In recent days a legislative proposal has been published which would amend laws on tax treatment of income (bill of 6 July 2017). According to the statement of reasons for the proposal, the aim is to further tighten up the tax system and (partially) implement the ATAD.
The proposal would increase the taxable base declared by many taxpayers and lead to a more complex tax assessment and payment process. To a lesser extent, the proposal also contains some regulations that would be favourable to taxpayers.
The most important changes proposed in the bill are as follows:
Minimum tax on commercial real estate
Separate treatment of sources of income
Limit on expenditure on intangible services, as well as remuneration and the employee benefit fund
More undercapitalisation restrictions
Amendments to CFC regulations
Easing of conditions for tax capital groups
Higher value of fixed assets which can be classed as tax deductible once