Financial Services Newsletter

2022

#4/2022

WTS Financial Services

Newsletter

News from nine European countries with a focus on the international Financial Services industry

#3/2022

WTS Financial Services

Newsletter

News from nine European countries with a focus on the international Financial Services industry

#2/2022

WTS Financial Services

Newsletter

News from nine European countries with a focus on the international Financial Services industry

#1/2022

WTS Financial Services

Newsletter

News from ten European countries with a focus on the international Financial Services industry

News from nine European countries with a focus on the international Financial Services industry

Sub-participations in loans - ECJ judgement of 6 October 2022 (C-250/21)

Consequences of the Cum-Ex-Trades on WHT refund and relief in Austria

The Belgian Constitutional Court decides on the annual tax on securities accounts (ATSA)

Additional taxes for the Belgian financial sector and snowball effect for Belgian regulated investment companies (tax-on-tax)

Reclaim opportunity re Belgian WHT for Luxembourg SICAVs

China: Tax audits on private wealth

Czech Republic: Windfall tax

Draft bill to improve attractiveness of Germany as a Financial Services location

Germany: Court decision: taxation of realized capital gains from fund units in the context of the 2018 tax reform

Italian Tax authorities rule on VAT and income taxes on mining activity

Poland: Changes to banking tax

Changes on Spanish SICAVs

United Kingdom: Autumn Statement 2022 impacts financial institutions
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News from nine European countries with a focus on the international Financial Services industry

Austria: Changes in the taxation of investment income by way of the Austrian tax reform 2022

China: Green channel for foreign loans to high-tech firms

Czech Republic: Taxation of cryptocurrencies & required capital of self-governed investment funds

Finland: Exit tax proposed for individuals

France: French Supreme Tax Court validates the possibility of charging foreign tax credits on the share of costs and expenses on dividends

Germany: ECJ judgement in the case “ACC Silicones” - C-572/20 & draft administrative guidance on duties of cooperation related to crypto assets & new regulation on crypto fund units

Indonesia: Taxation of crypto asset transactions, new regulation as of 30 March 2022

Italy: Important update on WHT reclaims due to recent Supreme Court decisions Poland: Interest on overpaid WHT for third-country investment and pension funds - SAC requests CJEU

United Kingdom: Sovereign immunity from direct taxation, Investment Management Exception, qualifying asset holding companies regime
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News from nine European countries with a focus on the international Financial Services industry

Argentina: Summary of recent tax news relevant to the FS industry

Belgium: Luxembourg treaty exemption for the Annual Tax on Securities Accounts at risk?

Finland: CJEU dated 7 April 2022 (C-342/20): Finnish WHT exemption in conflict with free movement of capital &

Finland: Finnish Tax Administration reveals malicious companies set up for tax evasion “as a service”

France: Intra-group interest – improvement for taxpayers Germany: Final administrative decree on crypto assets & Decision in ECJ case C-641/17 & “CPP” & Federal Tax Court on cum-/ex-transactions

Italy: Tax ruling on WHT exemption and foreign investment funds (dated 30 March 2022)

Poland: Two Supreme Administrative Court decisions on cryptocurrencies and interest on overpayment

United Kingdom: Changes to Economic Crime Act 2022 & Plans of HMRCs Business Risk Review & Crypto asset developments & Changes to the US Qualified Intermediary Agreement
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News from ten European countries with a focus on the international Financial Services industry

Hot topic: ECJ landmark decision in the case C-545/19 (AEVN) dated 17 March 2022

Hot topic: OECD Commentary on Pillar Two

Austria: Supreme Administrative Court on foreign Trusts

Belgium: New fund type – Belgian ELTIF

Belgium: WHT reclaim

China: Change in taxation of equity investments

Czech Republic: New Czech government & increase of interest rate

France: Tax measures on gains from the sale of digital assets

Germany: Economic ownership and securities lending & WHT on crypto fund units

Netherlands: Government proposal to curb dividend stripping

Poland: Supreme Administrative Court on beneficial ownership & Indirect transactions with tax havens

Sweden: WHT for pension funds & VAT treatment of interchange fees in Sweden

UK: HMRC on Implementation of Pillar Two, ISA compliance and Uncertain Tax Treatment & Review of UK funds regime
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2021

#4/2021

WTS Financial Services

Newsletter

News from thirteen countries with a focus on the international Financial Services industry

#3/2021

WTS Financial Services

Newsletter

News from eleven countries with a focus on the international Financial Services industry

#2/2021

WTS Financial Services

Newsletter

News from fifteen countries with a focus on the international Financial Services industry

#1/2021

WTS Financial Services

Newsletter

News from nine European countries, covering especially WHT topics related to the international Financial Services industry

News from thirteen countries with a focus on the international Financial Services industry

Recent EU developments with respect to WHT

Argentina: Tightening of the foreign exchange control framework, increase of Corporate Income Tax, taxation of crypto currencies, & Supreme Court decision on interest deduction

Austria: Draft bill on new Austrian tax regime for crypto currencies published

Czech Republic: Act on Investment Companies and Investment Funds & Green Tax

Finland: CJEU Advocate General Opinion (C-342/20) on tax exemption criteria designed for contractual funds & Changes to the interest deduction limitation rules

France: VAT option for banking and financial services (draft bill)

Germany: Impact of recent Coalition Agreement on the FS industry, Revised CFC rules & Introduction of check the box regime

India: Taxation of Dividend income

Ireland: The taxation of crypto currency in Ireland

Netherlands: Court decisions on German real estate investment fund with Dutch real estate income & Dividend tax refund for UK pension fund

Poland: Polish Deal – selected WHT issues (incl CIVs)

Slovenia: Taxation of crypto currencies

Sweden: Proposed tax on credit institutions & Postponement of new WHT Act

Switzerland: Reform of Swiss WHT regime & New legal framework on implementation of international tax agreements
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News from eleven countries with a focus on the international Financial Services industry

Germany: Introduction of crypto fund units

Austria: New CJEU decision on VAT exemption

Belgium: Investment funds and the new annual tax on securities accounts

Denmark: Fidelity Funds and 24 June 2021 Supreme Court (Update) – Beneficial ownership – Tax Havens

Finland: Government Budget Proposal – Supreme Administrative Court on taxation of carried interest

Germany: Administrative guidance on securities lending transactions

Hungary: New taxation rules for crypto assets

Ireland: Share Schemes in the Irish Tax System

Italy: Tax exemption on interest from medium / long term loans paid to foreign investment funds – Tax regime of interests on loan granted to Italian tax resident persons by non-resident banks

Luxembourg: Refund of Luxembourg dividend WHT and proof of beneficial ownership

Poland: Polish Deal – WHT scheme, holding companies and VAT option

Switzerland: Substantial reform of Swiss WHT and Stamp Tax
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News from fifteen countries with a focus on the international Financial Services industry

WHT reclaim – CJEU Case C-545/19 (“AEVN”) – Update

Belgium: New annual tax on securities accounts introduced

Czech Republic: Taxation of capital gains of German and Liechtenstein tax residents

Denmark: Danish High Court (Landsretten) issues two rulings in beneficial ownership on dividends

Finland: Taxation of crypto assets

France: The new French-Luxembourg tax treaty: comments from the French tax authorities

France: Consequences of the Brexit on direct tax in France

France: E-Invoicing & E-Reporting obligations in France

Germany: Upcoming legislation on crypto assets, new fund types, WHT reclaims and ATAD

India: Tax incentives set to attract global investors

Encashment Tax in Ireland – a recent amendment

Italian tax exemption on dividends paid to foreign investment funds

Luxembourg: New guidance on DTT mutual agreement procedure

Dutch Supreme Court of 9 April 2021 regarding Dutch dividend WHT refund claims

Polish WHT landscape – uncertainty and abeyance since 1 January 2019

Spain: Supreme Court on WHT exemption for sovereign wealth funds

Sweden: Crypto assets

Spring 2021: Reshaping UK‘s tax landscape
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News from nine European countries, covering especially WHT topics related to the international Financial Services industry

Denmark: New model for dividend taxation in Denmark

Finland: Changes to legislation regarding nominee-registered shares

France: French WHT on dividends paid to foreign investment funds

Germany: Digitalization of tax law and tightening of WHT process

Italy: WHT exemption on interest paid to UK [mutual] investment funds (after Brexit): Italian Revenue Agency Ruling n. 125, 24 February 2021

Netherlands: Developments regarding WHT on portfolio dividends

Portugal: Tax litigation associated with WHT on dividends obtained by EU pension funds

Spain: Resolutions of Central Economic Administrative Court, of 8 October 2019

UK’s funds regime to be overhauled
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Financial Services Newsletter

2022

News from nine European countries with a focus on the international Financial Services industry

News from nine European countries with a focus on the international Financial Services industry

News from nine European countries with a focus on the international Financial Services industry

News from ten European countries with a focus on the international Financial Services industry

2021

News from thirteen countries with a focus on the international Financial Services industry

News from eleven countries with a focus on the international Financial Services industry

News from fifteen countries with a focus on the international Financial Services industry

News from nine European countries, covering especially WHT topics related to the international Financial Services industry

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