WHT reclaim – CJEU Case C-545/19 (“AEVN”) – Update
Belgium: New annual tax on securities accounts introduced
Czech Republic: Taxation of capital gains of German and Liechtenstein tax residents
Denmark: Danish High Court (Landsretten) issues two rulings in beneficial ownership on dividends
Finland: Taxation of crypto assets
France: The new French-Luxembourg tax treaty: comments from the French tax authorities
France: Consequences of the Brexit on direct tax in France
France: E-Invoicing & E-Reporting obligations in France
Germany: Upcoming legislation on crypto assets, new fund types, WHT reclaims and ATAD
India: Tax incentives set to attract global investors
Encashment Tax in Ireland – a recent amendment
Italian tax exemption on dividends paid to foreign investment funds
Luxembourg: New guidance on DTT mutual agreement procedure
Dutch Supreme Court of 9 April 2021 regarding Dutch dividend WHT refund claims
Polish WHT landscape – uncertainty and abeyance since 1 January 2019
Spain: Supreme Court on WHT exemption for sovereign wealth funds
Sweden: Crypto assets
Spring 2021: Reshaping UK‘s tax landscape

Denmark: New model for dividend taxation in Denmark
Finland: Changes to legislation regarding nominee-registered shares
France: French WHT on dividends paid to foreign investment funds
Germany: Digitalization of tax law and tightening of WHT process
Italy: WHT exemption on interest paid to UK [mutual] investment funds (after Brexit): Italian Revenue Agency Ruling n. 125, 24 February 2021
Netherlands: Developments regarding WHT on portfolio dividends
Portugal: Tax litigation associated with WHT on dividends obtained by EU pension funds
Spain: Resolutions of Central Economic Administrative Court, of 8 October 2019
UK’s funds regime to be overhauled

EU Member-States

• Austria: Tax trap with Value Added Tax assessment
• France: Facilitating the reporting obligations of foreign operators
• Germany I: Warranty commitments granted for remuneration as insurance transaction
• Germany II: Supervisory board members as taxable persons
• Hungary: Online invoice reporting and self-billing
• Italy: Input VAT refund via web portal
• Poland: VAT group treatment

Further countries

• Nigeria: Validity of the VAT Act
• Ukraine: Taxation of digital services

EU Member-States

Denmark: Requirements for foreign businesses registered for VAT in Denmark
Germany I: Work deliveries – update
Germany II: ECJ case “Danske bank” and its potential effects on German VAT landscape
Hungary: 5% VAT on new residential properties
Poland: E-invoices as a new solution in the Polish law
Portugal: Update on the reverse charge mechanism for non-resident taxpayers
Spain: Pre303 – a service for everyone

Further countries

Chile: Simplified tax regime for digital services
Kingdom of Saudi Arabia: Tax exemptions for the Special Integrated Logistics Zone entities

EU Member-States

Czech Republic: VAT on rental of residential properties from 2021

Denmark: Consequences of change of intention as to the use of real estate

France I: Timing of input VAT deduction – favourable court ruling

France II: Implementation of an optional VAT Group 7

Germany: TOMS no longer applicable for all non-EU companies as of 2021

Hungary: Administration relief and tightening in Hungary

Ireland: VAT Updates

Italy: Main news regarding VAT compliance

Latvia: New VAT regulations

Further countries

Brazil: A Possible New Future for Digital Taxation

Chile: Mandatory nature of the electronic invoice in Chile

China: E-invoicing for newly registered taxpayers

Nigeria: Finance Act 2020: Highlights of the VAT reform

Oman: Introduction of VAT in Oman

Saudi Arabia: Tax amnesty

United Kingdom: Deadline for UK VAT Refund Applications

Vietnam: Increased efforts to enforce tax payment

EU Member-States
France: VAT reform for e-commerce
Germany I: Reduced VAT rates until 31 December 2020
Germany II: Revised definition of work deliveries

Further countries
Chile: VAT exemption on import of capital goods
KSA: Application of VAT to provision of collateral (liens and mortgages)

Europe
Austria: New Austrian Transfer Pricing Guidelines 2020
France: Self-financing through intangible assets or how to generate significant tax savings
Germany: German Federal Ministry of Finance: Administrative Principles 2020 published
Hungary: Pandemic does not stop TP audits in Hungary
Italy: New Rules on the Transfer Pricing Documentation
The Netherlands: Proposed limitation to Dutch unilateral downward adjustments
Poland: New documentation requirements for transactions with tax havens as of 1 January 2021
UK: UK Consultation on Transfer Pricing Documentation

Further Countries
Argentina: Mandatory Disclosure Framework and Transfer Pricing
Brazil: New ‘Local File’ Requirements in Brazil
Chile: Recent cases on TP – Chile vs Avery Dennison Chile SA (FY 2012)
China: China releases public consultation paper on simplified unilateral APA procedures
Ghana: Ghana introduces new Transfer Pricing Regulations
India: Transfer Pricing Update India
Senegal: Latest Transfer Pricing tax reform implementing Action 12 of the OECD BEPS project
Vietnam: The regulations on the Advance Pricing Agreement (“APA”) and its modification

Europe
France: Proof of the interest rate applied between related companies
Spain: Transposition of directive 2017/1852, of the council of 10 October 2017, relating to the integration of mechanisms or the resolution of tax disputes in the European Union into Spanish domestic law
Sweden: New guidance on financial guarantees
Ukraine: New business purpose test in Ukrainian tax law

Further Countries
Argentina: Argentina adds new transfer pricing documentation requirements for operations with intermediaries
Chile: Adoption of new transfer pricing requirements: master file & local file
Costa Rica: Transfer pricing update for Costa Rica
India: Updates on the Mutual Agreement Procedure (MAP)
China publishes annual APA report
Nigeria: Averting penalties on TP transactions by means of proper TP compliance
Senegal: The Multilateral Convention of OECD BEPS project: Senegal’s position and its impact on its bilateral DTTs
Taiwan: Draft amendments to transfer pricing assessment rule
Vietnam: New decrees on transfer pricing

France: Impact of the crisis on transfer prices
Germany: Suggested draft law on IC financing: typification of the arm’s length principle also applicable to domestic transactions? – A comparison of tax consequences in cross-border and domestic cases
Hungary: Recent Hungarian developments in transfer pricing with a focus on impacts of COVID-19
Italy: The New Italian Law on International tax disputes settlement
Netherlands: “To dip or not to dip, that is the question”
Ukraine: New proportionate TP adjustment rules introduced into Ukrainian tax law since May 2020!
Argentina: “Argentine Transfer Pricing News - 2020 Second Trimester”
Chile: Revision of formal obligations: what to expect
Nigeria: Applicable TP Methods in Nigeria – Analysing prime plastichem Nigeria limited V federal inland revenue services
Pakistan: Transfer Pricing Audit
Taiwan: One-time Transfer Pricing adjustment in Taiwan
Thailand: Transfer Pricing Update
Vietnam: The impact of the new Law on Tax Administration on Transfer Pricing

Argentina: Argentine Transfer Pricing News – 2020 First Trimester
Austria: Implementation of the EU Directive on Tax Dispute Resolution Mechanisms
Belgium: Belgian Tax Administration (BTA) published final version of the circular letter “Transfer Pricing”
Brazil: Dialogue Between Brazil and OECD on the Alignment of Brazilian Transfer Pricing Rules with the OECD Standard
Germany: I/C Financial Transaction and Transfer Pricing: Final OECD Guidance and Germany’s Bilateral Position
Italy: Arm’s Length Range – Recent Case Laws
OECD: Pillar One – Not Only the Taxation of Digital Business Models is Under Discussion!
Poland: New Transfer Pricing Reporting Obligations
Romania: Transfer Pricing update for Romania
Senegal: The New Regulation Provided by Law no. 2018-10 Amending the Senegalese Tax Law on Transfer Pricing
Republic of Serbia: Transfer Pricing Treatment of Purchasing Fixed Assets
Thailand: Transfer Pricing update for Thailand
Turkey: Legislative Works with Regard to BEPS Action 13 are Completed via Presidential Decree No: 2151
Ukraine: Ukrainian Parliament Implements Three-Tier Approach to TP Documentation and Other Important Changes to the Tax Code
Vietnam: Advance Pricing Agreements gaining importance