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 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 25 October 2019

25. October 2019 Marketing

The World Tax Advisor includes in particular:

OECD: Budget 2020 includes measures to promote investment and support SMEs
Colombia: Constitutional Court revokes most of recent tax reform due to procedural defects
European Union: CJEU upholds Belgian notional interest deduction
France-Luxembourg: Amendment to new France-Luxembourg treaty clarifies elimination of double taxation
India: SEBI simplifies regulations for foreign portfolio investors
Mexico: Revised tax reform proposals would benefit private equity structures
Mexico: Tax fraud to become type of organized crime
Norway: Budget 2020 amends interest expense deduction limitation rules, R&D incentives
Portugal: Invoice processing and storage rules clarified
Tax treaty round up

Steuern International

World Tax Advisor 23 August 2019

23. August 2019 Marketing

The World Tax Advisor includes in particular:

Luxembourg: Draft law to implement ATAD 2 in Luxembourg released
Barbados: Policy notes give effect to certain tax measures from budget
Brazil: Deductibility of certain royalty payments to foreign shareholders clarified
European Union: Finland SAC refers case involving Luxembourg SICAV to CJEU
Hong Kong: IRD issues guidance on application of PE profit attribution rules
India: ITAT rules reimbursed salary costs of seconded employee are not FTS
Ireland: Feedback statement published on consultation on ATAD anti-hybrid provisions
Italy: Implementing measures issued for transmission of data by online marketplaces
Trinidad and Tobago: Tax amnesty available for various direct and indirect taxes
United States: Tax implications of US site or services PEs of Chinese companies
United States: Impact of foreign tax credits on base erosion minimum tax amount
Tax treaty round up

Steuern International

World Tax Advisor 10 May 2019

10. May 2019 Marketing

The World Tax Advisor 10 May includes in particular:

India: “Users” may be basis for attribution of profits to Indian digital PE
Austria: Tax court rules on VAT tretment of roaming services provided by foreign companies
India: CBDT committee releases draft report on attribution of income to PEs
India: Appellate authority upholds levy of GST on “black office” support services
Japan: Continuity of control requirement for minority squeeze-out transactions relaxed
Luxembourg: MLI to enter into force as from 1 August 2019
New Zealand: Permanent establishment anti-avoidance guidance finalized
New Zealand: Changes made to facilitate self correction of tax returns
United States: 2019 BEPS global survey published

Steuern International

World Tax Advisor 3 May 2019

3. May 2019 Marketing

The World Tax Advisor 3 May includes in particular:

Singapore: Singapore tax authorities to publish summarized advance rulings
British Virgin Islands: Draft Economic Substance Code released
Denmark: Eastern High Court rejects dividend WHT refund claims by nonresident UCITS
Denmark: VAT rules on triangular transactions revised
Japan: OECD’s hard-to-value intangibles approach to apply
Jersey, Guernsey, Isle of Man: Guidance on economic substance legislation released
Luxembourg: 2019 budget law approved
Netherlands: Decree issued on state supervision of investment funds
Qatar: Guidance issued on transitional application of new income tax law

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 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 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 17 August 2018

17. August 2018 Marketing

The World Tax Advisor 17 August 2018 includes in particular:

Curaçao’s preferential tax regimes revised to bring them in line with BEPS standards
Bangladesh: Finance Act 2018 contains new definition of PE/”business connection” concept eliminated
Kosovo: Proposed changes to corporate income tax law include new definition of PE
Luxembourg: Tax authorities clarify treatment of virtual currency
Peru: Master file and CbC reporting requirements clarified
Ukraine: Tax on distributed profits proposed to replace corporate income tax
Tax treaty round up
Global tax alerts

Steuern International

World Tax Advisor 11 May 2018 – Connecting you globally

11. May 2018 Marketing

The World Tax Advisor 11 May 2018 includes in particular:

Luxembourg parliament considering introduction of VAT group regime
Argentina: Decree clarifies VAT collection on services provided by nonresidents
Austria: Draft bill includes measures to transpose EU ATAD into domestic law
Caribbean and Bermuda countries: First CRS reports due in 2018 for non-early adopter jurisdictions
Costa Rica: Tax reform proposal would replace GST with VAT and tax capital income
Luxembourg: Tax authorities to examine transactions with jurisdictions on EU list of noncooperative countries
Panama: Transfer pricing information reporting form modified
United States: Administration delays tariffs on steel and aluminum
Global tax alerts

Steuern International

World Tax Advisor 27 April 2018 – Connecting you globally

27. April 2018 Marketing

The World Tax Advisor 27 April 2018 includes in particular:

New Luxembourg-France tax treaty aligned with 2017 OECD model
China: SAT updates guidance on interpretation of tax treaties
Cyprus: New tax treaty with the UK contains BEPS-related measures
Malaysia: Guidance issued on tax treatment of digital advertising provided by a nonresident
Nigeria: Voluntary disclosure regime extended
Puerto Rico: Draft tax reform bill includes reduction in corporate income tax rate
Sweden: Proposal to restrict deductions of interest expense revised