Tag Archives: Germany

Steuern International

World Tax Advisor 10 January 2020

10. January 2020 Marketing

The World Tax Advisor includes in particular:

Israel: Israeli Court rules business model change not necessarily sale of functions, assets and risks
European Union: CJEU rules Belgian participation exemption applied with NID infringes EU directive
France: 2020 finance bill becomes law
Germany: Draft law includes long-awaited reform of CFC rules
Germany: Legislation to enact significant changes to transfer pricing rules introduced
India: Company law tribunal rejects scheme of arrangement involving outbound demerger
India: Legislation introducing reduced concessional tax rates and other reliefs enacted
Luxembourg: ATAD 2 implemted into domestic law
Luxembourg: Pre-2015 advance tax decisions cease to have effect from end of 2019 tax year
Qatar: New regulations amend income tax law and introduce transfer pricing requirements
United States: Deloitte Tax summarizes proposed regulations under sections 863-865
United States: Tresury, IRS release section 162(m) proposed regulations
United States: Congress approves tax relief and spending legislation

Steuern International

World Tax Advisor 20 December 2019

20. December 2019 Marketing

The World Tax Advisor includes in particular:

Greece: Greek corporate income tax reform includes corporate and withholding tax reductions
Australia: Revised R&D tax incentive bill introduced into parliament
Australia: Government releases budget update
Barbados: Economic substance legislation repealed and replaced
Germany: ATAD implementation law includes first draft of anti-hybrid rules
Greece: Individual income tax rules revised
United States: Congressional negotiators reach year-end tax deal
Tax treaty round up

Steuern International

World Tax Advisor 13 December 2019

13. December 2019 Marketing

The World Tax Advisor includes in particular:

Luxembourg: Luxembourg publishes guidance on ATA renewal procedure
Australia: Consultation on definition of corporate residency continues
Australia: Revised proposals to expand definition of significant global entity released
Austria: Wage tax obligations for foreign employers revised
Brazil: Divided withholding tax bill under consideration
Germany: Joint Germany-US statement issued on spontaneous exchange of CbC reports for 2018
New Zealand: “You Do The Math” – 10 simple ways to keep Inland Revenue away
OECD: Public comments published on global anti-base erosion proposal
Spain: Domestic administrative court rules on interest withholding tax exemption
United States: Summaries of new BEAT, foreign tax credit regulations
United States: US backs retaliation against French digital services tax

Steuern International

World Tax Advisor 6 December 2019

6. December 2019 Marketing

The World Tax Advisor includes in particular:

Germany: Germany’s upper house of parliament adopts law that introduces R&D tax incentive
Australia: Hybrid mismatch guidance dealing with US GILTI rule released
Australia: Tax authorities confirm compliance approach for related party debt derivatives
China: STA issues new rules for claiming treaty benefits
European Union: Member states fail to agree on compromise proposal for public CbC reporting
Guernsey, Isle of Man, Jersey: Updated guidance on scope and application of economic substance legislation released
Japan: Tax authorities intensify audits of foreign digital service providers
Taiwan: Draft regulations released on undistributed surplus earnings
United States: Final and proposed BEAT regulations released

Steuern International

World Tax Advisor 18 October 2019

18. October 2019 Marketing

The World Tax Advisor includes in particular:

British Virgin Islands: British Virgin Islands publishes economic substance rules
Brazil: Ruling issued on tax treatment of cross-border cost sharing arrangements
European Union: European Council updates list of noncooperative jurisdictions
Germany: BFH rules on constitutionality of discount rate for non-interest-bearing liabilities
Guernsey: Details on introduction of mandatory disclosure regime announced
Guernsey: Guidance on economic substance information required in company tax return issued
India: Secondary adjustment law amended
Jersey: Consultation on introduction of mandatory disclosure regime launched
Jersey: Changes to company rax return form announced
Luxembourg: Limitation of validity period of tax rulings issued before 1 January 2015
OECD: Proposal on challenges of digitalization includes new approach to profit allocation
United Arab Emirates: List of sectors in which increased foreign ownership permitted approved
United States: Additional guidance issued on tax treatment of virtual currency

Steuern International

World Tax Advisor 11 October 2019

11. October 2019 Marketing

The World Tax Advisor includes in particular:

OECD: OECD Secretariat issues proposal for unified approach to certain tax challenges of digitalization
Germany: BFH changes view on domestic transfer pricing adjustments in tax treaty cases
India: CBDT clarifies brought forward losses, MAT credit if company opts for lower tax rate
India: ITAT rules contributions to overseas superannuation fund are taxable perquisite
New Zealand: Positive business tax changes announced
New Zealand: Transfer pricing simplification measures aim to reduce compliance costs
Peru: Application of general anti-avoidance rule clarified
Peru: Supreme Court decision clarifies deductibility of accrued expenses
Sweden: 2020 budget bill proposal presented by the government, Centre Party and Liberal Party
Taiwan: Advance application available to determine taxable domestic-source income
United Arab Emirates: Guidance on economic substance released

Steuern International

World Tax Advisor 27 September 2019

27. September 2019 Marketing

The World Tax Advisor includes in particular:

European Union: EU General Court rules in state aid cases on transfer pricing rulings
Colombia: Tax exemption for creative and technological added-value industries clarified
Denmark: Changes proposed to transfer pricing legislation
European Union: AG opines on Belgian participation exemption applied with notional interest deduction
Germany: Upper house recommends further changes to planned amendments to RETT rules
Germany: BFH rules on possibility of tax-free repayment of capital by non-EU subsidiary
Greece: Specific and general anti-avoidance rules clarified
India: Corporate tax rates significantly reduced, along with other tax relief
India: CBDT introduces e-assessment scheme, 2019 for assessment proceedings
India: High Court rules on tax rate applicable to Indian PE of foreign bank
Russia: Reclassifying active income as passive income
Russia: Update on beneficial ownership status for holding companies
United States: Proposed regulations address section 382 built-in gains and losses
Tax treaty round up

Steuern International

World Tax Advisor 6 September 2019

6. September 2019 Marketing

The World Tax Advisor includes in particular:

Australia: Australian tax authorities publish draft practical guidance on arm’s length debt test
Argentina: Foreign currency control rules introduced
Czech Republic: Consultation held on introduction of digital services tax
Germany: Audits focusing on insurance premium tax relating to intragroup contributions
Guatemala: Constitutional Court ends suspension of rules lifting bank secrecy
Hong Kong: IRD further updates changes to guidance on deduction of foreign taxes
Korea: 2019 tax reform proposals announced
Singapore: Further details issued on extension and refinement of tax incentive schemes
United States: Court of Appeals affirms Tax Court decision in Amazon case

Steuern International

World Tax Advisor 28 June 2019

28. June 2019 Marketing

The World Tax Advisor 21 June includes in particular:

Japan: Japan’s enhanced earnings stripping rules align with action 4 of BEPS project
Brazil: Tax treaty signed with Uruguay
European Union: CJEU rules on applicable social security system for activities performed outside EU
Germany: BFH asks CJEU ro rule on scope of VAT exemption for commercial education services
India: GST Council recommends further extension of GST return filing deadline for 2017-18
Italy: Supreme Court rules on tax residence of holding company
Malaysia: Update on implementation of service tax on imported digital services
OECD: MLI matching database expanded, more countries sign/deposit ratification instruments
United States: Ninth Circuit Court of Appeals reverses Tax Court in Altera
United States: New regulations addressing GILTI issues, foreign tax credits, section 245A summarized
United States: Joint Committee on Taxation releases overview of Qualified Opportunity Zones
Tax treaty round up

Steuern International

World Tax Advisor 14 June 2019

14. June 2019 Marketing

The World Tax Advisor 14 June includes in particular:

Germany: German BFH clarifies taxation of carried interest from certain fund structures
Colombia: Guidance issued on tax amnesty program
Costa Rica: New draft rulings cover implementation of VAT for cross-border digital services
Italy: Clarifications provided on use of tax attributes to offset additional tax assessed
News Zealand: GST rules for nonresident retailsers selling to New Zealand consumers a step closer
New Zealand: Administrative approach agreed on for determining PoEM
Panama: Country-by-country reporting regulations introduced
United States: Joint Committee on Taxation releases overview of GILTI, FDII regimes
United States: Proposed regulations released on interests held by foreign pension funds

Steuern International

World Tax Advisor 7 June 2019

7. June 2019 Marketing

The World Tax Advisor 7 June includes in particular:

OECD releases program of work on tax challenges arising from digitalization of the economy
China: Guidance issued on taxation of income from stock incentive plans
Finland: Foreign entities may be required to register for VAT in certain cases
Germany: Lower tax court rejects MOFs position on CJEU ruling on anti-treaty shopping rules
Germany: Draft law on R&D tax incentive submitted to upper house of parliament
India: ITAT rules on availability of domestic foreign tax credit where a tax treaty applies
Pakistan: New tax amnesty includes opportunity to disclose “benami” property
Poland: Proposed changes to VAT law include introduction of split-payment mechanism
Portugal: New decree makes further revisions to invoicing requirements

Steuern International

World Tax Advisor 24 May 2019

24. May 2019 Marketing

The World Tax Advisor 24 May includes in particular:

Switzerland: Swiss voters approve corporate tax reform bill
Australia: Coalition government returned: tax agenda
Barbados: Barbados removed from EU list of noncooperative jurisdictions
Bermuda: Bermuda removed from EU list of noncooperative jurisdictions
Germany: Highlights of VAT measures in draft annual tax act for 2019
India: High Court rules withholding tax exemption available under Mauritius tax treaty
Italy: New VAT rules enacted for online marketplaces
Poland: Withholding tax rules affected by new beneficial owner definition
Sweden: Ruling on loss forfeiture on change of control of loss-making company
United States: Proposed regulations issued on ownership attribution to determine CFC relatedness
United States: Final regulations address deemed repatriation of earnings to domestic corporations

Steuern International

World Tax Advisor 17 May 2019

17. May 2019 Marketing

The World Tax Advisor 17 May includes in particular:

Austria: Draft bill addresses Austria’s taxation of digital economy
Brazil: New disclosure requirement introduced for crypto asset transactions
European Union: European Union invites comments on Luxembourg state aid investigation
Germany: Ministry of Finance publishes draft law to amend RETT rules on share deals
India: High Court rules on validity of amalgamated company’s revised income tax return
United States: Final regulations issued on recognition and deferral of section 987 gain or loss
United States: Proposed regulations released on certain partnership interest dispositions

Steuern International

World Tax Advisor 12 April 2019

12. April 2019 Marketing

The World Tax Advisor 12 April includes in particular:

Australia: Australian Full Federal Court decision affects private investment funds
European Union: CJEU finds certain sale and leaseback transactions are outside scope of VAT
Germany: BFH on trade tax exemption for partner in real estate managing partnership
Germany: BFH rules merger gain is tax exempt in upstream merger in fiscal unity cases
Nigeria: FIRS guidelines on mutual agreement procedure
OECD: Expansion of ICAP pilot announced at Forum on Tax Administration meeting
Panama: Tax fraud criminalized
United Kingdom: Guidance issued on social security contributions in event of a no-deal Brexit
United Kingdom: Further extension to 13th Directive claims deadline for US businesses

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 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 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