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Japanese Business Taxation Europe - Vol 31


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June 2012

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

Belgium

  • Belgium asked to expand scope of application of notional interest deduction

Austria

  • Draft austerity package announced

EU

  • The ECJ has ruled against the “respondent fiscal” regime in France
  • EU Commission issues guidelines for import controls
  • ECJ rules Dutch exit charge is disproportionate and infringes EU law

Finland

  • EBITDA-based limitation on related party interest proposed

France

  • Investment funds prevail in French withholding tax case before ECJ

Germany

  • Federal tax court clarifies scope of participation exemption
  • Draft Taxation Act 2013 incorporates AOA approach to taxing PEs
  • BFH rules on set off of loss carryforwards
  • New treaties with Netherlands and Luxembourg contain “real estate” clauses

Greece

  • VAT refund procedure modernized

Hungary

  • Main audit areas for 2012
  • Overview of Hungary’s improved IP box regime

Spain

  • More tax measures introduced to tackle public deficit

Sweden

  • Court rules withholding tax on dividends paid to foreign fund undertakings violates EU Law
  • Government proposes further restriction on deduction of interest on intra-group debt
  • Court rules on interpretation of Nordic treaty

The Netherlands

  • Supreme Court rules regarding Dutch FX gains on tainted group debt
  • New policy for VAT on private use of company cars

UK

  • Real Time Information: new guidance on corrections and errors
  • Large Business Service Enquiry yield
  • New Protocol to UK/Singapore Double Taxation Agreement signed
  • 2012 Budget measures affecting foreign multinationals
  • Consultation: possible changes to Income Tax rules on interest
  • Infraction proceedings against UK on exit taxes
  • Senior Accounting Officer (SAO) legislation: revised HMRC guidance
  • Other UK tax topics

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