In der EAS 3421 vom 25.3.2020 wird vom BMF die Frage behandelt, unter welchen Voraussetzungen eine Beteiligung an einer landwirtschaftlich tätigen ungarischen Kapitalgesellschaft (Kft) einer Betriebsstätte in Ungarn zuzurechnen ist. Continue reading EAS 3421: Betriebsstättenvorbehalt bei einer ungarischen Landwirtschaft
Category Archives: Steuern International
World Tax Advisor 26 June 2020
- Israel: Israeli tax authorities reaffirm position regarding burden of proof in transfer pricing audits
- Australia: Guidance addresses COVID-19 impacts on transfer pricing
- European Union: Eurpean Council agrees on optional extended DAC 6 deadlines
- European Union: Overview of recent EU tax policy and other tax developments
- France: Third amended finance bill provides for early refund of carryback receivables
- Germany: 2020 economic stimulus package includes temporary reduction of VAT rates
- Hong Kong: Concessionary measures for ship leasing businesses passed by Legislative Council
- Paraguay: Taxation of digital services of nonresidents postponed
- Spain: Update on economic and fiscal measures introduced to address impact of COVID-19
- Taiwan: Ruling issued on tax treatment of leases for companies using IFRS 16 since 2019
- United Kingdom: VAT refunds for overseas businesses delayed
- United States: Settlement payments post-TCJA – Don’t forget about IRC section 1341
- United States: US exits multilateral consensus talks on digital services tax
- Tax treaty round up
For the latest developments from various countries on measures in response to COVID-19, please visit the Deloitte tax@hand COVID-19 page.
World Tax Advisor 19 June 2020
- India: AAR rejects applications to confirm capital gains exemption under Mauritius treaty
- Canada: Observations on recently released CRA guidance on international tax issues
- Cyprus: Amendments to notional interest deduction rules published
- European Union: CJEU AG opines on right of “active” holding company to deduct VAT
- Germany: COVID-19: Government approves economic stimulus bill
- India: Sales by nonresident through independent resident agent held not subject to WHT
- New Zealand: COVID-19: The latest wage subsidy information
- Nigeria: Clarifications on significant economic presence concept released
- Oman: Government announces implementation of tax card system
- Singapore: Tax treatment of payments made under separation agreement clarified
- United States: New PPP guidance addresses concerns about loan forgiveness “cliff”
For the latest developments from various countries on measures in response to COVID-19, please visit the new Deloitte tax@hand COVID-19 page.
World Tax Advisor 12 June 2020
The World Tax Advisor includes in particular:
- United States: United States Trade Representative opens new investigations into digital services taxes
- Germany: COVID-19: government agrees on comprehensive financial and tax measures
- Australia: Significant changes to foreign investment laws proposed
- Belgium: COVID-19: Measures proposed to reduce companies’ tax payments and improve cash flow
- Brazil: New withholding tax rates published for certain cross-border payments
- European Union: EU member states’ representatives agree on extended DAC 6 deadlines
- European Union: Commission approves French scheme to stimulate R&D activities to fight COVID-19
- France: Trust-based relationship model presents new opportunities for multinationals
- Japan: Overview of tax controversy trends and procedures
- Luxembourg: Decision to defer DAC 6 reporting obligations by six months and relevant clarification
- Malaysia: Guidelines issued to clarify determination of place of business
- New Zealand: New tax bill introduced: Giving with one hand while taking with the other
For the latest developments from various countries on measures in response to COVID-19, please visit the new Deloitte tax@hand COVID-19 page.
World Tax Advisor 5 June 2020
The World Tax Advisor includes in particular:
For the latest developments from various countries on measures in response to COVID-19, please visit the new Deloitte tax@hand COVID-19 page.
- Brazil: Draft bill proposes new tax on digital operations
- Brazil: STJ rules technical service fees are exempt from WHT under treaty with France
- Czech Republic: Supreme Administrative Court rejects tax authorities’ practice of tax loss chaining
- Hong Kong: Tax exemption for subsidies under the Anti-epidemic Fund announced
- India: Supreme Court rules liaison office’s activities do not constitute PE under UAE treaty
- India: ITAT rules equipment and services are composite contract, offshore supplier has PE
- New Zealand: COVID-10: Common questions in relation to wage subsidy and loan schemes
- New Zealand: Proposed tax-related amendments to the Overseas Investment Act 2005
- Thailand: Customs Department further extends voluntary disclosure program
- Ukraine: President signs BEPS tax reform into law
- United States: COVID-19 guidance adresses PPP loans, NOL carrybacks, alternative energy projects
- United States: House approves Paycheck Protection Program enhancements
World Tax Advisor 29 May 2020
The World Tax Advisor includes in particular:
- France: French tax authorities publish draft guidelines on DAC 6 hallmarks
- El Salvador: El Salvador grants additonal time for filing 2019 annual income tax return and paying tax
- Australia: Amendments to hybrid mismatch rules introduced to parliament
- Australia: Tax authorities highlight concerns over certain cross-border transactions
- European Union: Commission approves Italian scheme to support economy in light of COVID-19 outbreak
- France: VAT measures introduced to address impact of COVID-19
- India: Procedural rules for MAP resolutions revised
- India: Reduction in employer and employee contributions to provident fund announced
- Italy: Italian notional interest deduction implications under new US anti-hybrid rules
- Peru: Accelerated depreciation of certain fixed assets introduced in response to COVID-19
- Russia: Tax reliefs and extensions to compliance deadlines announced in response to COVID-19
- Singapore: Ruling on calculation of notional capital allowances for shipping company issued
- Taiwan: Application for refund of overpaid business tax simplified in response to COVID-19
- United States: Paycheck Protection Program enhancements would expand loan forgiveness rules
- Tax treaty round up
For the latest developments from various countries on measures in response to COVID-19, please visit the new Deloitte tax@hand COVID-19 page.
Keine KESt-Entlastung an der Quelle für Drittstaat-Holdings – Teil II
Das BMF hielt in einer EAS im Jahr 2019 (EAS 3414, 3.7.2019) fest, dass bei Einhalten aller Formalvoraussetzungen bei Dividendenausschüttungen an EU-Holding-Gesellschaften eine KESt-Entlastung an der Quelle möglich ist, sofern hinter den EU-Holdings operativ tätige EU-Muttergesellschaften stehen. Mit EAS 3422 vom 7.1.2020 stellte das BMF klar, dass dies jedoch nicht für Drittstaat-Holdings gilt (siehe dazu unsere Tax & Legal News vom 12.2.2020). In der EAS 3423 vom 25.3.2020 präzisierte das BMF nun diese Ausführungen. Continue reading Keine KESt-Entlastung an der Quelle für Drittstaat-Holdings – Teil II
World Tax Advisor 22 May 2020
- Brazil: COVID-19: FAQs and additional emergency tax measures published
- Colombia: DIAN issues new regulations on electronic invoicing
- European Union: Uncertainties exist over whether EU member states will agree extended DAC 6 deadlines
- European Union: European Commission proposes to delay entry into force of VAT e-commerce package
- European Union: CJEU rules that former Luxembourg fiscal unity regime is incompatible with EU law
- India: Supreme Court rules on withholding tax on payments to nonresident sports associations
- Italy: New official guidance on proof of intra-EU transport published
- Norway: Government presents revised national budget for 2020
- Peru: Procedure introduced to use overpayment of corporate tax to offset other tax debts
- Poland: Effective date of revised mandatory disclosure rules postponed due to COVID-19
- Saudi Arabia: Saudi Arabia’s VAT rate to increase to 15% from 1 July 2020
- Taiwan: Losses incurred in Q1 2020 due to COVID-19 may offset 2018 undistributed surplus
- United States: Updated FAQs explain review process for Paycheck Protection good-faith certification
- United States: Heroes Act clears House, next steps uncertain
- Uruguay: Tax incentives introduced for real estate projects
World Tax Advisor 15 May 2020
The World Tax Advisor includes in particular a special COVID-19 section:
- Peru: Peru extens tax loss carryforward period for corporations in response to COVID-19
- Belgium: Additional agreements concluded to manage COVID-19 impact on cross-border workers
- Bermuda: Economic substance declaration portal now available
- Brazil: COVID-19: Tax and other financial measures approved
- China: Enterprise income tax incentive extended in western regions
- European Union: CJEU rules on independent EU subsidiary as VAT fixed establishment of non-EU parent
- European Union: European Commission proposes extensions of DAC 6 reporting deadlines
- Hong Kong: IRD issues updated guidance on advance rulings
- India: CBDT relaxes individual residency rules for FY 2019-20 in light of COVID-19 lockdown
- India: Supreme Court rules evidence in penalty proceedings valid to determine assessment
- New Zealand: What impact will COVID-19 travel restrictions haven on your company’s tax residence?
- OECD: Concerns over unilateral DSTs grow as OECD tax overhaul project faces possible delay
- United States: More Paycheck Protection FAQs and other guidance released
World Tax Advisor 8 May 2020
The World Tax Advisor includes in particular a special COVID-19 section:
- OECD: OECD issues permanent establishment considerations due to COVID-19
- Austria: Tax payment and filing deadlines extended in response to COVID-19
- European Union: CJEU rules that Italian financial transactions tax is compatible with EU law
- Guatemala: Procedures for updating taxpayer information modified due to COVID-19
- Indonesia: Additional businesses eligible for tax incentives during COVID-19 pandemic
- Japan: Overview of anti-dividend stripping rules under 2020 tax reform
- New Zealand: Loss carryback rule: Fine in theory, but watch out for fish hooks
- OECD: Update provided on OECD’s work on taxation in context of COVID-19
- Peru: Procedures for calculating advance payments of income tax modified
- Portugal: Postponement of transfer pricing obligations due to COVD-19 pandemic
- Portugal: 2020 budget law makes changes to corporate, individual, and indirect tax rules
- South Africa: Finance minister provides more detail on additional COVID-19 tax relief measures
- Spain: Additional economic and fiscal measures introduced to address impact of COVID-19
- United States: USMCA to enter into force on 1 July 2020 as US progresses its implementation steps
- United States: Guidance addresses deductibility of expenses paid for by PPP loans
World Tax Advisor 1 May 2020
The World Tax Advisor includes in particular a special COVID-19 section:
- Albania: COVID-19 financial assistance measures for current and former employees announced
- Australia : Significant developments to JobKeeper scheme announced
- Austria: Considerations for dividend distributions due to impact of COVID-19
- British Virgin Islands: FATCA and CRS registration and reporting deadlines extended due to COVID-19
- Canada: COVID-19: Canada Emergency Wage Subsidy (CEWS) – Frequently asked questions
- China: Tax and trade measures approved to stimulate economic recovery
- European Union: Commission approves Finnish scheme to support companies affected by COVID-19
- Germany: COVID-19: Government allows deferred wage tax filing
- Indonesia: Additional tax relief announced and deadlines further extended in view of COVID-19
- Italy: Decree expands incentive measures introduced in response to COVID-19
- Korea: Individual income tax payment deadline for 2019 extended
- Mexico: COVID-19: Economic and fiscal measures in Latin America
- Netherlands: Additional VAT measures in response to COVID-19
- New Zealand: Practical relief from consequences of COVID-19 travel restrictions for individuals
- Nigeria: COVID-19: Economic, tax, and other fiscal stimulus measures
- Norway: Final regulations published on financial support program
- Poland: New legislation aims to support enterprises affected by COVID-19
- South Africa: Additional tax relief measures announced in response to COVID-19
- United Arab Emirates: VAT return filing and payment deadline extended
- United States: Additional coronavirus resources available
- Zimbabwe: Expedited processing of VAT refunds announced
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- Peru: Peru introduces new valuation method for taxable indirect share transfers
- Australia: AAT decisions find mining activities not “core R&D activities”
- Belgium: New circular letter regarding the VAT treatment of tour operators and travel agents
- European Union: Revised EU posted workers directive due to become law
- Finland: E-invoicing mandatory for B2B sales upon request of purchaser
- India: ITAT rules on scope of business connection for event organized overseas
- Indonesia: Implementing regulation issued for super tax deduction for labor-intensive industries
- Ireland: Guidance issued on VAT groups
- United States: USMCA update: Canada and Mexico confirm completion of entry into force procedures
World Tax Advisor 24 April 2020
The World Tax Advisor includes in particular a special COVID-19 section:
- Australia: Jobkeeper scheme: Racing the clock
- Canada: COVID-19 – Recent support announcements
- Canada: COVID-19 – The new Canada Emergency Response Benefit
- Colombia: Simplified and accelerated procedure for requesting tax refunds or offsets introduced
- Costa Rica: Tax relief measures enacted in response to COVID-19
- Cyprus: Changes to VAT periods and deadlines for submission of returns and payment of VAT
- India: FDI policy change to restrict opportunistic takeovers of domestic companies announced
- India: CBDT clarifies extensions to lower or nil TDS/TCS certificates for FY 2020-21
- Korea: Tax reform measures enacted in response to COVID-19
- Kuwait: Government announces extension of public holiday beyond tax filing deadline
- New Zealand: COVID-19: The latest tax announcements
- OECD: Individual residency and taxation for stranded workers due to COVID-19
- OECD: Report presented to G20 on how tax policy can help governments deal with COVID-19
- Peru: Clarification provided that deadline extensions apply to temporary net assets tax
- Saudi Arabia: VAT return and payment deadlines extended due to COVID-19
- Singapore: Managing GST compliance and cashflow during COVID-19
- Switzerland: SFTA modifies its approach to net tax rate scheme due to COVID-19
- Taiwan: Annual income tax return filing and payment period extended
- Thailand: Tax relief measures announced in response to COVID-19
- United Arab Emirates: Economic substance considerations in light of COVID-19
- United States: Update on US global trade regulatory developments in response to COVID-19
- United States: Summary of employer payroll tax relief
- United States: Additional coronavirus guidance, resource materials available
- Venezuela: Measures in response to COVID-19 include tax exemptions for certain imported goods
- Bahrain: Guidance on mutual agreement procedure issued
- El Salvador: Deadline approaching for appointment of tax auditors for 2020 tax period
- Guatemala: Changes to taxation of international air transportation industry coming in 2021
- India: Certain Mauritius FPIs not covered under indirect transfer income deeming provisions
- India: CBDT clarifies that employers may apply simplified tax regime for withholding taxes
- United Arab Emirates: Foreign businesses may submit 2019 VAT refund requests
- United States: Deloitte Tax looks at final, proposed hybrid regulations
- United States: IRS releases transfer pricing documentation “frequently asked questions”
- Venezuela: Value of tax unit adjustment
- Tax treaty round up
World Tax Advisor 17 April 2020
The World Tax Advisor includes in particular a special COVID-19 section:
- Botswana: Economic and fiscal measures introduced in response to COVID-19
- Canada: COVID-19 – Update on the Canada Emergency Wage Subsidy (CEWS)
- China: Export VAT refund rates increased on over 1,400 goods
- Colombia: New extensions for corporate income tax compliance, filing overseas assets return
- Cyprus: Relief from import duties and VAT exemption on imports needed to combat COVID-19
- European Union: EU permits import duty relief and VAT exemption on certain goods in view of COVID-19
- Germany: COVID-19: Additional tax measures announced and implemented by government
- Hong Kong: Third round of tax and financial relief measures in response to COVID-19 announced
- Indonesia: Implementing guidance issued for COVID-19 tax incentives
- Italy: Law decree introduces additional urgent tax measures in response to COVID-19
- Japan: Additional tax relief proposed as part of COVID-19 emergency economic response plan
- Oman: Tax relief measures announced in response to COVID-19
- Portugal: Deadline for issuing e-invoices for B2G transactions postponed to 2021
- Russia: 2019 tax return filing deadline for individual taxpayers extended in view of COVID-19
- Singapore: IRAS guidance on company tax residence, PE, and employee taxation in view of COVID-19
- Spain: Economic and fiscal measures introduced to address impact of COVID-19
- Taiwan: Relief measures announced to help industries affected by COVID-19
- United States: Expanded stimulus bill resource list available
- United States: New IRS releases provide filing and other tax relief
- United States: Transfer pricing considerations in the time of COVID-19
World Tax Advisor 10 April 2020
The World Tax Advisor includes in particular a special COVID-19 section:
- Australia: R&D uplifts available on accelerated depreciation and (most) IAWOs
- Bahrain: Economic substance reporting deadline extended
- Belgium: Certain income tax prepayment credit percentages increased in view of COVID-19
- Brazil: COVID-19: Latest tax measures approved by government
- Canada: COVID-19 – Recent government support measures
- Colombia: Local authorities adopt new tax compliance deadlines and tax cuts in view of COVID-19
- El Salvador: Additional legislation enacted in response to COVID-19
- European Union: Commission approves French, Spanish aid schemes for companies affected by COVID-19
- Greece: COVID-19 – Third package of measures announced
- India: Ordinance effects extended tax compliance deadlines announced in response to COVID-19
- Indonesia: Measures introduced in response to COVID-19 include immediate CIT rate reduction
- Israel: Tax filing deadlines postponed under COVID-19 emergency regulations
- Italy: Measures introduced in response to COVID-19 include various incentives
- Japan: FAQs clarify relief available for taxpayers affected by COVID-19
- Luxembourg: Financial aid scheme established for enterprises affected by COVID-19
- New Zealand: R&D tax credit – Broader refundability for loss making companies
- New Zealand: Cross-border workers and tax considerations resulting from COVID-19
- Norway: Government implements financial support program
- OECD: OECD issues recommendations on implications of COVID-19 on cross-border matters
- Peru: Postponement of deadlines for certain tax obligations extended and expanded
- Qatar: Government temporarily exempts 905 items from customs duties in response to COVID-19
- Russia: 15% dividend and interest WHT rate to apply to recipients in conduit jurisdictions
- Singapore: Resilience budget to ease financial consequences of COVID-19 for taxpayers announced
- South Africa: Update on tax developments in response to COVID-19
- United Arab Emirates: Update on economic substance notification deadlines
- United Kingdom: New guidance on execptional circumstances for UK residence test in view of COVID-19
- United States: Understanding the CARES Act’s tax provisions – A selected list of key resources
- United States: Penalty relief for failure to deposit employment taxes linked to COVID-19 tax credits
- Hong Kong: Tax authorities issue updated guidance on taxation of e-commerce transactions and digital assets
- Cambodia: Guidance clarifies TOS exemption on 2020 seniority indemnity payments
- European Union: CJEU clarifies application of EU parent-subsidiary directive to Gibraltar
- European Union: CJEU AG opines on VAT treatment fo investment fund management services
- India: Parliament enacts Finance Act 2020, amends certain Finance Bill 2020 proposals
World Tax Advisor 3 April 2020
The World Tax Advisor includes in particular a special COVID-19 section:
- Albania: Certain tax deadlines for small businesses extended, among other COVID-19 measures
- Argentina: Tax measures introduced in response to COVID-19
- Australia: Federal government announces significant foreign investment approval changes
- Australia: JobKeeper scheme announed to maintain employment levels
- Belgium: VAT credit refund possibility announced in response to COVID-19
- Bermuda: CRS and CbC reporting deadlines extended due to COVID-19
- British Virgin Islands: Information exchange, economic substance frameworks to be maintained during COVID-19
- Canada: COVID-19 – Update on fiscal measures
- China: Summary of tax relief measures relevant to COVID-19
- Colombia: COVID-10 measures include increased powers for local government, VAT exemptions
- Cyprus: COVID-19 tax and VAT measures voted
- El Salvador: Special decrees and laws on tax matters issued in response to COVID-19
- European Union: Commission approves German direct grant scheme for companies affected by COVID-19
- France: Government eases tax rules cross-border employees working remotely
- India: Tax and regulatory compliance deadlines extended in response to COVID-19
- Indonesia: New fiscal measures announced in response to COVID-19
- Japan: Effect of COVID-19 on transfer pricing
- Kosovo: Extension of tax filing deadlines in response to COVID-19
- Mexico: Various tax measures proposed to mitigate economic impact of COVID-19
- Netherlands: Measures announced in response to COVID-19 include tax deferrals
- New Zealand: COVID-19 Response (Taxation and Social Assistance Urgent Measures) Act 2020
- Norway: Parliament adopts measures in response to COVID-19
- OECD: Platform for Collaboration on Tax launches new website including COVID-19 resources
- Portugal: COVID-19 – Support measures for companies and employees
- South Africa: Tax relief measures announced in response to COVID-19
- United States: COVID-19 stimulus: A taxpayer guide
- India: Equalization levy on e-commerce supply or services introduced
- Cambodia: TOI exemption granted to businesses impacted by suspension of EBA scheme
- France: New guidelines for non-EU exporters released
- France: Supreme Court rules self-employed status of digital platform worker is “fictional”
- India: Mandatory e-invoicing for GST purposes deferred until 1 October 2020
- Qatar: Directives published on mutual agreement procedures
- Singapore: Foreign worker hiring ratio to be cut in three sectors as from 2021
- United States: Deadline unchanged to apply for quick refund of overpayment of estimated tax
- Uruguay: Companies involved in restructuring may elect tax-free treatment for goodwill
World Tax Advisor 27 March 2020
The World Tax Advisor includes in particular a special COVID-19 section:
- Australia: Tax and business relief in response to COVID-19
- Belgium: COVID-19 measures to support businesses and individuals announced
- Brazil: Emergency economic measures approved by government in response to COVID-19
- Canada: COVID-19 – New fiscal measures
- Chile: Tax measures in response to COVID-19 announced
- Colombia: Additional tax measures announced in response to COVID-19
- Czech Republic: Stabilization package for taxpayers approved in response to COVID-19
- Germany: Two decrees with tax relief measures to boost liquidity published
- Guatemala: Effect of COVID-19 on tax matters
- Indonesia: Changes in working practices in response to COVID-19 affect tax services
- Italy: Clarification provided on businesses eligible for extended deferral of tax payments
- Korea: Tax measures in response to COVID-19 announced
- Luxembourg: New tax measures implemented in response to COVID-19
- Peru: Government announces ta measures in response to COVID-19
- Peru: Deadline for filing 2019 income tax return extended for more taxpayers
- Saudi Arabia: Deadlines extended due to COVID-19 for filing tax returns and paying taxes
- Sweden: Financial measures in response to COVID-19 announced
- Taiwan: Relief plan announced, travel tightened in response to COVID-19
- United Kingdom: COVID-19 tax measures to support businesses and individuals announced
- United States: Senate leaders reach deal on coronavirus economic stimulus proposal
- United States: What may be considered “qualified disaster relief payments” related to COVID-19?
- United States: Tax considerations for self-employed individuals in coronavirus stimulus package
- United Kingdom: Updated draft legislation and guidance on digital services tax issued
- Czech Republic: Amendments to digital service tax legislation could reduce 7% tax rate
- Luxembourg: DAC 6 proposed rules become law
- Poland: MDR amendment bill provides for additional reporting obligations
- Poland: Ministry of Finance considers relaxing requirements of VAT “white list”
- Spain: Clarification on classification of foreign-incorporated entities as tax transparent
- United Kingdom: IR35 changes postponed for 12 months
- Tax treaty round up
Vorübergehendes Homeoffice: Gefahr einer Betriebs-stättenbegründung?
Auf Grund des COVID-19 Virus sind derzeit viele Mitarbeiterinnen und Mitarbeiter dazu aufgefordert im Homeoffice zu arbeiten. Dank der europäischen Integration befindet sich in der heutigen Zeit jedoch das Zuhause oft nicht im selben Staat wie der Arbeitgeber bzw die Arbeitgeberin. In ganz Europa gibt es grenzüberschreitende Pendlerinnen und Pendler, welche aktuell dazu angehalten sind im Homeoffice zu arbeiten. Dabei stellt sich im Zusammenhang mit dem Arbeiten im Homeoffice stets die Frage, ob hierdurch eine ertragssteuerliche Betriebsstätte für den Arbeitgeber bzw die Arbeitgeberin begründet werden kann. Es sei darauf hingewiesen, dass in diesem Artikel ausschließlich die Begründung von ertragssteuerlichen Betriebsstätten diskutiert wird, nicht jedoch bspw auf die Begründung von Lohnsteuer-Betriebsstätten eingegangen wird. Continue reading Vorübergehendes Homeoffice: Gefahr einer Betriebs-stättenbegründung?
World Tax Advisor 20 March 2020
The World Tax Advisor includes in particular a special COVID-19 section:
- Autralia: Administrative measures on international tax issues in response to COVID-19 announced
- Australia: Government accounces business support measures in response to coronavirus
- Belgium: COVID-19 implications for taxation of cross-border workers
- Canada: Fiscal measures to support the economy
- Columbia: Tax measures announced in response to COVID-19
- Cyprus: Direct tax and VAT measures in response to COVID-19 announced
- Indonesia: Changes in working practices in response to COVID-19 affect tax services
- Italy: Urgent tax measures adopted in response to COVID-19
- Jersey: Guidance on COVID-19 and economic substance issued
- New Zealand: COVID-19 – Tax reform measures included as part of Business Continuity Package
- Taiwan: Various filing and payment deadlines extended in response to COVID-19
- United States: Senate approves coronavirus stimulus package
- India: AAR denies capital gains exemption under tax treaty with Mauritius
- Australia: ATO view of associate test prevails
- Canada: 2020-2021 Quebec budget highlights
- Cayman Islands: FATCA and CRS changes introduced for 2019 reporting year
- France: DAC 6: First FTA guidelines published
- Germany: Guidance issued on guaranteed minimum payments in tax consolidated group
- Germany: MOF publishes first draft of decree for application of DAC 6 rules
- Luxembourg: Tax authorities release guidance on CFC rules
- Peru: Branches of foreign entities not subject to additional tax on indirect distributions
BEPS: Update Anwendbarkeit MLI
Mit Jänner 2019 wurden die ersten Änderungen bestehender Doppelbesteuerungsabkommen (DBA) durch das Multilaterale Instrument (Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting – BEPS) anwendbar. Aufgrund weiterer MLI-Ratifizierungen seit unserem letzten Tax & Legal News Beitrag vom 7.8.2019 zu diesem Thema wächst die Liste der zukünftig anwendbaren MLI-Bestimmungen auf Österreichs DBA schrittweise. Ziel des MLI, eines Aktionspunktes der OECD BEPS-Initiative, ist die rasche, international abgestimmte und einheitliche Umsetzung diverser Anti-BEPS-Maßnahmen ohne langwierige bilaterale Neuverhandlungen der einzelnen DBA (siehe dazu auch unsere Tax & Legal News Beiträge vom 20.6.2017 und 17.1.2018). Continue reading BEPS: Update Anwendbarkeit MLI
World Tax Advisor 13 March 2020
Thee World Tax Advisor includes in particular:
- Singapore: Singapore’s Budget 2020 extends a number of tax incentives
- UK: Key measures from UK Spring Budget 2020 for non-UK owned groups
- Belgium: Transfer pricing circular published
- European Union: CJEU rules no requirement to offset prior tax losses after transfer of tax residence
- European Union: CJEU rules Hungarian turnover tax in store retail trade sector compatible with EU law
- Greece: Ministerial decision issued on alternative lump sum taxation for individuals
- Singapore: New GST compliance measures announced and updated e-Tax guides issued
- Taiwan: CRS financial institution portal launched
- United Arab Emirates: Designated zones a focus for FTA audits
- United States: Proposed regulations on meals, entertainment and fringe benefits released