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Japanese Business Taxation Europe - Vol 32


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December 2012

In this issue of the JBTE newsletter the following topics are covered:

Belgium

  • ECJ rules Belgian dividend tax treatment of non-residents discriminatory 
  • Belgian 95% dividend received deduction held incompatible with EU parent-subsidiary directive 
  • Belgian 2013 tax plans submitted to parliament 

Denmark

  • New bill would tighten taxation of dividends 
  • New bill proposed to ease taxation of capital gains on portfolio shares

EU

  • Resolution of the European parliament regarding proposed revisions to interest royalty directive

France

  • Proposals for 2013 finance bill expected to increase corporate income tax burden 2012 finance bill proposals contain “tax shock” for wealthy individuals

Germany

  • German tax act and business tax reform act

Luxembourg

  • Government presents amended budget 2013

Italy

  • Italian finance ministry publishes decree implementing notional interest deduction

The Netherlands

  • New restrictions proposed on participation financing - 2013 budget includes repeal of thin capitalization rules

Portugal

  • 2012 new austerity measures affect nonresidents

Spain

  • Tax measures introduced to tackle economic crisis
  • Another round of austerity measures proposed

UK

  • UK consortium relief held incompatible with EU law
  • ECJ rules UK's former tax treatment of foreign-source dividends violated EU law
  • Tax authorities issue response document for withholding on interest payments

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