2022-05-24-KPMG_Global-E-News_from_the_EU_Tax_Centre_13页_320kb

报告摘要

CJEU ruled French "précompte" dividend system contrary to EU law (Parent Subsidiary Directive), ending double taxation on cross-border distributions.
Referral by Commission against Malta over discriminatory car taxation on imports.
Formal notice sent to Germany for amending pension saving rules to avoid worker free movement restrictions.
Commission closed infringement proceedings against Ireland for incomplete transposition of ATAD I directive.

European Commission referred Malta to CJEU for taxing imported used cars higher than domestic ones.
Commission sent formal notice to Germany regarding pension savings contracts and free movement.
Infringement procedures against Ireland closed due to partial implementation of ATAD I provisions.

European Commission proposed Directive for debt-equity bias reduction (DEBRA), including anti-abuse measures and interest deductibility limits.
Commission proposed revised Directive for EU long-term resident status with anti-abuse controls.
Commission announced end of COVID Temporary Framework; transition measures continue.
European Parliament approved a Minimum Tax Directive report to implement Pillar Two of OECD BEPS 2.0, with requested amendments.
Parliament hosted a public hearing on special tax regimes used by high net-worth individuals.

G7 communique emphasized commitment to OECD's Two-Pillar solution and tax co-operation for the 21st Century, including digital administration solutions.
Senegal ratified Multilateral Convention (BEPS MLI), effective September 2022.

Austria clarified application of dispute resolution mechanisms under tax treaties and EU conventions.
Belarus explained beneficial ownership rules for foreign recipients of dividends, interest, and royalties.
Finland updated guidance on double taxation relief mechanisms.
Greece proposed tax exemption for business reorganizations under specific conditions.
Italy provided further DAC6 clarifications on reporting cross-border arrangements and updated industrial investments R&D credits.
Malta announced corporate tax system reform to a classical system, effective 2025, and detailed tax deferral payment timelines.
Poland stated MDR deadlines remain suspended due to pandemic status.
Slovakia proposed a windfall profit tax on Russian oil refined in the country.
Sweden offered guidelines on permanent establishment risks for employees working from home.
Switzerland published transfer pricing dispute resolution statistics showing a decrease in pending cases.
UK launched public consultation on potential reforms of capital allowance regime, focusing on investment impacts.

Czech Republic Court ruled that transactions influenced by related parties may be treated as controlled transactions for transfer pricing adjustments.

KPMG held a webcast on EU Minimum Tax Directive developments, BEPS 2.0, and the "Unshell" Directive.
Event on future of tax and legal technology discussed innovations and ESG transparency challenges for life sciences companies.
KPMG prepared a memorandum on practical considerations for OECD Pillar Two GloBE rules.

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