Greece – Tax amendments for 2020 proposed
On 7 October 2019, a bill amending the tax legislation was submitted for public consultation. The main amendments are set out below.
On 8 November 2019, the General Authority of Zakat and Tax (GAZT) issued a decision amending the Zakat regulations. The amendment focuses on a new estimation method for Zakat calculation. As per the amendment, the Zakat base, annual sales and Zakat will be calculated as provided below.
(i) The Zakat base will be the higher of the following amounts:
The approved estimation method is applicable only to Zakat payers that have no legal obligation to maintain regular accounting records for their Zakat returns submitted after 31 December 2019.
Slovenia - Corporate tax rate was increased
In the Official Gazette of 5 November 2019, amendments to the Corporate Income Tax Law were gazetted. The amendments will apply as of 1 January 2020. The amendments include increasing general tax rate from 19% to 20%.
ANTI TAX AVOIDANCE
Denmark - New CFC rules are proposed
On 6 November 2019, the Ministry of Taxation presented its law proposal transposing into the Danish legislation the CFC rules in line with the EU ATAD Directive 2016/1164.
The adjustments to the existing CFC rules are based on ATAD Model A. The Danish government aims to achieve a balance that ensures a robust Danish tax base but at the same time reduces the economic and administrative consequences for ordinary businesses. This has resulted in the proposed amendments to the CFC rules having a very broad scope. The key features of the amendments are as follows:
Nigeria - Interest limitation rules are proposed
On 6 November 2019, the Finance Bill for 2019, which had been presented to the National Assembly by the President on 8 October 2019, was presented for a second reading. Bill introduces the BEPS Action 4 recommendation on interest limitation. The maximum interest expense deduction allowable is 30% of EBITDA. If approved the rules will apply from 1 January 2020.
Treaty between Luxembourg and Lithuania – MFN clause on royalties activated
On 22 November 2019, the Luxembourg administration for direct taxes published a press release announcing that the conditions for the activation of the most-favoured-nation (MFN) clause contained in the Protocol to the Lithuania - Luxembourg Income and Capital Tax Treaty had been met. The MFN clause applies as from 1 January 2019. The MFN clause modifies the wording of article 12, paragraphs 2 and 3, as follows:
Royalties shall not be taxable in the contracting state in which they arise. The term "royalties" as used in this article means the remuneration of any kind paid for the use or the concession of the use of a copyright in a literary, artistic or scientific work, cinematographic films or patent, trade mark, design or model, plan, formula or process secret and for information relating to experience acquired in the industrial, commercial or scientific field."