tax rate, which was 18 percent for the 2012 tax year,  currently is to be reduced according to this schedule:
17 percent for 2013
16 percent for 2014
15 percent for 2015 and later tax years
Currently, the thin capitalization rules apply to loans granted by a shareholder who, at any time during the tax period, directly or indirectly owns at least 25 percent of the shares in the equity capital or voting rights of the taxpayer company, provided that at any time during the tax period the shareholder loans exceed the prescribed debt / equity ratio. The proposed change would extend application of the thin capitalization rules to loans granted by a related company (i.e., with respect to loans granted by a shareholder or family members who directly or indirectly own at least 25 percent of the shares in the equity capital or voting rights of the lending company and the taxpayer).
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Spain
Tax legislation adopted and regulatory update VAT 2014 While Royal Decree 1615/2011 provided that all VAT payers in Spain were to file form 340 beginning in 2014, the deputy director of indirect taxes of the Spanish tax authority today announced that this rule will be postponed.
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Sweden
Administrative and case law Investment funds June 2013 The Swedish Supreme Administrative Court issued several decisions concerning the taxation of Swedish and foreign investment funds and pension funds, including the tax treatment of Luxembourg SICAVs.
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Switzerland
Treaties DTT 1 January 2013 Tax agreements between Switzerland and the United Kingdom and between Switzerland and Austria entered into force 1 January 2013. These new tax agreements aim to allow for proper taxation of assets held in Switzerland by investors taxable in the UK or Austria without invading their financial privacy.
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Tanzania
Proposed legislation Budget 2013 Tax proposals in the 2013 budget in Tanzania include provisions that would:
reduce the minimum tax rate for individuals from 14 percent to 13 percent
reduce the “skills and development levy” (a contribution paid by employers) from 6 percent to 5 percent
repeal a withholding tax exemption that currently applies with respect to aircraft lease rental payments made to a non-resident lessor by a Tanzanian air transport operator
introduce a petroleum levy and increase excise duty rates imposed on motor vehicles
impose an 18 percent rate of VAT on tourist-related services
provide VAT relief for inputs with respect to textile manufacturing
increase excise duty taxes on certain beverages
limit the import duty-free treatment to 75 percent (instead of 100 percent) for companies registered with the Tanzania Investment Centre.
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Uganda
Proposed legislation Budget 2013 Uganda’s budget for 2013 includes tax proposals that would:
impose a VAT rate of 18 percent on water, on certain hotel accommodations outside Kampala district, and on wheat and flour (previously exempt from VAT)
increase the excise tax / duty rate on undenatured spirits, petrol and diesel, kerosene, cigarettes, promotional activities, and certain money transfers
increase the stamp duty on third-party insurance policies coverage for motor vehicles
repeal the 0 percent import duty on raw materials and inputs
measures allowing the tax authorities to have access to taxpayer financial records from financial institutions, to aid in tax audits
increased number of withholding tax agents, to allow for greater tax compliance
The authorities also plan to review the value chain of the petroleum and mining sectors during 2013 and 2014.
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Ukraine
Tax legislation adopted and regulatory update Advanced pricing agreements June 2013 An order from the Ukraine Ministry of Finance approves an information form concerning related parties, which large taxpayers are to file along with an APA application.
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Foreign currency transactions 19 November 2013 Temporary measures in Ukraine concerning transactions involving foreign currency are effective until 19 November 2013. The measures were adopted 14 May 2013.
The provisions shorten the settlement period to 90 calendar days (from 180 days) for export and import transactions, and impose requirements to convert foreign currency (i.e., sell revenue) received on the sale of goods under external contracts.
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United Kingdom
Tax legislation adopted and regulatory update Tax avoidance June 2013 The Public Accounts Committee (PAC) of the UK Parliament has published a report entitled Tax Avoidance - Google.
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Proposed legislation Financial instruments and bank taxation July/August 2013 The UK government published several consultation documents and draft guidance that would amend: (1) the corporate tax rules on loan relationships and derivative contracts; (2) the rules relating to the code of practice on taxation for banks; (3) the rules concerning the foreign exchange market; and (4) the CFC regime.
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Financial instruments/
CFC
June 2013 The UK government published a consultation document under a proposal to amend the corporate tax rules on corporate debt / loan relationships and derivative contracts under future legislation (2014 and 2015 Finance Bills).
HM Revenue & Customs has published updated draft guidance concerning the new CFC regime, with new chapters on clearance procedures and the interaction with the branch exemption.
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Tax transparency June 2013 The UK government, followed by the Crown Dependencies and Overseas Territories, in connection with this month’s G-8 summit, announced "action plans" to promote tax transparency. The action plans will provide concrete steps intended to clarify and implement standards on beneficial ownership.
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FATCA 6 September 2013 The UK government published a discussion document seeking comments concerning the effects of proposed intergovernmental agreements (IGAs) under the U.S. FATCA regime on UK financial institutions, and how the agreements would to be implemented in the UK―including the Crown Dependencies and overseas territories―in terms of regulations and guidance. The discussion period is open through 6 September 2013.
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