WTS Global VAT Newsletter

EU Member-States

Austria: Higher court confirms the granting of interest for overdue VAT credits

France: First flavour of the planned ambitious e-invoicing and e-reporting reform

Germany I: Sale of admission tickets for events, non-objection regulation

Germany II: Postponed: warranty commitments granted for remuneration as insurance transaction

Hungary: eVAT – What does the new draft eVAT return mean for taxpayers?

Poland: Further changes in the Polish VAT Act

Romania: Implementation of the Standard Audit File for Tax (SAF-T)

Further countries

Ukraine: Taxation of motivational fees

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Germany: TOMS no longer applicable for all non-EU companies as of 2021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

• Belgium: Amendments to the VAT statute of limitations – VAT compliance impact
• Italy: VAT refund in the case of late VAT registration
• The Netherlands: Dutch Supreme Court clarifies the term "essentially new construction"
• Poland: Mandatory e-invoicing as of 2024

Further countries

• Kingdom of Saudi Arabia: Rules and procedures for VAT recovery by licensed real estate developers
• Nigeria: Expected changes to VAT law in 2023

• Hot Topic: Foreign investors in US real property interest – Final regulations on FIRPTA tax exemption for Qualified Foreign Pension Funds (QFPF) issued)
   
• Austria: Married couples are not entitled to apply jointly for refund of capital gains tax
   
• Belgium: Possibility for non-resident investment funds to reclaim Belgian source tax (incl. WHT); Dividends; Interest payments; Belgian real estate income
   
• Denmark: Danish Supreme Court (Højesteret) issues final judgement in the beneficial owner cases on dividends
   
• Finland: Recent Finnish case law considering the tax (WHT) exemption of foreign investment funds
   
• France: An opportunity of tax refund for foreign life insurance companies receiving French source dividends; Quick insight into key VAT measures expected for 2023 and 2024
   
• Germany: International Private Equity funds, the return of capital and German fund investors
   
• India: Key tax proposals arising from the Union Budget
   
• Italy: The Italian Investment Management Exemption: a new safe harbor for asset manager of foreign investment vehicles
   
• Philippines: WHT on Income of Foreign Investors in Philippine Securities
   
• Poland: Reference for preliminary ruling on Polish CIT exemption for self-managed foreign investment funds; Finance Minister's public tax ruling on disclosure duties of real estate companies
   
• Portugal: ECJ rules that marketing of shares in common funds falls within the scope of the Council Directive concerning indirect taxes on the raising of capital(Case C-656/21)
   
• Sweden: Three Finnish public sector pension institutions may be comparable with the Swedish AP funds and be granted a refund of WHT levied on dividend income
   
• United Kingdom: UK IME Investment Transactions List updated with crypto assets

• China: China boosting offshore trading business
• Netherlands: DMS: The new Dutch Customs declaration system
• United Kingdom: Upcoming deadlines for import and export measures in the UK
• Vietnam: “Royalty” fees for imported goods
• Germany: Restrictive measures against Russia and Belarus due to the war of aggression against Ukraine – Current developments

• Australia: Pacific Australia Labour Mobility expansion
• Austria: Income Tax - exemption with progression for non-residents.
• Belgium: Belgian expat tax regime now extended to foreign non-profit organisations
• China: IIT benefits continue for another year
• France & Switzerland: Agreement on the taxation of home office income
• Germany: New Framework for telework between Germany and Austria
• Hungary: Tax allowances and leave in 2023
• Italy: New interpretations of recurring cross-border tax issues
• Netherlands: Exchange of information obligation
• Nigeria: Recent updates on immigration rules
• Poland: New rules on remote work and business trips
• Portugal: Digital Nomad visa and taxation of crypto asset-derived income
• Saudi Arabia: Tax implications of global mobility in KSA.
• Senegal: Senegal raises its personal income tax shield to 43%
   

• Austria: Reserved dividends in the case of share deals
• Belgium: Leveraged distributions challenged by the tax authorities
• Brazil: Impact of contingent consideration on tax amortisation of goodwill
• China: Case study – indirect share transfer
• France: Management package – back to reality?
• Poland: Latest amendments to the Polish restructuring law
• Romania: Consolidation for corporate income tax purposes
• Switzerland: Substance requirements for international investments or group structures
• General: Deals news

Argentina: Suspension of the Argentine Mandatory Disclosure Framework

Austria: No carryforward of withholding taxes

China: China has approved the Multilateral BEPS Convention

Colombia: Colombian tax reform bill 2022

Germany: Council of the EU reaches agreement on global minimum taxation  (Pillar Two)

Poland: Polish holding companies as of 2023

Singapore: Tax treatment of ship pooling arrangements

Argentina: Argentine Tax Court ruling on “Cargill” Transfer Pricing Case

Austria: Intra-Group Financing – Austrian Specifics

Austria: Decision of the Austrian Financial Court regarding Transfer Pricing

Brazil: Superior Court of Justice rules out illegal Methodology to calculate the PRL 60 Method

Chile: 2022 Tax Reform Bill Proposal to update Transfer Pricing Regulations in Chile

France: Research Tax Credit and Subsidies Synergies with Transfer Pricing

Indonesia: Introduction of New Transfer Pricing Methods

Italy: New Arm's Length Range is set for Transfer Pricing

Poland: Administrative Courts condemn Tax Authorities’ unlawful Practices regarding the Questioning of Benchmarking Studies 

Saudi Arabia: Amending Transfer Pricing Instructions to apply to Zakat Payers

Senegal: Transfer Pricing: Systematizing the Control of Reporting Obligations

Thailand: Cash Pooling between related Companies

Ukraine: The War is not an excuse to ignore Transfer Pricing Compliance

United Kingdom: Draft Legislation on the UK TP Documentation Requirements

EU Member-States

Italy: VAT deduction and year-end peculiarities

Poland: recent developments regarding the fixed establishment in Poland

Romania: changes to Romanian Fiscal Code as of 1 January 2023

Further countries

Brazil: federal government reduces tax burden on the import of services

China: national VAT e-invoicing targeted this year

Switzerland: changes to the Swiss VAT landscape as of 1 January 2023

Sub-participations in loans - ECJ judgement of 6 October 2022 (C-250/21)

Consequences of the Cum-Ex-Trades on WHT refund and relief in Austria

The Belgian Constitutional Court decides on the annual tax on securities accounts (ATSA)

Additional taxes for the Belgian financial sector and snowball effect for Belgian regulated investment companies (tax-on-tax)

Reclaim opportunity re Belgian WHT for Luxembourg SICAVs

China: Tax audits on private wealth

Czech Republic: Windfall tax

Draft bill to improve attractiveness of Germany as a Financial Services location

Germany: Court decision: taxation of realized capital gains from fund units in the context of the 2018 tax reform

Italian Tax authorities rule on VAT and income taxes on mining activity

Poland: Changes to banking tax

Changes on Spanish SICAVs

United Kingdom: Autumn Statement 2022 impacts financial institutions

Brazil: Benefits of the drawback regime extended to some services

China: China’s customs relaxes voluntary disclosure rules

Italy: Penalties for customs violations must be proportionate: the Italian Supreme Court takes a clear position against the more than proportional increase in penalties for customs law violations

United Kingdom: UK developments on CDS

United States: Applicability of the First Sale Rule for Non-market Economies

Germany: Appeal in “Hamamatsu” case rejected by German Federal Fiscal Court

Austria: Changes in the taxation of investment income by way of the Austrian tax reform 2022

China: Green channel for foreign loans to high-tech firms

Czech Republic: Taxation of cryptocurrencies & required capital of self-governed investment funds

Finland: Exit tax proposed for individuals

France: French Supreme Tax Court validates the possibility of charging foreign tax credits on the share of costs and expenses on dividends

Germany: ECJ judgement in the case “ACC Silicones” - C-572/20 & draft administrative guidance on duties of cooperation related to crypto assets & new regulation on crypto fund units

Indonesia: Taxation of crypto asset transactions, new regulation as of 30 March 2022

Italy: Important update on WHT reclaims due to recent Supreme Court decisions Poland: Interest on overpaid WHT for third-country investment and pension funds - SAC requests CJEU

United Kingdom: Sovereign immunity from direct taxation, Investment Management Exception, qualifying asset holding companies regime

Argentina: Tax court rules on PE under Belgium-Argentina tax treaty

Austria: Double taxation risk in connection with software as a service

France: Double tax treaties: application of the double tax treaties and beneficial ownership CE, 20 May 2022, n° 444451 Sté Planet

Indonesia: The development of the OECD’s two-pillar solution in Indonesia

Kenya: National tax policy: a more certain future tax regime

Netherlands: The saga on the withholding tax exemption continues

Pakistan: Changes in the corporate tax rate structure

Poland: Polish deal 2.0 – further changes in Corporate Income Tax

Portugal: Remote permanent establishment/remote work

Saudi Arabia: Zakat, tax, & customs authority re-launches tax amnesty initiative

South Africa: The modernisation of South Africa’s tax and exchange control regime

United Kingdom: Pillar 2: draft Income Inclusion Rule (IIR) legislation and consultation response 

EU Member-States

Austria I: New interest rule for overdue VAT credits and claims

Austria II: No Reverse Charge Mechanism in case of rental revenues of foreign property owners

France: Spontaneous regularization of French VAT on distance sales by foreign operators

Germany I: Annual VAT returns: New deadlines and interest rules

Germany II: Federal Fiscal Court: Transfer of vouchers in distribution chains

Further countries

KSA: E-Invoicing Phase II “linkage and integration”

Nigeria: Guideline on VAT requirements of non-resident digital service providers

Europe

Austria: New Info from the Austrian Ministry of Finance – Mutual Agreement Procedure and Arbitration Procedure

Denmark: Mandatory Submission of Transfer Pricing Documentation in Denmark during 2022

France: The SAP Case: The Difficulty for Tax Courts when Handling Negative Interest Rates

Hungary: TP Update

Ireland: The Irish Position on the proposed ATAD3 Directive

Italy: DAC6 Reporting: Year-End TP Adjustment

United Kingdom: APAs, ATCAs and HM Revenue and Customs Statistics

Further Countries

Argentina: Deemed Affiliation: Cross-Border Transactions with Low-Tax Jurisdictions

Brazil: Plan for Brazil’s Accession to the OECD: Changes to Transfer Pricing Rules

Chile: Practical Lessons learned from Transfer Pricing Audits in Chile

China: First Chinese Customs and Tax Collaborative Transfer Pricing Management Mechanism

India: The Indian Revenue’s Measures for effective Dispute Resolution

Kenya: A Fundamental Shift in the Transfer Pricing Regime in Kenya

Senegal: After joining the Multilateral Convention, a Step forward in the Fight against Tax Evasion & Avoidance

Australia: Pacific Australia Labour Mobility (PALM)

Austria: Establishment of a PE through home office activity

Chile: Global mobility in Chile

China: Expatriates’ tax position affected by staycation

Germany/China: Treaty override regarding German assignees working for a Chinese company

Czech Republic: Flat tax in the Czech Republic

France: French pension “impatriate” regime: exemption from affiliation and from payment of pension contributions

Hungary: Working days instead of calendar days and clarification of the concept of base salary

Italy: Italian source pensions paid to non-resident individuals

Luxembourg: Luxembourg cross-border workers situation since 30 June 2022

Netherlands: Update on the 30% ruling and change in the share option tax regime

Switzerland: Swiss source tax revision – notable changes

Thailand: Long-term Resident Program (LTR)

Ukraine: Taxation of individuals working remotely on Ukrainian projects

Germany/Ukraine: Treaty override regarding Ukrainian employees working in Germany

Vietnam: Work permit issues

China: Export tax rebate made easy

Italy: The contrast between the digitalization of the bill of import and the requirements for deducting Import VAT

United Kingdom: Brexit 2022 update – 2

Vietnam: Goods labeling

UK/EU: EU Sanctions developments on Russia/Ukraine

Germany/EU: Restrictive measures against Russia and Belarus due to the war of aggression against Ukraine – Current developments

Argentina: Summary of recent tax news relevant to the FS industry

Belgium: Luxembourg treaty exemption for the Annual Tax on Securities Accounts at risk?

Finland: CJEU dated 7 April 2022 (C-342/20): Finnish WHT exemption in conflict with free movement of capital &

Finland: Finnish Tax Administration reveals malicious companies set up for tax evasion “as a service”

France: Intra-group interest – improvement for taxpayersGermany: Final administrative decree on crypto assets & Decision in ECJ case C-641/17 & “CPP” & Federal Tax Court on cum-/ex-transactions

Italy: Tax ruling on WHT exemption and foreign investment funds (dated 30 March 2022)

Poland: Two Supreme Administrative Court decisions on cryptocurrencies and interest on overpayment

United Kingdom: Changes to Economic Crime Act 2022 & Plans of HMRCs Business Risk Review & Crypto asset developments & Changes to the US Qualified Intermediary Agreement

EU Member-States

The Netherlands: Broader interpretation of conditions for forming a VAT group

Further countries

Chile: VAT changes for services

China: VAT measures to tackle business contraction

Nigeria: VAT obligations of non-resident digital service providers

Vietnam: VAT rate reductions

Argentina: Argentine Supreme Court rules on treaty shopping in the context  of the Argentina-Chile Double Tax Treaty

Brazil: Victory of taxpayers in the Federal Administrative Tax Court: overlapping of Double Tax Treaties and Brazilian CFC rules 

China: New challenges and impacts brought by Pillar Two to Chinese companies

Germany: Pillar Two

India and Austria: International project business – India: Tax trap offshore supplies 

Italy: Italian rules on hybrid mismatches 

Netherlands: ATAD3 

Pakistan: ATIR rules on taxability of split contract arrangements under Pakistan-China Double Tax Treaty 

Poland: Pay and refund – new WHT collection mechanism for passive payments

Singapore and Indonesia: New Singapore-Indonesia Double Tax Agreement takes effect 

Vietnam: Tax exposure of the PE 

Europe

Austria: No annual CbCR notification required since 1 January 2022

Czech Republic: The Czech Supreme Administrative Court’s thoughts on related party definition

France: The RKS case: shades of nuance in TP by the French Supreme Administrative Court

Germany: New case law on the determination of arm’s length interest rates for intercompany loans

Ireland: TP Compliance requirements in Ireland

Italy: New rules on TP documentation

The Netherlands: Netherlands disallows unilateral downward TP adjustments

Poland: Polish regulations on “indirect” transactions with tax havens

Portugal: Amendments to Transfer Pricing legislation

United Kingdom: Outcome of the UK consultation on TP documentation  

Ukraine: Ukrainian Ministry of Finance clarifies new TP rules on business purpose

Further Countries

Brazil: Effects of extinction of LIBOR rate to Brazilian TP controls

China: Deduction of interest charged by related parties  

New Zealand: New BEPS disclosure guidance and preparation forms

Taiwan: Taiwan CFC rules will be implemented as of 2023 in response to the Global Minimum Tax

Austria: Customs law thwarts VAT law

Belgium: E-commerce: Belgium changes VAT rules on importer of record

Brazil: Brazilian Superior Court of Justice defines the calculation of penalty and interest on drawback

Brazil: Ex-Tariff saved from extinction

China: Major updates in China customs

France: The Goods and Services Tax Code – (A way to clarify the applicable rules!)

Hungary: Changes to customs administration in Hungary

Italy: Importer not established in the EU – operative clarifications

Senegal: The recent customs reforms of 20 December 2021

Singapore: Asia’s FTA Spree: benefits galore for businesses but caveat emptor

Sweden: Swedish Import VAT – Is Swedish Customs the competent authority?

United Kingdom: National Security and Investment Act

United Kingdom: Brexit 2022 update

United States: Outcome of “De Minimis” will have Major Effects on E-Commerce Importations and the US FTZ Program

Vietnam: Import of software to Vietnam

Hot topic: ECJ landmark decision in the case C-545/19 (AEVN) dated 17 March 2022

Hot topic: OECD Commentary on Pillar Two

Austria: Supreme Administrative Court on foreign Trusts

Belgium: New fund type – Belgian ELTIF

Belgium: WHT reclaim

China: Change in taxation of equity investments

Czech Republic: New Czech government & increase of interest rate

France: Tax measures on gains from the sale of digital assets

Germany: Economic ownership and securities lending & WHT on crypto fund units

Netherlands: Government proposal to curb dividend stripping

Poland: Supreme Administrative Court on beneficial ownership & Indirect transactions with tax havens

Sweden: WHT for pension funds & VAT treatment of interchange fees in Sweden

UK: HMRC on Implementation of Pillar Two, ISA compliance and Uncertain Tax Treatment & Review of UK funds regime

EU Member-States

Austria: Change in the VAT treatment of rental revenues of foreign property owners

Belgium: VAT registration with a fiscal representative, new rules on guarantees

France: Changes in sight

Germany/EU: Changes to Intrastat reporting

Hungary: VAT changes from 2022

Italy: E-invoicing via SDI extension

The Netherlands: Developments for investment funds and VAT fiscal unities

Poland: Voluntary e-invoice as of 1 January 2022
 

Further countries

China: Changes to indirect tax surcharges

Kingdom of Saudi Arabia: Changes to VAT, invoicing and customs charges

Singapore: Expanding the scope of application of GST

Ukraine: New VAT regulations taking effect in 2022

Recent EU developments with respect to WHT

Argentina: Tightening of the foreign exchange control framework, increase of Corporate Income Tax, taxation of crypto currencies, & Supreme Court decision on interest deduction

Austria: Draft bill on new Austrian tax regime for crypto currencies published  

Czech Republic: Act on Investment Companies and Investment Funds & Green Tax  

Finland: CJEU Advocate General Opinion (C-342/20) on tax exemption criteria designed for contractual funds & Changes to the interest deduction limitation rules 

France: VAT option for banking and financial services (draft bill) 

Germany: Impact of recent Coalition Agreement on the FS industry, Revised CFC rules & Introduction of check the box regime 

India: Taxation of Dividend income 

Ireland: The taxation of crypto currency in Ireland 

Netherlands: Court decisions on German real estate investment fund with Dutch real estate income & Dividend tax refund for UK pension fund 

Poland: Polish Deal – selected WHT issues (incl CIVs) 

Slovenia: Taxation of crypto currencies 

Sweden: Proposed tax on credit institutions & Postponement of new WHT Act 

Switzerland: Reform of Swiss WHT regime & New legal framework on implementation of international tax agreements 

Brazil: Ex-Tariff on the brink of extinction

China: Major updates in China Customs

France: Customs administration – French cultural exception?

Italy: The importer is almost always responsible in case of an untrue certificate of origin

Mexico: CFDI with consignment note complement

Pakistan: Pakistan Single Window (PSW)

United Kingdom: EU export controls on dual-use goods: the latest update

Vietnam: Duty–free goods imported for export production and processing

Europe

Austria: New Austrian Transfer Pricing Guidelines 2021

Belgium: Belgian Transfer Pricing court case: a rare occurrence

France: The Engie Case: an ambitious new approach by the French Tax Administration

Germany: German Federal Ministry of Finance: Administrative Principles 2021 on Transfer Pricing published

Germany: Recent changes on German Tax Law concerning Transfer Pricing

Ukraine: State Tax Service intensifies TP control

Further Countries

Argentina: Transfer Pricing developments in Argentina

Benin: Transfer Pricing Update Benin

Chile: Migration of the approach of the Chilean Revenue Service to segments with greater fiscal impact

China: Responses to practical questions on the Transfer Pricing implications of the COVID-19 impacts15

Nigeria: Transfer Pricing Update on Nigerian TP case

Senegal: Implementation of Action 12 of BEPS project: a strengthened internal tax system

Taiwan: Supreme Administrative Court decides on one-time Transfer Pricing adjustments

Thailand: TP legal framework and practical insights

United States: The US’ role in global adoption of Pillar 1 and Pillar 2 / ongoing conversations in the US on tax reform / a status update on US tax reform

Vietnam: Transfer Pricing Update Vietnam

EU Member-States

Austria: Higher court confirms the granting of interest for overdue VAT credits

France: First flavour of the planned ambitious e-invoicing and e-reporting reform

Germany I: Sale of admission tickets for events, non-objection regulation

Germany II: Postponed: warranty commitments granted for remuneration as insurance transaction

Hungary: eVAT – What does the new draft eVAT return mean for taxpayers?

Poland: Further changes in the Polish VAT Act

Romania: Implementation of the Standard Audit File for Tax (SAF-T)

Further countries

Ukraine: Taxation of motivational fees

Brazil I: Customs Controls to Curb Red Tape

Brazil II: Brazil issues regulation to combat customs fraud

China: Major updates in China Customs

Italy I: Simplifications for authorisation to the “approved place for export”

Italy II:Simplified procedure for relief from the import duties of reimported goods

Mexico I: Changes in customs compliance regulations

Mexico II: New Framework as of 2020 & 2021

Mexico III: New Free Zone in Chetumal, Quintana Roo

Portugal: Brexit implications on customs

Ukraine: New Rules on Authorised Economic Operators Implemented in Ukraine

Vietnam: Vietnam’s implementation of the EU and Vietnam Free Trade Agreement (“EVFTA”)

Germany: Introduction of crypto fund units

Austria: New CJEU decision on VAT exemption

Belgium: Investment funds and the new annual tax on securities accounts

Denmark: Fidelity Funds and 24 June 2021 Supreme Court (Update) – Beneficial ownership – Tax Havens

Finland: Government Budget Proposal – Supreme Administrative Court on taxation of carried interest

Germany: Administrative guidance on securities lending transactions

Hungary: New taxation rules for crypto assets

Ireland: Share Schemes in the Irish Tax System

Italy: Tax exemption on interest from medium / long term loans paid to foreign investment funds – Tax regime of interests on loan granted to Italian tax resident persons by non-resident banks

Luxembourg: Refund of Luxembourg dividend WHT and proof of beneficial ownership

Poland: Polish Deal – WHT scheme, holding companies and VAT option

Switzerland: Substantial reform of Swiss WHT and Stamp Tax

Europe: European Commission Communication on Business Taxation for the 21st century

Austria: Austrian Supreme Administrative Court on beneficial ownership of trademarks

China: Will an expatriate’s China tax position change due to COVID-19?

France: The French Supreme Court refers to the international definitions of permanent establishment

Germany: German registered IP of foreigners subject to tax in Germany

Italy: Step-up and realignment procedure for businesses

Netherlands: Proposal to disallow unilateral downward transfer pricing adjustments

Russia: Russian Federal Tax Service on intragroup services by MNCs to subsidiaries located in Russian Federation

Spain: 5% taxation on dividends and capital gains

United Kingdom: Tax Implications of the 2021 UK Budget

United States of America: Debt Financing in the U.S. – What a foreign investor needs to know

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

Regulations of the BMF letter dated 13.04.2021 on the delimitation of cash benefits and benefits in kind

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

Regions

Asia Pacific: Regional Comprehensive Economic Partnership (RCEP): the world’s largest Free Trade Area and business opportunities in the Asia Pacific region

European Union: E-commerce and new provisions on low-value consignments

Additional country news

China I: China Export Controls 2.0

China II: China launches four free trade zones

Malaysia: ASW – A game changer for ASEAN trade and Customs clearance

Philippines: The Philippines Implements its “Strategic Trade Management Act” (Republic Act No. 10697)

USA: America’s New US President and International Trade: 5 Feb. 2021

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

We are pleased to present this special edition of our Global Mobility newsletter about one of the hottest topics currently: #workfromanywhere

Austria: Wage withholding tax for foreign employers abolished

Bulgaria: COVID-19: what are the implications on employees and employers in Bulgaria in 2021

China: Tax honeymoon for expatriates ending on 31 December 2021

Germany/France: Being prepared for the 2020 French and German tax return filing season

Germany II: New tax return filing obligation for non-residents in Germany

Hungary: Guidance to Social Security and Personal Income Taxation concerns regarding the COVID-19 pandemic

Italy: The Italian tax regime for “impatriates” – Recent amendments

Russian Federation: Migration and Personal Income tax updates 2021

Senegal: Shall a foreign employee, assigned to Senegal to perform a contract signed between its employer and a local company for less than 90 days, file personal income tax in Senegal?

Sweden: Sweden adopts the Economic Employer Concept and expands companies’ obligations to make tax deductions as of January 2021

The Czech Republic: Taxation of income from employment and entrepreneurship since 2021

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

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)

Austria: Home Office work in Austria and consequences due to Covid-19

Chile: COVID-19 crisis, forced permanency and PE

China: Does the coronavirus cause any impact on the IIT of individuals stranded in China?

Costa Rica: Tax treatment for employees staying in Costa Rica

Czech Republic: The influence of anti-COVID measures on tax residence and affiliation to social insurance regulations

Germany: Stay compliant when working from home

Hungary: Expat employees working from home

Italy: Issues related to working from home or remotely during the Covid crisis

Kenya: Virtual work – Tax considerations of the new normal

The Netherlands: Working from home due to the coronavirus: the Dutch tax impact

Poland: COVID-19 tax and social security guidelines still to come

Portugal: Working remotely from Portuguese home office due to thepandemic and beyond

The Russian Federation: Stuck in Russia due to the Corona pandemic

Sweden: Swedish tax liability for individuals during COVID-19

Turkey: Working remotely from Turkey

Ukraine: Migration and taxation issues in times of COVID-19

Vietnam: Does having an employee in Vietnam create a permanent establishment?

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

EU Member-States

Greece: VAT suspension for newly developed real estate properties

Ireland: Reduction VAT standard rate

Further countries

Azerbaijan: VAT action plan

Chile: New VAT Legislation for Digital Services

China: VAT refinement continues

India: Implementation of e-invoicing system for B2B supplies from October 2020

Malaysia: Malaysian Digital Service Tax - Did you miss the boat on 1 January 2020?

Nigeria: VAT changes

EU Member-States

Belgium: Monthly VAT refund for “starters”

Czech Republic: Generalised reverse charge mechanism

Denmark: The export VAT system – cash optimisation

France: VAT cash optimisation

Germany: Temporary cut in VAT rates and extension of payment due dates for import VAT

Hungary: VAT compliance basics for non-residents

Italy: E-invoicing / Proof of transport (EU)
 
Further countries

Angola: COVID-19 and other VAT news

Chile: Relevant VAT changes

Costa Rica: VAT Law since 2019 – basics

Kingdom of Saudi Arabia: VAT rate increase to 15%

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

EU Member-States

France: New tax obligations for online marketplaces

Hungary: Most important changes to online invoice reporting

Poland: Changes regarding taxes as of 2020

Romania: Annulment of split VAT regime
 
Further countries

Angola: Cabinda VAT Special Regime, VAT in LNG Project, Reverse charge in Transitory VAT Regime

Azerbaijan: Amendments to the Tax Code<br />

GCC States I (KSA): Value added tax in KSA

GCC States II (Oman, Qatar and Kuwait): The VAT Marathon – The Clock Is Ticking for Oman, Qatar and Kuwait

Nigeria: Recent VAT updates

Singapore I: Exempting digital payment tokens from GST

Singapore II: Levying GST on imported services

Turkey: Digital Services Tax

Ukraine: Plans to tax supplies of digital services from non-residents

Austria: New wage withholding tax obligation in Austria as per 01/01/2020

Belgium: Belgians working in Luxembourg – 24-days’ tolerance mayincrease to 48 days

China: Announcements concerning the 2019 annual filing of individual income tax (IIT) and the coronavirus pneumonia (COVID-19) epidemic

Costa Rica: Salary Income Tax (SIT) and Social Security Charges (SSC)

France: Tax domicile in France of the corporate executives of French major companies

Germany: New flat-rate tax for Branch Travellers

Italy: Italy’s measures towards future: young people of excellence, sharing of parenthood, rise of smart working

The Netherlands: Workers posted to the Netherlands reporting obligation implemented

Poland: New tax exemption and new rules, if tax still has to be paid

Turkey: Recent Developments in Turkey

Ukraine: Major amendments introduced in 2020 – affecting individuals’ taxation

China: Preferential VAT policies for certain industries

Czech Republic: Start of last stage of electronic sales registration (EET)

Hungary: Online invoicing: experiences and version 2.0

Italy: Italian Digital Service Tax 2020

Portugal: Invoices and other tax-relevant documents: new rules postponed again

United Kingdom I: Making Tax Digital for VAT

United Kingdom II: UK Digital Service Tax

Austria: Limits of temporary relief in the MAP (Mutual Agreement Procedure)

China: Chinese taxation in the era of digitisation

Hong Kong: Hong Kong IRD issues guidance regarding TP Documentation and CbCR

Netherlands: The EU General Court’s judgement in Starbucks’ state aid case

Nigeria: Transfer Pricing in Nigeria – Navigating a Tax Dispute Resolution

Pakistan: A Paradigm Shift in the Approach to Transfer Pricing in Pakistan

Russia: Changes in Russian TP legislation effective as of 2020

Saudi Arabia: Recent developments in KSA transfer pricing

Switzerland: The Swiss Tax Reform coming into force on 1 January 2020

United Arabic Emirates (UAE): Transfer Pricing Regulations in the UAE

Vietnam: 2020 Tax audits in Vietnam for Foreign Invested Companies will focus on TP

Angola: VAT & Special Consumption Tax enter into force on October 1, 2019

China: Refund of unutilized VAT credits

France I: VAT liability for online marketplaces and other measures to fight VAT fraud

France II: Evolution of electronic invoicing in France

Hungary: Summer VAT law amendments

Ireland: Registering for VAT

Italy: Cooperation and enhanced collaboration procedure (“CECP”)

Malaysia: Digital Service Tax

Poland: Mandatory split payment regime in Poland to be introduced from November 2019

Portugal: Invoices and other tax-related documents: new rules postponed

Austria: Reporting and documentation obligations for employee secondments to Austria

Belgium: Changes in tax and social security obligations affecting Belgian companies for benefits granted by foreign affiliated companies

China: China’s new IIT law

France: New income tax collection system

EU-Member States: The new EU Posting of Workers Directive

EU-/EEA-Member States & Switzerland: Business Trips and A1 certificate of coverage

Netherlands: 30% ruling shortened to five years as of 1 January 2019

Sweden: The Economic Employer Concept to be implemented in Sweden

United Kingdom: Brexit update – Social Security implications for Global Mobility

Australia: Australia introduces new Transfer Pricing Guideline for “inbound distributors”

Austria: Horizontal monitoring

Egypt: Egypt’s Transfer Pricing Guidelines

Hungary: Recent developments in Hungarian transfer pricing

Italy: Corresponding adjustments made easier

Saudi Arabia: Tax current developments and their impacts on permanent establishments (PEs)

Gulf Cooperation Council (GCC): Transfer Pricing in the GCC

Republic of Serbia: Interest rates under the arm’s length principle for 2019 fiscal year

South Africa: Extending the scope of transfer pricing rules in South Africa

Thailand: The new Transfer Pricing Act, effective 1 January 2019

Turkey: Current status of the BEPS Action Plan in Turkey from the viewpoint of Turkish legislation

Ukraine: New changes in Ukrainian transfer pricing rules in 2019

Austria: Construction PE – Austrian MoF on influence of trial runs and subcontracting

Azerbaijan: Amendments to the Tax Code of Azerbaijan

Benin: Permanent Establishments – forthcoming developments after introduction of public-private partnership law

Chile: Permanent establishment – a modern concept?

Indonesia: Development of permanent establishment in Indonesia

Malaysia: Permanent establishment: a total revamp or just a formality?

The Netherlands: Changing (Dutch) permanent establishment

Pakistan: Permanent establishment tax regime – key developments and issues

Senegal: For a contract concluded between a Senegalese company and a foreign one, are all the products necessarily subject to corporate income tax (CIT) in Senegal?

Vietnam: Permanent establishment (PE) in Vietnam

Angola: Angola approves implementation of VAT in July 2019

Austria: Austrian Digital Tax Act 2020

Bulgaria: VAT News 2019

China: New VAT policies for tax cuts

France: France introduces its own tax on digital services

Italy: Marketplace to buy & sell VAT fulfilments

Poland I: Important changes in VAT

Poland II: DAC6 Directive – Mandatory Disclosure Rules (MDR) for domestic VAT arrangements

Portugal: Invoices and other tax-relevant documents – new rules

United States I: US Sales & Use Tax vs VAT – What’s the difference?

United States II: US Sales & Use Tax – How to execute post-Wayfair decision

Belgium: Belgian authorities take a more flexible stance on VAT penalties

Bulgaria: Submission of information on sales through online stores

China: New export VAT refunds

Czech Republic: Application for a general reverse-charge mechanism

European Union: E-commerce: New obligations for payment service providers introduced

Germany: Supply of goods via consignment stock as of 2019 – update

Hungary: Most important changes to Hungarian VAT law

Ireland: Changes brought about by the 2019 finance bill

Malaysia: Service Tax on Cross-Border Services – the onus on Malaysian customer or foreign service provider?

The Netherlands: Zero VAT rate for seagoing vessels

Romania: Extension of reverse-charge mechanism for specific transactions until 30 June 2022

Russia: Change of VAT rate in Russia from 18% to 20%: transition period

Austria: The expanded Advance Tax Ruling Procedure

Belarus: Transfer pricing reform in Belarus

Brazil: Benchmark Price and Renowned Research Companies: Challenges in Brazil

Czech Republic: Functional and risk profile identification as a key issue in current transfer pricing controls

Italy: Implementing BEPS Actions 8 to 10

OECD: WTS Global Comments to the OECD Discussion Draft on Financial Transactions

Poland: Poland changes TP regulations

Portugal: Latest news on the implementation of BEPS in Portugal

Russia: Development of TP court practices in Russia

Republic of Serbia: Interest rates in accordance with the “arm’s length principle” for fiscal year 2018

Ukraine: Transfer pricing in figures

Angola: Angola plans implementation of VAT in July 2019

Belgium: VAT exemption for export supplies: concept exporter of record for customs and VAT purposes

Burkina Faso: New regime for taxation of services, intangible goods, transfer of mining research permits and interests on loans

China: VAT refund offered to tech firms

Czech Republic: Draft amendment to the VAT Act as from 2019

Germany I: German draft bill for new regulation of electronic marketplaces

Germany II: Possible implementation of the ECJ Ruling Skandia into German VAT Law from January 1, 2019

Hungary: Online invoice data reporting – first impressions

Ireland: General VAT compliance obligations

Italy I: Mandatory e-invoicing goes live from January 1, 2019

Italy II: VAT group option as from 2019

Kazakhstan: Changes regarding VAT from 2018

Netherlands: VAT topics budget 2019

New Zealand: New Zealand continues to extend online shopping GST rules

Nigeria: VAT – Changes in compliance duties in Nigeria

Romania: General VAT compliance obligations and registration requirements

Russia: VAT regulation and recent changes regarding electronic services

Senegal: VAT changes 2018

Switzerland: New mail order regulations from January 1, 2019

Ukraine: VAT exemption for supply of software products

United Kingdom: Making tax digital – VAT

• Austria: The transparent shareholder
• Brazil: Deadline to disclose the Ultimate Beneficial Owner to the Brazilian Federal Revenue Service
• France: 2018 French finance bill – Individual Tax: Main Provisions
• Germany: Planned limited taxability on the sale of shares in foreign corporations holding German real estate
• Mexico: Bill of amendments to the Mexican federal income tax law inheritance, bequest and gift tax
• Spain: Spanish Supreme Court ends overt discrimination against non-EU/EEA tax residents subject to Spanish Inheritance/Gift tax
• Ukraine: Non-resident individual income taxation: recent trends

Austria: The transparent shareholder

Brazil: Deadline to disclose the Ultimate Beneficial Owner to the Brazilian Federal Revenue Service

France: 2018 French finance bill – Individual Tax: Main Provisions

Germany: Planned limited taxability on the sale of shares in foreign corporations holding German real estate

Mexico: Bill of amendments to the Mexican federal income tax law inheritance, bequest and gift tax

Spain: Spanish Supreme Court ends overt discrimination against non-EU/EEA tax residents subject to Spanish Inheritance/Gift tax

Ukraine: Non-resident individual income taxation: recent trends

Austria: BMF-Info Transfer Pricing Documentation

Brazil: Prevalence of Law provisions over Normative Instructions issued by the Brazilian Federal Revenue Service

China: China updates “beneficial owner” rules

Germany: Contradictory Views on the Pricing of I/C Loans in German Fiscal Courts

Hungary: Brand new TP Decree

India: Recent Transfer Pricing related updates in India

Luxembourg: New Luxembourg intellectual property regime in force

Republic of Serbia: Changes in Corporate Income Tax law related to transfer pricing

Ukraine: Extension of TP control to permanent establishments in Ukraine

The ordinance amending the Energy and Electricity Tax Implementing Ordinance was  published: important information about the resulting legal changes at the turn of the year 2018

Excise duties & energy law

Austria: Prohibition on deduction of incidental acquisition costs for private investors

Belgium: Belgium look-through taxation referred to as Cayman tax, modified as of 1 January 2018. Distributions from trusts mainly the target of this new legislation

Brazil: Statement of Transactions Liquidated in Cash

Brazil: Changes to Tax on Donations and Inheritances in Rio de Janeiro

Italy: Italian Flat Tax Regime

Grand-Duchy of Luxembourg: UBO register very close to being introduced in Luxembourg

Mexico: Capital Repatriation Decree

Portugal: A very competitive tax regime

Switzerland: Tax benefits due to private investments in real estate

United States: 2017 Tax Legislation Impacts All Taxpayers

Finland: Import VAT reverse charged on periodic VAT returns as of 2018

France I: E-invoicing with the Public Administration

France II: Simplifications for the storage of invoices

Germany: Supplies of goods via consignment stocks as of 2019

Hungary: Live invoice reporting as of July 2018

Italy: Main 2018 VAT news

Poland: Optional split payment as of July 2018

Portugal: Main 2018 VAT news

Romania:VAT split payment system – significant changes

Brazil: Adoption of the Resale Price Less Profit method on long-term agreements

China: The developing APA programme

India: India introduces the Final Rules on drawing up the Country-by-Country (CBC) report and Master File (MF)

Latvia: Increased focus on transfer pricing is expected due to fundamental tax reform entering into force on 1 January 2018

Russia: Transfer Pricing Developments in Russia

Slovenia: Increasing tax assessment on transfer pricing 

South Africa: Summary of SA Local and OECD BEPS Transfer Pricing Compliance Requirements

Ukraine: New Draft Law on BEPS implementation

Belgium: Belgium introduces horizontal supervision

Chile: New Sales and Purchases registers

Czech Republic: Amendment to the VAT Act

Denmark: ECJ rules on input VAT recovery on services supplied free of charge

France: New anti-VAT fraud measures

Hungary: The EKAER system as a tool for Hungarian VAT inspections

Ireland: VAT reform affecting e-commerce and electronic publications

Italy: Simplification rules for EC listings/INTRASTAT forms from 2018

The Netherlands: Input VAT revision regarding "expensive services"

Portugal: Import VAT reverse charged on periodic VAT returns

Romania I: VAT split payment mechanism

Romania II: VAT registration and deregistration from October 2017

Switzerland: Changes governing Swiss VAT liability

United Arab Emirates: Introduction of VAT in the Gulf region

Austria: Corresponding TP correction: Direct contact between Austrian and German tax authorities 

Brazil: Brazil’s Request to Join OECD: Changes to Local Transfer Pricing Rules?

Czech Republic: Increasing number and effectivity of tax controls focused on transfer pricing 

Greece: New transfer pricing documentation requirements for Country-byCountry reporting 

Hungary: The implementation of the Country-by-Country Reporting (CbCR)

International: WTS IT tool “WTS CbCR-2-XML Converter”

Japan: Transfer pricing guidebook released in Japan

Luxembourg: New IP regime as of 201

The Netherlands: Should a construction permanent establishment always realise a profit? 

Portugal: Enhancement of tax transparency

Romania: Romania introduces Country-by-Country Reporting

Ukraine: The First Shots in Ukrainian TP Court Practice 

Overview of tax, Social Security and immigrationrelated matters for assignments to and within Europe

Belgium: VAT advance payments for quarterly VAT returns abolished 

Croatia: Input VAT deduction for costs for vehicles 

France: Right of VAT recovery of French permanent establishments

Germany: Increase in the threshold for small amount invoices

Hungary: Live invoice reporting postponed to July 2018

India: New single GST system from July 2017 

Italy: New measures to tackle VAT fraud 

Spain: SII VAT changes

Spain: TRACE-SII ReportingManager (Reporting Tool)

Panama Papers accelerate the process of voluntary disclosures

Austria: Transfer Pricing Documentation implementation provision (VPDG-DV) announced 

Brazil: Country-by-Country Reporting in Brazil 

China: Challenging times come after Base Erosion and Profit Shifting actions

Czech Republic: Ministry of Finance’s discussion paper on the implementation of the ATA 

Germany: German Ministry of Finance publishes circular regarding the use of the company name

India: Recent TP updates in India 

Luxembourg: Transfer pricing developments in Luxembourg

The Netherlands: Incorrect transfer pricing and Dutch penalties 

Russian Federation: Specifics of Transfer Pricing control in Russia 

Ukraine: Update of Ukrainian TP rules in 2017

Austria: Transfer Pricing Documentation Law (VPDG) in force

Belgium: Mandatory TP Documentation Requirements introduced into law

China: China is amending its tax collection law, and scrutinizing outbound payments

Germany: Government Draft regarding the implementation of OECD BEPS’s three-tired documentation concept was published on July 13, 2016

Hungary: New domestic regulations introduced on royalties in the light of BEPS

India: India implements Action 13 Plan of OECD 

Nigeria: Nigeria Gets Set for the Full Implementation of Country-by-Country Report Framework

Norway: Implementation of BEPS-Actions

Poland: Update on the implementation of CbC Reporting in Poland

United States: Proposed Section 385 Regulations 

Australia: Update on the implementation of BEPS measures in Australia

Brazil: OECD BEPS Action 13 Transfer Pricing 

China: When will the BEPS Action 13 transfer pricing requirements be implemented? 

Hungary: BEPS – implementation in Hungary – the sounds of silence 

India: Transfer Pricing in BEPS context – India updates 

Italy: The implementation of BEPS transfer pricing guidance in Italy

The Netherlands: Dutch implementation of BEPS Action point 13: TP Documentation and Country-by-Country Reporting 

Norway: Well prepared to comply with BEPS recommendations

Russia: Russian Federation 

Singapore: Singapore’s evolving transfer pricing regime 

Slovenia: Expected Changes in the Field of Transfer Pricing Documentation 

Ukraine: BEPS in Ukraine: not yet but closer 

United Kingdom: Evolving transfer pricing landscape in the United Kingdom

Australia: Multinational Anti-Avoidance Law & Tax Transparency Initiatives 

Brazil: Cost plus profit as an alternative to resale price less profit

China: Enforcement of BEPS in China 

India: Multiple Year Data + Range Concept 

Italy: Transfer Pricing and Domestic Intercompany Transactions in the Light of the New Legislation

Korea: Korea 2015 Tax Reform Proposals: Reinforcement of Multinational Enterprises (“MNE”)’s Transfer Pricing (“TP”) Information Reporting Requirements 

Latvia: Recent transfer pricing judgements in Latvia leading to increased controversy in application of resale minus method 

Luxembourg: Impact of European Commission’s Fiat State Aid decision on Luxembourg’s transfer pricing practice 

Philippines: Transfer Pricing: One of the 2015 Top Priority Programs in PHL 

Poland: Poland implements BEPS Action 13 

Spain: New CbC reporting obligation and amendments to transfer pricing rules

The Netherlands: Dutch Implementation of BEPS Action Point 13: TP Documentation and Country-by-Country Reporting 

Ukraine: The Variations in the List of Controlled Transactions in Ukraine

United Kingdom: Tax and transfer pricing update on interest deductibility

Important facts to know

Comments regarding the OECD Draft on Transfer Pricing (TP) Documentation and country-by-country (CbC) Reporting

China: Preferential VAT policies for certain industries

Czech Republic: Start of last stage of electronic sales registration (EET)

Hungary: Online invoicing: experiences and version 2.0

Italy: Italian Digital Service Tax 2020

Portugal: Invoices and other tax-relevant documents: new rules postponed again

United Kingdom I: Making Tax Digital for VAT

United Kingdom II: UK Digital Service Tax

Angola: VAT & Special Consumption Tax enter into force on October 1, 2019

China: Refund of unutilized VAT credits

France I: VAT liability for online marketplaces and other measures to fight VAT fraud

France II: Evolution of electronic invoicing in France

Hungary: Summer VAT law amendments

Ireland: Registering for VAT

Italy: Cooperation and enhanced collaboration procedure (“CECP”)

Malaysia: Digital Service Tax

Poland: Mandatory split payment regime in Poland to be introduced from November 2019

Portugal: Invoices and other tax-related documents: new rules postponed

Angola: Angola approves implementation of VAT in July 2019

Austria: Austrian Digital Tax Act 2020

Bulgaria: VAT News 2019

China: New VAT policies for tax cuts

France: France introduces its own tax on digital services

Italy: Marketplace to buy & sell VAT fulfilments

Poland I: Important changes in VAT

Poland II: DAC6 Directive – Mandatory Disclosure Rules (MDR) for domestic VAT arrangements

Portugal: Invoices and other tax-relevant documents – new rules

United States I: US Sales & Use Tax vs VAT – What’s the difference?

United States II: US Sales & Use Tax – How to execute post-Wayfair decision

Belgium: Belgian authorities take a more flexible stance on VAT penalties

Bulgaria: Submission of information on sales through online stores

China: New export VAT refunds

Czech Republic: Application for a general reverse-charge mechanism

European Union: E-commerce: New obligations for payment service providers introduced

Germany: Supply of goods via consignment stock as of 2019 – update

Hungary: Most important changes to Hungarian VAT law

Ireland: Changes brought about by the 2019 finance bill

Malaysia: Service Tax on Cross-Border Services – the onus on Malaysian customer or foreign service provider?

The Netherlands: Zero VAT rate for seagoing vessels

Romania: Extension of reverse-charge mechanism for specific transactions until 30 June 2022

Russia: Change of VAT rate in Russia from 18% to 20%: transition period

Angola: Angola plans implementation of VAT in July 2019

Belgium: VAT exemption for export supplies: concept exporter of record for customs and VAT purposes

Burkina Faso: New regime for taxation of services, intangible goods, transfer of mining research permits and interests on loans

China: VAT refund offered to tech firms

Czech Republic: Draft amendment to the VAT Act as from 2019

Germany I: German draft bill for new regulation of electronic marketplaces

Germany II: Possible implementation of the ECJ Ruling Skandia into German VAT Law from January 1, 2019

Hungary: Online invoice data reporting – first impressions

Ireland: General VAT compliance obligations

Italy I: Mandatory e-invoicing goes live from January 1, 2019

Italy II: VAT group option as from 2019

Kazakhstan: Changes regarding VAT from 2018

Netherlands: VAT topics budget 2019

New Zealand: New Zealand continues to extend online shopping GST rules

Nigeria: VAT – Changes in compliance duties in Nigeria

Romania: General VAT compliance obligations and registration requirements

Russia: VAT regulation and recent changes regarding electronic services

Senegal: VAT changes 2018

Switzerland: New mail order regulations from January 1, 2019

Ukraine: VAT exemption for supply of software products

United Kingdom: Making tax digital – VAT

Finland: Import VAT reverse charged on periodic VAT returns as of 2018

France I: E-invoicing with the Public Administration

France II: Simplifications for the storage of invoices

Germany: Supplies of goods via consignment stocks as of 2019

Hungary: Live invoice reporting as of July 2018

Italy: Main 2018 VAT news

Poland: Optional split payment as of July 2018

Portugal: Main 2018 VAT news

Romania:VAT split payment system – significant changes

Belgium: Belgium introduces horizontal supervision

Chile: New Sales and Purchases registers

Czech Republic: Amendment to the VAT Act

Denmark: ECJ rules on input VAT recovery on services supplied free of charge

France: New anti-VAT fraud measures

Hungary: The EKAER system as a tool for Hungarian VAT inspections

Ireland: VAT reform affecting e-commerce and electronic publications

Italy: Simplification rules for EC listings/INTRASTAT forms from 2018

The Netherlands: Input VAT revision regarding "expensive services"

Portugal: Import VAT reverse charged on periodic VAT returns

Romania I: VAT split payment mechanism

Romania II: VAT registration and deregistration from October 2017

Switzerland: Changes governing Swiss VAT liability

United Arab Emirates: Introduction of VAT in the Gulf region

Belgium: VAT advance payments for quarterly VAT returns abolished 

Croatia: Input VAT deduction for costs for vehicles 

France: Right of VAT recovery of French permanent establishments

Germany: Increase in the threshold for small amount invoices

Hungary: Live invoice reporting postponed to July 2018

India: New single GST system from July 2017 

Italy: New measures to tackle VAT fraud 

Spain: SII VAT changes

Spain: TRACE-SII ReportingManager (Reporting Tool)