2023-01-11-KPMG-E-News_from_the_EU_Tax_Centre_22页_564kb

报告摘要

Italian Tax Withholding: Non-resident intermediaries must report data and withhold tax on peer-to-peer rentals, though appointing a tax representative in Italy is prohibited.
Portuguese Stamp Duty: Precluded under Capital Duties Directive due to taxation of management fees on shares.
Spanish State Aid: Corporate tax exemption for ports declared illegal.
Dividend Taxation: Dutch ruling challenges whether non-residents get net taxation relief on dividends.

EU Energy Sector Tax: Germany, the Netherlands, and US oil companies challenge solidarity contributions as tax measures.
General Court Upholds: Spanish port tax exemption decision.

Minimum Tax Directive: EU Agreement (Dec 2022) establishes global minimum tax ('Digital Minimum Tax'—DMTT) effective Dec 2024, with Option QDMTT for specific MNEs.
Public CbCR Reporting: Spain implements CbCR for groups with revenue over €750M (as from June 2024).
Windfall Tax: Austria, Belgium, Bulgaria, Croatia, Finland, Sweden, France, Germany, Hungary, Ireland, Italy, Latvia, Luxembourg, Netherlands, Portugal, Romania, Slovakia, Spain introduced temporary/extraordinary taxes related to energy and fossil sectors, often coexisting with existing energy taxes.

GloBE Model: Release of Draft Administrative Guidance on Safe Harbors/Penalty Relief under Pillar Two; Consultation paper on GloBE Information Return and Tax Certainty.
Digital Services Tax Removal: Consultation paper for removal of DSTs under Pillar One Amount A.
Peer Review: Compliance with BEPS Action 5 among Inclusive Framework members, with 73 jurisdictions fully compliant.
Forum on Harmful Tax Practices: Recent assessments, including non-harmful status for Hong Kong, Jamaica, North Macedonia, and negative reviews for Albania and Pakistan.

Solidarity Contributions/Energy Taxes: Austria, Belgium, Bulgaria, Croatia, Finland, Georgia (N/A), Hungary, Ireland, Italy, Latvia, Luxembourg, Netherlands, Portugal, Romania, Slovakia, Spain, Sweden.
Interest Limitation Rules/Transfer Pricing: Finland, France, Germany, Poland, Slovakia.
Start-up Incentives: Spain.
Technical/Administrative Changes: Finland updates equity escape clause, Luxembourg clarifies reverse hybrid rules, Netherlands updates non-cooperative jurisdictions list.

DAC7: Deadline for compliance is 31 Dec 2024; Most member states (e.g., Belgium, Bulgaria, Croatia, Czech Republic, Denmark, Finland, France, Germany, Hungary, Ireland, Latvia, Netherlands, Slovakia) have transposed; Delays are left in Spain, Cyprus, Estonia, Greece, Lithuania, Malta, Poland, Portugal, Romania, Slovenia, and UK.

Monthly webcast discussing Pillar One/Two progress, harmful tax practices, CbCR, and state aid concerns.
Additional insight into plastic taxes in the EU.

More details available in original Euro Tax Flash.

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