Ab 1.1.2019 haben beschränkt Steuerpflichtige vor der Stellung eines Rückerstattungsantrags betreffend Kapitalertrag-, Lohn- oder sonstiger Abzugsteuern verpflichtend eine Vorausmeldung beim zuständigen Finanzamt auf elektronischem Weg abzugeben. Continue reading Neue Vorausmeldungsverpflichtung bei Steuerrückerstattung durch Ausländer →

Steuern International

World Tax Advisor 29 March 2019

29. March 2019 Marketing

The World Tax Advisor 22 March includes in particular:

Austria: Austria introduces comprehensive CFC regime
China: VAT rates to be reduced as from 1 April 2019
European Union: EU announces that preparations for no-deal Brexit are complete
European Union: Hong Kong removed from EU watchlist on tax cooperation
European Union: European Commission invites comments on Madeira state aid investigation
Greece: Reduction of withholding and income tax rates on dividends
Italy: New tax return form approved for quarterly VAT refnd claims
Mexico: Proposal released to allow general tax offsettings
Saudia Arabia: GAZT publishes VAT guide in Islamic finance
United Kingdom: HM Revenue & Customs publish no-deal Brexit withholding tax guidance
United States: Treasury department issues policy statement on tax regulatory process
Tax treaty round up

Steuern International

World Tax Advisor 22 March 2019

22. March 2019 Marketing

The World Tax Advisor 22 March includes in particular:

Spain: Spain and UK sign tax agreement on Gibraltar
Australia: Interim digital services tax will not be introduced
Belgium: Federal tax rules to be adapted to new Companies and Associations Code
Bermuda: Bermuda included on updated EU list of noncooperative jurisdictions
Canada: 2019-2020 federal budget highlights
Hong Kong: Laws on tax treatment of financial instruments, tax exemption for funds enacted
Ireland: Proposed VAT amendments post-Brexit
Netherlands: Draft decree contains transition rules relating to non-deal Brexit
Netherlands: Consultation launched on bill on excessive borrowing by individual shareholders
United Arab Emirates: UAE included on updated EU list of noncooperative jurisdictions
United Kingdom: Brexit: Announcements on UK tariffs, Irish border controls in event of “no deal”

Steuern International

World Tax Advisor 15 March 2019

15. March 2019 Marketing

The World Tax Advisor 15 March includes in particular:

Luxembourg: Luxembourg releases draft budget law for 2019
China: VAT rates to be reduced
Colombia: Transitional regime for dividends clarified
European Union: ECOFIN expands noncooperative jurisdiction list
European Union: European Union requests Finland to amend group contribution rules
Germany: BFH allows limited cash pool netting for trade tax purposes
India: Operating guidelines for North Eastern Industrial Development Scheme issued
Italy: Supreme Court, tax authoritites take different positions on dividend WHT exemption
Italy: Clarifications on “portfolio management of investment in real estate”
Sweden: Proposal would allow withholding tax deferral for nonresident loss-making companies
United States: BEAT consinderations for foreign corporations with US branches

Steuern International

World Tax Advisor 8 March 2019

8. March 2019 Marketing

The World Tax Advisor 8 March includes in particular:

European Union: CJEU interprets concept of beneficial ownership in EU directives
Australia: Similar business test now law
Australia: Consultation launched on changes to tax transparency code
British Virgin Islands: Country-by-country reporting guidance notes released
Colombia: Draft resolution provides details of tax treaty mutual agreement procedure
France: Proposed digital services tax legislation released
Germany: Lower house of parliament finalizes Brexit Tax Implementation Act
India: New measures announced to encourage investment in start-ups
United States: Proposed regulations released on deduction for FDII and GILTI

Steuern International

World Tax Advisor 1 March 2019

1. March 2019 Marketing

The World Tax Advisor 1 March includes in particular:

Singapore: Singapore’s Budget 2019 includes extension of certain tax incentives
Germany: Applicability of royalty WHT to payments for online ads under consideration
Hong Kong: 2019/20 budget analysis
India: Beneficial ownership rules amended
New Zealand: Tax Working Group releases final report on the future of tax
South Africa: 2019 budget announced
Spain: Parliament rejects budget bill 2019
Sweden: Public consultation on proposal to expand scope of anti-hybrid rules
United Kingdom: Brexit: Making claims for EU VAT incurred in 2018

Steuern International

World Tax Advisor 22 February 2019

22. February 2019 Marketing

The World Tax Advisor 22 February includes in particular:

Malaysia: Changes to Malysia’s incentive regimes include modifications in line with BEPS action 5
Costa Rica: First draft regulations to implement VAT released
European Union: EU General Court annuls excess profit rulings state aid decision
Germany: Guidance issued on application of trade tax rules following CJEU decision
Guatemala: Detail on suppliers to be reported in monthly VAT returns
Iceland: Ceiling for R&D tax credit increased
Ireland: Public consultation sought views on ATAD interest limitation and hybrid provisions
New Zealand: Interim digital services tax to be implemented ahead of OECD work
OECD: Peer review reports released on treaty shopping and tax dispute resolution
Saudi Arabia: GAZT issues final transfer pricing regulations
Taiwan: Legislation on FTZ activities qualifying for corporate income tax exemption amended
Tax treaty round up

Steuern International

World Tax Advisor 15 February 2019

15. February 2019 Marketing

The World Tax Advisor 15 February includes in particular:

Barbados: New and amended Barbados legislation includes introduction of economic substance test
Australia: R&D bill almost certain to lapse
Ireland: Tax impact of Brexit for UK asset managers and investment funds relocating to Ireland
Malaysia: 2018 finance bill and related legislation enacted
OECD: Consultation document released on tax challenges of digitalization

Steuern International

World Tax Advisor 8 February 2019

8. February 2019 Marketing

The World Tax Advisor 8 February includes in particular:

Peru: Income tax regulations updated to implement significant tax changes in Peru
Belgium: ATAD interest deduction limitation rules apply as from 1 January 2019
Botswana: Transfer pricing, interest deductibility regimes enacted, IFSC regime amended
Denmark: Guidance issued on extension of interest exemption under thin cap rules
European Union: European Commission requests Germany to revise exit tax rules
France: Digital services tax proposal to be presented to parliament
Portugal: 2019 budget law contains corporate, individual and indirect tax changes
South Africa: VAT e-services regulations amended
Thailand: International Business Center regime enacted

Steuern International

World Tax Advisor 1 February 2019

1. February 2019 Marketing

The World Tax Advisor 1 February includes in particular:

Spain: Spain’s budget bill would limit participation exemption, introduce corporate minimum tax
European Union: CJEU AG opines on cross-border use of losses
European Union: European Commission requests Spain to amend reorganization, CbC reporting rules
Germany: Annual Tax Act 2018 introduced
Hong Kong: IRD issues guidance on CbC reporting notification process
OECD: Policy note released on tax challenges of digitalization of economy
Spain: Bill on digital services tax submittet to parliament for approval
United Kingdom: Brexit: VAT statutory instruments laid before parliament
United States: Regulations and other new guidance under section 199A released

Steuern International

World Tax Advisor 25 January 2019

25. January 2019 Marketing

The World Tax Advisor 25 January includes in particular:

Mexico: Tax authorities issue rules for tax offsets and incentives for taxpayers in northern border region
Bulgaria: 2019 tax law changes include partial implementation of ATAD 1
Finland: Changes expected to tax treatment of certain fund types
Germany: New administrative quidance issued on deviations from arm’s length principle
Ireland: Guidance issued on VAT compensation for charities
Korea: 2019 tax reform includes rules to improve efficiency of tax law
Romania: New interest deduction limitation rules in effect
Switzerland: Referendum to be held on corporate tax reform bill
United States: Finland regulations released on transition tax
Tax treaty round up

Steuern International

World Tax Advisor 11 January 2019

11. January 2019 Marketing

The World Tax Advisor 11 January includes in particular:

France: Finance law for 2019 implements ATAD 1 measures, changes tax consolidation rules
Bermuda: Legislation on economic substance passed
China: Final IIT regulations revise draft rules
Colombia: Tax reform legislation includes progressive reduction in corporate income tax rate
European Union: Commission concludes state aid investigation of Gibraltar
Japan: Diet approves 2019 tax reform proposals
Luxembourg: Law implementing ATAD 1 published in official gazette
Netherlands: List of low tax jurisdictions published
Romania: Tax on financial assets of banks introduced
Saudi Arabia: Draft zakat regulations released for public comment
Sweden: New penalty introduced for FATCA/CRS reporting violations
Sweden: Server can be considered a permanent establishment
Uruguay: Requirments relating to free zones modified

Steuern International

World Tax Advisor 21 December 2018

21. December 2018 Marketing

The World Tax Advisor 21 December includes in particular:

Saudi Arabia releases draft transfer pricing regulations
Belgium: Transfer pricing documentation deadline extended
Cambodia: 2019 tax law changes would distinguish between legal and “physical” persons
Cyprus: CbC reporting deadline extended
European Union: CJEU rules German RETT intragroup exemption in line with EU state aid rules
Finland: Final interest deduction limitation rules include changes to group ratio rule
Greece: Capital tax exemption introduced for capital investments in R&D
Italy: Tax amnesty introduced for taxpayers to settle their tax positions
Malta: EU ATAD implemented into domestic law
Netherlands: New income thresholds for highly skilled migrants
Sweden: New precedent on taxation of stock options

Steuern International

World Tax Advisor 14 December 2018

14. December 2018 Marketing

The World Tax Advisor 14 December includes in particular:

News Luxembourg government coalition agreement includes CIT rate reduction, other tax measures
Brazil: Access to mutual agreement procedure expanded
Colombia: Guidance issued on procedure for filing CbC report
Costa Rica: New law makes broad changes to corporate tax rules, introduces VAT
Finland: Corporate income tax proposals would affect LLCs, group contribution regime
Malaysia: Social security coverage extended to foreign workers, including expatriates
Malta: Guidelines on tax treatment of distributed ledger technology assets issued

Steuern International

World Tax Advisor 7 December 2018

10. December 2018 Marketing

The World Tax Advisor 7 December includes in particular:

Barbados IBC and ISRL regimes to be abolished and no new licenses to be granted
Malaysia tax bills include BEPS measures, some Budget 2019 measures
Australia: Draft compliance guidelines on inbound distribution arrangements issued
Bahrain: MOF provides update on VAT implementation
China: Requirements for foreign investors to benefit from deferral of dividend WHT relaxed
Germany: Finance ministers of federals states reach agreement on tightening of RETT rules
India: ITAT rules on proof of residence for salary exemption for work performed overseas
Sweden: Parliament adopts proposal to amend CFC legislation

Steuern International

World Tax Advisor 30 November 2018

30. November 2018 Marketing

The World Tax Advisor 30 November includes in particular

Colombia’s 2019 finance bill proposes significant tax reforms
Bulgaria: Mandatory transfer pricing documentation requirements proposed
China: Tax exemptions granted for bond interest derived by foreign institutional investors
India: Back office support services subject to 18% GST
Isle of Man : Draft legislation on company economic substance published
Netherlands: State Secretary of Finance announces new tax ruling practice
OECD: Guidance released on MLI-synthesized tax treaty texts
Thailand: Transfer pricing law enacted
United States: Proposed regulations released on new business interest expense deduction limitation

Steuern International

World Tax Advisor 23 November 2018

23. November 2018 Marketing

The World Tax Advisor 23 November includes in particular

Switzerland’s FTA announces no new principal company, finance branch rulings as from 1 January 2019
Belgium: Draft transfer pricing circular issued
Malaysia: Budget 2019 includes rate reductions, service tax on imported services
OECD: Update on preferential regime reviews and new standard on substantial activities
Panama: Multinational headquarters regime amended in line with BEPS action 5
Papua New Guinea: Tax measures in 2019 budget include changes to loss carryforward rules
South Africa: 2018 tax amendment bill includes changes to anti-dividend stripping rules