Category Archives: Steuern International

World Tax Advisor 8 March 2019

World Tax Advisor 1 March 2019

World Tax Advisor 22 February 2019

World Tax Advisor 15 February 2019

World Tax Advisor 8 February 2019

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

World Tax Advisor 1 February 2019

World Tax Advisor 25 January 2019

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

World Tax Advisor 11 January 2019

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

 

World Tax Advisor 21 December 2018

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

 

World Tax Advisor 14 December 2018

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

World Tax Advisor 7 December 2018

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

World Tax Advisor 30 November 2018

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

 

World Tax Advisor 23 November 2018

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

 

World Tax Advisor 16 November 2018

The World Tax Advisor 16 November  includes in particular

  • Finland proposes changes to CFC rules based on EU ATAD
  • Egypt: Updated transfer pricing guidelines issued
  • European Union: Directive allowing reduced VAT rates adopted
  • European Union: Namibia removed from EU list of
    noncooperative jurisdictions
  • Guernsey: Draft regulations on company economic
    substance published
  • Hong Kong: Discussion paper released on proposed
    tax exemption for investment funds
  • Italy: Tax authorities clarify VAT grouping
    rules and VAT treatment of transfer
    pricing adjustments
  • Peru: Due date extended for filing CbC report
    for FY 2017
  • South Africa: SARS proposes penalty for failure to
    file income tax returns
  • United Kingdom: Public consultation on proposed digital
    services tax launched
  • United States: Deadlines to request competent
    authority assistance in transfer pricing
    disputes

 

Filmproduktion in Österreich keine Betriebsstätte (EAS 3404)

Im Rahmen des „Express Antwort Service“ hat sich das BMF mit der Frage der Begründung einer abkommensrechtlichen Betriebsstätte beschäftigt. Im angefragten Fall unterhält eine in Deutschland ansässige Filmproduktions-GmbH (M-GmbH) aufgrund ihrer dauerhaften Tätigkeiten durch eine feste Einrichtung im Inland eine Betriebsstätte in Österreich. Die M-GmbH hält zugleich 100% der Anteile an einer ebenfalls in Deutschland ansässigen Tochter-GmbH (T-GmbH), welche einmalig für rund sechs Wochen in Österreich Räumlichkeiten anmietet und Dreharbeiten im Rahmen einer von der M-GmbH unabhängigen Filmproduktion durchführt. Continue reading Filmproduktion in Österreich keine Betriebsstätte (EAS 3404)

World Tax Advisor 9 November 2018

The World Tax Advisor 9 November  includes in particular

  • Minister of Finance issues decree on exit tax consequences where Germany’s taxing rights are restricted
  • Australia: Guidance issued on transfer pricing and financing arrangements
  • Denmark: Proposals would implement ATAD interest expense deduction limitation rules
  • Hong Kong: Enhanced deduction regime for R&D expenditure in effect
  • Italy: Draft 2019 budget law includes changes to tax incentives
  • Netherlands: Transition rules proposed to apply to shortened term of 30% facility
  • Ukraine: Draft law on BEPS released

World Tax Advisor 2 November 2018

The World Tax Advisor 2 November  includes in particular

  • UK Budget 2018 includes new digital services Tax
  • Australia: ATO releases guidelines on general anti-avoidance and hybrids
  • China: Draft IIT implementation regulations released for public consultation
  • Denmark: New guidance issued on VAT treatment of holding companies
  • Finland: Income register reporting to be introduced from 2019
  • Jersey: Draft legislation on company economic substance presented
  • Netherlands: Consultation launched on measures to implement EU ATAD II into domestic law
  • New Zealand: R&D tax incentive bill introduced to parliament
  • Spain: Draft bills issued on digital services and financial transaction taxes, ATAD measures

World Tax Advisor 26 October 2018

The World Tax Advisor 26 October includes in particular:

  • Thailand approves new IBC regime to replace
    existing HQ regimes
  • Austria: Draft regulation addresses
    requirements under new “horizontal
    monitoring” procedure
  • Brazil: 31 December deadline for disclosure of
    ultimate beneficiary information
  • Denmark: Proposals would implement ATAD
    hybrid mismatch rules
  • Netherlands: Supreme Court confirms CJEU decision
    in fiscal unity cases
  • New Zealand: GST on low-value imported goods:
    Details of proposed regime released
  • United Kingdom: MLI-synthesized treaty with Slovenia
    published

World Tax Advisor 19 October 2018

The World Tax Advisor 19 October includes in particular:

  • Aligning R&D arrangements and transfer pricing for MNEs operating in China
  • Australia: Tax cuts brought forward for companies with turnover under AUD 50 million
  • Australia: Black economy measures draw a wide net
  • Denmark: Significant changes to CFC legislation proposed
  • El Salvador: Tax authorities update tax haven guide
  • Malta: Rules from EU VAT package on e-commerce implemented
  • Netherlands: Amendments announced to 2019 tax package
  • OECD: Residence and citizenship by investment schemes posing CRS avoidance risk identified
  • Thailand: Lower VAT rate extended for another year

World Tax Advisor 12 October 2018

The World Tax Advisor 12 October includes in particular:

  • Ireland budget 2019 includes measures to implement EU ATAD
  • Bahrain: VAT to be introduced as from 1 January 2019
  • Belgium: Cooperative tax compliance program pilot to launch at end of 2018
  • El Salvador: Changes made to information required in transfer pricing report form
  • European Union: EU council agrees on proposals to reform VAT system
  • France: Income tax withholding considerations regarding internationally mobile employees
  • Germany: MOF publishes first draft of Brexit Tax Implementation Act
  • Hong Kong: Overview of tax law changes under new BEPS law
  • Ireland: Taxpayers can be selected for “compliance interventions” based on risk factors
  • Thailand: BEPS-type transfer pricing documentation rules to be introduced
  • United Kingdom: MLI enters into force in respect of UK