Slovakia has proposed legislation conforming treatment of hybrid loan arrangements and general anti-avoidance rules (GAAR) of the EU Parent-Subsidiary Directive. Note that Slovakia has not suggested expansion of such rules, as Sweden’s recent proposal suggests.
EY’s Global Tax Alert highlights these developments, as well as other changes including penalties and service PE determination.
Click to access 2015G_CM5410_Slovakia%20proposes%20changes%20to%20tax%20legislation.pdf
The new legislation is expected to take effect as of 1/1/2016, thus future planning should document transactions accordingly, especially noting the “main purpose” rule of the GAAR initiative which is inherently subjective.
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