WTS Newsletter

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

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

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

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

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

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

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?

• 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: 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 

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: 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