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Proposed corporate interest restrictions in Sweden

On 21 March 2018, the Swedish government put forward proposals for new corporate tax regulations. The key proposal is to limit the deduction for corporate interest expenses. The right of deduction will be based on a so-called EBITDA-rule and will be accompanied by a decrease in the corporate tax rate.

President Trump signs Omnibus Spending Bill with Favourable Real Estate Tax Provisions

On 23 March 2018, President Trump signed the Consolidated Appropriations Act of 2018 (the Omnibus Act), an omnibus government spending bill which includes several technical corrections of previously enacted tax provisions related to FIRPTA, REIT spin-off transactions, REIT income tests and the partnership audit rules. The Omnibus Act also includes new low-income housing tax credit provisions.

New Double Tax Treaty between France and Luxembourg: impact on real estate structures

The new DTT seeks to modernise the rules applying. The current treaty between Luxembourg and France was signed as long ago as 1 April 1958. The new DTT is fully “post-BEPS”. It implements the new approaches developed at international level during the OECD/G20 BEPS Project, now reflected in the 2017 version of the OECD Model Tax Convention, and in the Multilateral Convention to Implement Tax Treaty Related Measures (“the MLI”), signed by both Luxembourg and France in June 2017.

EPRA Global REIT Survey 2018

The REIT structure varies country-by-country, and it is constantly evolving. PwC have contributed the UK chapter of this European Public Real Estate Association analysis of global REITs.

Newsalert - Finnish Government proposes restrictions on interest relief

The Finnish Government have published their proposals to implement the EU Anti-Tax Avoidance Directive I (restricting interest relief), which is expected to come into force 1 January 2019. This represents a major development for the real estate industry as most real estate investors have until now been outside the scope of the Finnish interest capping rules.

Netherlands 2018 Budget Real Estate focus - update

On 18 September 2018, the Dutch Ministry of Finance announced a number of important changes and amendments to the Dutch tax legislation for 2019 and onwards, including the abolition of the current Dutch Dividend Withholding Tax Act and the introduction of a new conditional withholding tax on dividends. On Budget day, the Dutch government also issued a legislative proposal regarding the Dutch implementation of the ATAD. On 15 October 2018, the Dutch Government announced that the proposed changes have been reconsidered which has resulted in the withdrawal of the proposal to abolish the dividend withholding tax. In order to stimulate the Dutch investment climate, alternative measures have been proposed.