2021-07-27-KPMG_Global-E-News_from_KPMG_s_EU_Tax_Centre_12页_261kb

报告摘要

CJEU Opinion on Spanish Sanctions: Advocate General deemed sanctions for failure to report foreign assets disproportionate, violating EU freedom principles, as they deter cross-border investment and impose excessive fines.
EFTA Court Referral: Norway's limited interest deduction rule on EEA agreement compatibility is under review.
State Aid General Court Decision: Upholds European Commission's referral of Dutch tax rulings, finding no premature action in investigating selective advantages for subsidiaries.

European Commission: Proposed the "Fit for 55" package for carbon pricing reforms, including expanding the ETS, introducing the Carbon Border Adjustment Mechanism (CBAM), and strengthening anti-money laundering rules with a new EU authority.
European Parliament: Held a public hearing on tax transparency initiatives and proposals.

France: Temporarily suspended DAC6 filing services; approved Finance bill changes extending loss carry-back and aligning withholding tax with EU law.
Germany: Terminated double tax treaty with UAE due to lack of extension agreement.
Gibraltar: Increased corporate income tax rate from 10% to 12.5% aligning with OECD's BEPS 2.0 framework.
Ireland: Launched public consultation on OECD's revised two-pillar approach for tax transparency.
Kenya: Enacted Finance Act 2021, including country-by-country reporting and updated thin capitalization rules.
Mauritius: Consulted on 2021 Finance Bill introducing new permits and changes to trusts.
Oman: Clarified CbC reporting suspension based on entity residency.
Turkey: Published guidelines on beneficial ownership notification, effective August 31, 2021.

Italy: Supreme Court ruled on beneficial ownership interpretation, upholding double tax treaty applicability based on legal and economic control.
Netherlands: Supreme Court dismissed anti-abuse arguments on group loan interest deduction, citing arm's length principles and freedom of financing choice.

Pillar 1 and Pillar 2 Webcast: Provided insights into the new OECD framework; highlighted tools for tax transparency reporting, including country-by-country and digital economy measures.
Tax Transparency: KPMG services assist with compliance, stakeholder communication, and digital services tax impacts.
Database Updates: Summarized regional developments like DAC6 transposition and CbC reporting.
Carbon Border Adjustment Mechanism: Explored implications for businesses under the EU's CBAM initiative.

KPMG's EU Tax Centre compiles updates on EU and international tax developments, emphasizing trends in transparency, digital taxation, and carbon pricing reforms part of broader policy goals.

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