Philipp Schwegmann is taking over the expansion of the service portfolio at the Hamburg office by setting up a local deal advisory team.

Austria's new government faces a challenging economic outlook, aiming to provide tax relief while introducing levies to boost treasury revenues. These measures could impact the financial services industry. Explore the changes in this article, prepared by our colleagues at ICON (WTS Global in Austria).

News on tax developments affecting the international Financial Services industry.

A recent article analyzes foreign pension fund taxation under EU free movement of capital rules, covering WHT on dividends and insights from both EU/EEA and third-country perspectives.

Budget 2025 introduced tax measures to encourage domestic listings and investments and support the growth of insurance companies, Registered Business Trusts (“RBTs”), S-REITs, and other segments of the financial ecosystem.

The CJEU judgement of 19 December 2024 has important implications for foreign companies investing in Spain that incur losses in their country of residence and that cannot recover the WHT on the income derived from their investments in Spain.

The SAC’s ruling has a major direct impact on financial operators established in Finland and possible more general impact on questions concerning the application and interpretation of the VAT Directive.

A key ruling may reshape VAT obligations for Finnish and EU financial institutions outsourcing loan management, impacting compliance, servicing agreements, and operational costs.

The Netherlands’ 2025 tax overhaul reshapes fund classification rules—this article explores its impact on foreign investors, fund structures, and the shift from opaque to transparent entities.

In this article, we explore the impact of recent Belgian case law on Luxembourg UCIs and their potential to reclaim subscription tax under the Belgium-Luxembourg tax treaty.

CJEU's February 2025 ruling may reshape Polish WHT exemption rules for foreign investment funds—key implications for internally managed structures.

Explore Employment Tax Year End Overview from FTI Consulting, which summarizes key deadlines and changes for employers in the new tax year 2025/26.

Discover the key differences in how EU member states are implementing the new EU Emissions Trading System 2 (ETS2), which targets sectors like buildings and road transport. Learn how these variations impact businesses and energy prices across Europe.

Join our webinar to explore key policy shifts from the Trump Administration and how businesses can adapt to navigate the evolving tax and trade landscape for risk mitigation and growth.

Discover Zimbabwe's promising investment landscape, fueled by vast natural resources, strategic positioning in Southern Africa, and ongoing reforms. With opportunities across mining, agriculture, and tourism, the country offers significant growth potential.

Explore Togo's evolving exchange control regime, shaped by UEMOA regulations and recent reforms. Learn about its legal framework, current trends, and the opportunities for businesses in a dynamic financial landscape.

In 2024 South Africa was the largest economy in Africa with a GDP of over USD 400 billion. It furthermore has the most diversified and industrialized economy in Africa.

Positioned along the Atlantic coastline of West Africa, Sierra Leone is a nation rich in heritage, culture, and natural wealth. With a population exceeding 8 million and a GDP of around $4 billion, Sierra Leone presents a distinctive investment opportunity.

Senegal, in 2024, is a leading African investment hub, fueled by growth in energy, infrastructure, and agriculture. With political stability, modern infrastructure, and investor-friendly reforms, it provides access to ECOWAS and AFCFTA markets, offering tax incentives for sustainable investments.

Nigeria, Africa’s largest economy, offers vast investment opportunities with a population of over 200 million. Rich in natural resources, including oil and gas, the country is diversifying into agriculture, technology, and manufacturing, making it an attractive destination for investors.

Discover Liberia's untapped investment potential in sectors like natural resources, agribusiness, infrastructure, tourism, and fintech, highlighting its strategic location, government incentives, and growing market opportunities.

In this article, explore Kenya's growing economy, its favorable business environment, and the regulatory framework governing foreign exchange, highlighting key opportunities for investors in various sectors.

We are delighted that our VAT unit, which has over 145 employees, has once again been awarded the top star rating of 5 stars in the current JUVE Tax Market Ranking.

Ghana, with a population of about 33 million located in West Africa provides an opportunity to investors with a wealth of natural resources such as cocoa, gold, oil, timber, and gas. Ghana is known for its political stability, providing a secure environment for business operations.

Ivory Coast is a top investment hub in Francophone West Africa, offering stability, rich resources, and business-friendly reforms. Explore its exchange control regulations and financial trends.

Under President Donald J. Trump, US trade policy has undergone significant changes through a new tariff package designed to reduce trade deficits and strengthen the domestic economy, with far-reaching effects on international trade relations and the global economy.

EQT, through the EQT X fund, becomes an anchor investor in WTS Germany, providing significant growth capital as part of a long-term and comprehensive strategic partnership.

Recent tax developments on the continent.

In this article, we explore Benin's exchange control regime, covering key laws, regulatory priorities, intercompany transactions, enforcement agencies, sanctions, and trends, including the evolving stance on cryptocurrencies.

The ratification of the SA/Kuwait protocol represents a pivotal development in the tax relationship between the two countries. The changes introduced by the protocol, particularly those related to dividends, have far-reaching implications for Kuwaiti, Dutch and Swedish investors in SA companies.

Adopted in line with the forecasts set out in the Initial Finance Act (PLFI), the Finance Act for 2025 introduces several major tax reforms aimed at modernizing tax administration and enhancing transparency.

Effective January 2025, Nigeria's FIRS issued Guidelines for Advance Pricing Agreements (APAs) to enhance transparency and manage transfer pricing disputes, ensuring compliance with the Arm’s Length principle.

In the recent case, the Supreme Court of Mauritius ruled in favor of Alteo Energy Ltd, overturning the ARC's decision on tax exemption for interest income, emphasizing strict interpretation of tax laws. 

Kenya's Significant Economic Presence Tax (SEPT) replaces the Digital Service Tax (DST) to better capture revenue from non-resident digital service providers, aiming to boost tax revenue but posing compliance challenges.

Following Julie Essiam's resignation, Ghana's President appointed Anthony Sarpong as the new Commissioner-General of the GRA. Major tax reforms in the 2025 Budget aim to ease economic pressure, including the abolition of several taxes and VAT reforms.

EQT, through the EQT X fund, becomes an anchor investor in WTS, providing significant growth capital as part of a long-term and comprehensive strategic partnership.

WTS Advisory GmbH has advised Instalco, one of the leading installation companies in the Nordic region, on the acquisition of a minority stake in Fabri AG. ...

The Tax Flash – Budget Edition from WTS Renmere provides an overview of tax and exchange control proposals announced in the 2025 Budget Speech of the National Treasury (RSA).

WTS PSP AI extends the plAIground with numerous features that are available in a completely new interface. At the same time, the company is establishing an innovative training concept for artificial intelligence with the AI Campus

The Cyprus government is poised to implement its most comprehensive tax reform since 2002. Explore the key preliminary proposals presented on the 26 of February 2025. 

The purpose of this note is to provide a didactic presentation of the reporting obligations, particularly aimed at the many "small groups" subject to Pillar Two regulations which are still at the beginning of their project and the French subsidiaries of foreign groups subject to this regulation.

This article summarizes the 2025 Finance bill, enhancing the global minimum tax regime with OECD instructions on deferred taxes and "transparent" entities, effective for financial years ending after Dec 31, 2024

WTS Advisory AG has exclusively advised the shareholders of the Netz16 Group (Netz16 GmbH, Netz16 Hosting GmbH, digisoolut gmbh, ParIT GmbH and Fundwerk GmbH & Co. KG) on a strategic partnership with accompio GmbH (“accompio”) on an exclusive basis.

WTS has advised hVIVO Group on the acquisition of two research units of CRS Clinical Research Services Management GmbH on financial and tax matters.

WTS has advised hVIVO Group, a global leader in clinical trials and laboratory services, on the acquisition of the shares in two research units of CRS ...

WTS Digital, the digital unit of the WTS Group, is pleased to announce a premium cooperation with software provider Lucanet. As part of this partnership, WTS Digital will provide 1st level support for joint customers, ensuring seamless support. 

Yesterday evening, WTS, a global full-service provider for tax advisory services and financial & deal advisory, celebrated its 25th anniversary. What once began as a small start-up is now one of the leading consulting firms in its segment with 14 locations, over 1,600 employees and an annual turnover of around 242 million euros - and the future promises further growth.

WTS Advisory GmbH (“WTS Advisory”) has prepared a vendor financial due diligence for kfzteile24, a leading omnichannel platform in the automotive aftermarket, as part of a refinancing of the kfzteile24 Group by ...

News on tax developments affecting the international Financial Services industry.

Explore recent updates to Singapore's tax incentive schemes for funds. Singapore continues to refine its tax incentive schemes for both offshore and onshore funds managed by Singapore-based fund managers.

HMRC recently released Transfer Pricing Guidelines for Compliance, a clear framework for compliance to provide tax-payers with more guidance but with increased scrutiny and potential risks for those who fall short.

Serbia's tax framework treats portfolio investors and majority shareholders equally, creating potential disparities. Explore how WHT, DTTs, and the need for reforms impact cross-border investments and market competitiveness.

This article delves into the evolving Polish WHT regulations on passive income, examining recent rulings on exemptions for dividends, interest, and royalties, impacting international industry groups.

In November 2024, a new decision from the Norwegian Tax Appeals Board (SKNS1-2024-97) was published regarding the refund of withholding tax for a RIC resident in the US. The decision implies that more shareholders may be entitled to a refund of withholding tax.

This article covers key insights on new rules for taxation of crypto-assets and changes to the taxation of employee shares in the Czech Republic.

On 7 November 2024, the European Court of Justice (CJEU) issued a judgment (XX, C-782/22) regarding the levy of dividend withholding tax (DWT) on foreign insurance companies in light of the European free movement of capital.

In December 2024, the first foreign investment fund received a tax refund under EU law, following a key German court ruling. However, securing timely WHT refunds requires applicants to navigate complex procedural, operational, and documentation challenges.

Liechtenstein's favorable tax rates attract international tax planning, but legal conflicts with Austria can lead to double taxation. A recent Austrian Fiscal Court case highlights the risks of complex tax avoidance schemes. 

Recent tax developments from nine countries on the continent.

The business climate in Togo has experienced significant upheaval in recent months, particularly in terms of tax and customs regulations. These changes, primarily affecting international transactions, warrant the attention of large multinational groups due to the disruptions they are causing.

The South African Revenue Service will soon replace PN31 with section 11G of the ITA, governing deductions for expenses incurred in producing interest income. This will apply to years of assessment starting after 1 January 2025.

Senegal is modernizing its VAT framework for digital services, aligning with global standards. This article outlines the key features of the VAT regime on digital services.

In this article we highlight crucial changes that would arise from the Nigerian tax reforms, including CIT, VAT, and PIT. 

In Mauritius, Limited Partnerships are tax-transparent, with partners taxed on their income share. New laws introduce a 2% Corporate Climate Responsibility Levy on chargeable income, with certain exemptions.

Corporate governance is key to organizational success, driving trust, transparency, and sustainability. In Kenya, frameworks like Mwongozo guide businesses, enhancing performance and aligning with global trends like ESG.

The Ghana Revenue Authority has launched the second phase of its Electronic VAT Invoicing System, onboarding 2,000 VAT-registered businesses. Additionally, Ghana is negotiating income tax treaties with several countries.

The Egyptian Tax Authority (ETA) has issued guidelines for applying transfer pricing rules under Income Tax Law No. 91 of 2005, ensuring fair taxation of transactions between associated enterprises in Egypt and abroad.

Côte d'Ivoire’s 2025 Tax Appendix focuses on boosting revenue, supporting businesses, and tackling climate change. Key reforms aim to strengthen state resources and ensure inclusive, sustainable economic growth.

The VAT chain reform introduces new compliance measures and deadlines, impacting taxpayers starting 1 January 2025. Key changes include new filing deadlines, VAT credit management, and stricter penalties.

Luxembourg VAT authorities have issued a Circular providing clarity on the VAT position of Independent Directors. The guidelines outline refund procedures, eligibility, and deadlines for reclaiming undue VAT.

Explore the new flyer on personnel secondment in Italy, created by WTS R&A. The flyer covers key insights on VAT treatment, recent legal changes, and the impact of the CJEU ruling on Italian tax law.

Cyprus IP regulations incentivize R&D in Qualifying Intangible Property (QIP) to promote innovation, aligned with EU & OECD standards.

We are thrilled to share with you a roundup of significant updates from December 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions.

WTS Advisory GmbH (“WTS Advisory”) advised Nexus AG in the context of the voluntary public takeover offer of Project Neptune Bidco GmbH (TA Associates). A fairness opinion (IDW S 8) was prepared for ... 

This article begins a series on ESG components and tax sustainability, focusing on actions and data to meet rising stakeholder expectations. Future articles will cover Stakeholder Engagement and Environmental topics.

Discover the new Transfer Pricing framework in Cyprus created by WTS Cyprus, covering TP rules, documentation, filing obligations, and statutory requirements.

Explore the Doing Business in Ghana Guide 2024 by WTS Nobisfields - your personal guide to the Ghana's legal and taxation system and beyond.

WTS, a global full-service provider of tax advisory and financial & deal advisory services, is further expanding its partnership with three long-standing key players from the Tax and Digital business units as of December 2, 2024. 

WTS PSP AI enters into a content partnership with the Otto Schmidt publishing group and a technology partnership with the AI company Taxy.io. 

Estonia plans to introduce a 2% profit tax in 2025 to support defense funding, impacting both individuals and companies. The tax is expected to last until 2028.

Austria’s Pillar Two rules allow the ultimate parent entity to designate a "single taxable CE" for top-up tax, with the declaration to be filed via FinanzOnline by 31 December 2024.

The European Court of Justice decided on November 7, 2024, that the levying of withholding taxes on dividends received by foreign insurance companies on their investments relating to unit-linked insurance policies can violate EU law.

Nuwaru rebrands as WTS Australia, expanding in Australia, New Zealand, and Asia. It offers comprehensive tax services with a focus on AI and technology, positioning itself as a trusted partner for global clients.

WTS, a global full-service provider for tax advisory services and financial & deal advisory, continues to grow and achieved record group revenue of € 241.9 million in the past financial year 2023/24.

Get the latest on Pillar Two with WTS Global’s overview of implementation status and registration requirements in 72 countries, updated monthly by our tax experts.

Since 1 August 2024, the reporting of actual emissions has been mandatory for every CBAM good imported into the EU. Our article highlights the new requirements and responsibilities for companies that must submit CBAM reports.

WTS Global wrapped up its 2024 Global Week, welcoming Jürgen Scholz as Chairman and focusing on AI-driven growth and new client-centered partnerships.

WTS Advisory welcomes Georg Schürmann as new Of Counsel. The former Managing Director of Triodos Bank Germany is one of the pioneers in the field of sustainable finance ...

Foreign entities owning real estate in France could face a 3% annual tax unless they meet specific disclosure requirements. Recent court rulings highlight key conditions for tax exemptions.

Recent tax developments from nine countries on the continent.

In 2024, South Africa proposed amendments to Section 7C of the Income Tax Act to curb tax avoidance through interest-free or low-interest loans to trusts, targeting cross-border transactions and clarifying the interaction with transfer pricing provisions, starting January 2025.

The Initial Finance Act (LFI) for 2024 implemented substantial modifications to the Senegalese General Tax Code (GTC) aimed at modernizing and harmonizing the tax framework.

In August 2024, Nigeria introduced guidelines for implementing a zero-duty rate on basic food items from July to December 2024, aiming to reduce food prices. Additionally, a proposed windfall tax of 50-70% on Nigerian banks' FX profits aims to fund infrastructure, education, and healthcare.

The Finance Act 2024, published on 27 July 2024, has introduced the imposition of the CCR Levy, which is intended to support national efforts aimed at protecting, managing, investing in, and restoring Mauritius’ natural ecosystem, as well as addressing the impacts of climate change.

On 1 July 2024, the EU-Kenya Economic Partnership Agreement (EPA) entered into force culminating negotiations towards an EU-Kenya Strategic Partnership.

Since 2021, Guinea's tax system has undergone major changes, including the ratification of tax exemptions by the National Assembly, expansion of flat-rate levies, and new tax code provisions, including payroll tax adjustments, corporate tax modifications, and expanded transfer pricing regulations.

Recent tax developments in Ghana include a two-month amnesty for uncustomed vehicles (Aug-Sept 2024), the implementation of VAT on Additional Oil Entitlement (AOE) for upstream contractors, and expanded tax incentives for the extractive sector and electric vehicle manufacturers.

Cote d’Ivoire facing International Challenges related to the Changes Introduced by the Multilateral Instrument to Prevent Base Erosion and Profit Shifting (BEPS).

Recent developments in Benin's tax legislation since 2024 include exemptions for certain capital gains, artistic remuneration, and vehicle taxes, along with new rules on income tax advance payments and financial transactions.

This Budget Day special from Atlas Tax Lawyers lists the main proposals from the 2025 Tax Plan and additional parliamentary bills.

WTS Advisory AG exclusively advised the shareholder of INTEGER (“integer GmbH”) on its entry into the Valley IT Group (“VALLEY”), a full-service provider for medium-sized IT solutions ...

WTS Global, the only non-audit tax organization with representation in more than 100 countries, has been awarded as Tax Technology Provider of the Year at EMEA ITR Awards Ceremony 2024 in London. 

Jürgen Scholz honored as Indirect Tax Leader of the Year

WTS Global has been awarded with four accolades at this year’s EMEA ITR Awards Ceremony held on 18 September in London.

In the latest edition of theJUVE Handbuch Steuermarkt 2024 ranking, WTS was once again listed among the top tier advisors in numerous categories, which once again underlines WTS' position as one of the leading international tax advisory units.

News on tax developments affecting the international Financial Services industry.

On 28 March 2024, the Director of the Polish National Revenue Information Centre issued a private tax ruling (ref. 0111-KDIB3-1.4012.938.2023.3.IK) addressing the VAT implications of a specific transaction involving bonds issued by a fund.

Advocate General Juliane Kokott's recent opinion in Case C-18/23, delivered on 11 July 2024, has sparked concern due to her support for Poland's differential tax treatment of resident externally managed and non-resident internally managed (self-managed) investment funds.

The Polish government is currently working on amendments to the Polish Tax Code (Ordynacja podatkowa) in response to a recent ruling by the Court of Justice of the European Union (CJEU).

The special tax regime applicable to Loan Funds was finally enacted this Summer, paving the way to a new form of lending to Portuguese borrowers.

The CJEU ruled that Sweden’s tax system is discriminatory and violates EU law, as it denies tax refunds on dividends to foreign public pension funds while exempting Swedish ones, following a challenge by Finnish pension funds

Private Equity (“PE”) funds are impacted by recent HM Revenue & Customs (“HMRC”) changes in the UK relating to the Limited Liability Partnerships (“LLPs”) structure, meaning some partners are treated as employees for tax purposes.

The UK Chancellor of the Exchequer Rachel Reeves confirmed that the Autumn Budget will be presented on 30 October and paved the way for a number of expected tax increases. What does this news mean for PE firms and executives from a tax perspective?

Serbian economy is widely recognized as an investment destination for outsourcing activities. However, Serbian government introduced many incentives in order to attract businesses who will create intellectual property and change economic landscape.

The German Federal Fiscal Court (BFH) recently published two important decisions according to which foreign securities investment funds were discriminated against compared to German investment funds.

The EU Commission recently decided to initiate infringement proceedings against the Netherlands (INFR 2024/4017 of 25 July 2024).

On 29 July 2024, the European Court of Justice (“CJEU”) issued a new judgement (“KEVA”, C-39/23) that concerns public pension funds, WHT and the EU fundamental freedom of capital movement.

Effective from January 1, 2024, the Korea-source income payer to foreign investors is required to withhold taxes at Korean domestic rates (22% for dividends) without applying any tax exemption or reduced tax rate under a pertinent tax treaty at the time of withholding.

On 29 July 2024, CJEU issued its judgement in CJEU case "KEVA" (Case C‑39/23) between the Swedish Tax Agency and three Finnish public pension funds, regarding the levy of WHT on foreign public pension institutions.

The Belgian tax authorities (FPS Finance) announced that from 2 September 2024 multinational enterprises (MNE) and large domestic groups subject to the minimum tax for MNE groups and large domestic groups (Pillar 2) can start their Pillar 2 related prepayments.

This collaboration aims to offer the financial sector comprehensive and digital withholding tax services in the future

On 25 July 2024, the European Commission published its decision to initiate an infringement procedure, which may force the Netherlands to reconsider their discriminatory taxation practice regarding the taxation of foreign investment funds which has been in place for years.

The EU's Pillar Two Directive complements CFC legislation from ATAD. Austria adopted it in 2023, after implementing a CFC regime in 2018. The OECD later identified conflicts between the CFC legislation and Pillar Two.

Law No.7524, titled “On Amendments to the Tax Code and Certain Other Laws’’  was published in the Official Gazette numbered 32620 on August 2,2024 and has come into force.

Starting 2026, Latvia requires electronic invoices for company transactions, excluding certain exceptions. Implementation details and deadlines yet to be clarified.

WTS Advisory AG acted as financial advisor to BigRep GmbH in the preparation and realization of the IPO and also provided intensive support with the IFRS conversion.

WTS advised HVEG Fashion Group (“HVEG” for short), a leading company in the fashion industry, on the acquisition of all shares in Sassa Mode Group in financial and tax matters.

WTS, a global full-service provider of tax advisory and financial & deal advisory services, has advised HVEG Fashion Group on the acquisition of all shares in ...

From 1 January 2022, corporate taxpayers and sole entrepreneurs (except flat rate users) are entitled to tax relief for digital and green transition investments to support the 2050 climate neutrality goal.

Recent tax developments from eight countries on the continent.

One of the key issues that foreign investors in South Africa (ZA) need to consider is whether their activities in South Africa will create a Permanent Establishment (PE) and expose them to a corporate income tax liability in South Africa.

Senegal has adopted the new Environmental Code in 2023, which replaces the 2001 version, to address challenges arising from increased production activities, demographic pressures, and natural resource extraction.

As we noted in our 2024 Tax Outlook, the Nigerian Tax system is currently undergoing significant reviews with the aim of improving the system. In this article, we identify some of the notable proposals and updates in the tax reform process.

The Supreme Court recently provided an interesting interpretation of the application of the remittance rule, as well as the tax residency rule, in a judgment delivered in the now commonly called “Dilloo Case”.

The Kenya Revenue Authority (KRA) aimed to expand the definition of "royalty" in the Finance Bill, 2024, to include software payments, but the bill was rejected after protests. Despite this, KRA's proposal follows a High Court case and reflects ongoing debates over software taxation in Kenya.

The Ghana Revenue Authority has started rolling out Electronic VAT Invoicing System that will help businesses and GRA to obtain real time monitoring of VAT transactions.

We are thrilled to share with you a roundup of significant updates from June 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions.

Six new partners and two partners of counsel

The Inland Revenue Authority of Singapore (IRAS) released the 7th edition of its Transfer Pricing Guidelines on 14 June 2024. To assist taxpayers to understand the changes and assess their impacts, this article summarizes the main changes to the guidelines for Singapore taxpayers.

WTS Digital and Lucanet Amana have expanded their collaboration as part of an official partnership

We are pleased to introduce the latest WTS Global Transfer Pricing Guide for Asia Pacific countries.

On March 22, 2024, the Federal Council approved the Act to Strengthen Growth Opportunities, Investment and Innovation as well as Tax Simplification and Fairness (Growth Opportunities Act, WtChancenG).
 

WTS provided tax advice to AviAlliance GmbH

Svalner Group and Atlas Tax Lawyers, announce their union as Svalner Atlas Group, to form a new premier advisory group offering tax advisory, transaction services and related services in Sweden, Finland and The Netherlands. 

The GloBE Model Rules were released by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) in December 2021. This article further examines the importance of efficient implementation, to ensure these guideliens achieve the desired economic result. 

On November 16, 2023, the OECD issued a discussion paper on treaty provisions for the extractive industries.  The OECD proposal sets a very low threshold for granting taxation rights in respect of corporate and employee income.

European Union (EU) tackles plastic waste with a levy on non-recycled packaging & bans on single-use plastics. Diverse national measures pose challenges for cross-border businesses. 

WTS Legal continues its expansion course. Frederik Johannesdotter joined WTS Legal in Munich from KPMG Law on December 1, 2023. He joins the firm as an Associate Partner in the Corporate practice area in Munich.

The experienced group tax specialist will advise clients on national and international group tax law as well as on organisational and strategic issues.

We are thrilled to share with you a roundup of significant updates from May 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

WTS Digital has started a cooperation with the international msg group, a leading provider of IT, software and industry solutions, with the aim of increasing the efficiency of tax processes

On 21 March 2024, Attorney General (GA) Collins of the Court of Justice of the European Union (CJEU) issued his legal opinion in the CJEU case "KEVA" (Case C‑39/23). The GA opines in favour of the applicants, three Finnish pension institutions.

The German Federal Fiscal Court's (BFH) recently published its ruling on the “L-Fund case” dated 11 October 2023, following the European Court of Justice judgement of 27 April 2023 (C‑537/20).

The UK’s Chancellor of the Exchequer, Jeremy Hunt, delivered the Spring Budget on 6 March 2024 announcing a variety of measures impacting the financial services industry.

On 23 November 2023, the Luxembourg Administrative Court overruled a decision rendered by the Administrative Tribunal on 23 September 2022.

In 2023 Italy amended the domestic permanent establishment (“PE”) definition provided by Article 162 of Italian Income Tax Code by introducing the so-called “Investment Management Exemption” (hereinafter “IME”), which constitutes a PE “safe harbor” for asset managers of foreign investment vehicles.

On 22 March 2024, the German parliament approved a bill that enacts significant changes applicable to German and non-German Real Estate funds.

It may be of interest to foreign asset managers and custodian banks that the German government recently presented a plan to stabilize the statutory pension system.

For a German private investor the indirect investment in cryptocurrency via CIVs is less tax beneficial than a direct holding of this asset class.

Recently, Guangzhou Municipal People's Government issued several policy measures for promoting high-quality development of the biomedical industry in Guangzhou. The measures include the encouragement of QFLP to invest in biomedical projects.

About the use of AI in the tax sector

On 22 March 2024, the Supreme Administrative Court issued a ruling (KHO 2024:38) seeking a preliminary ruling from the CJEU regarding the VAT treatment of factoring financial arrangements.

News on tax developments affecting the international Financial Services industry.

Zimbabwe has embarked on a significant reform of its fiscal policies concerning the mining sector, introducing amendments to the Finance Act effective January 1, 2024.

Zambia's journey towards a more efficient, inclusive, and digitally advanced tax system is marked by significant legislative changes and policy introductions.

Interest expenditure incurred by a South African resident taxpayer may only be deducted in terms of section 24J(2) of the Income Tax Act, No. 58 of 1962 (‘ITA’)

In African economies, extractive industries are key, heavily regulated by authorities to maximize tax revenue, underscoring the importance of a clear "Permanent Establishment" (PE) concept, particularly in Senegal's expanding sector.

As times are changing, so is the Nigerian tax landscape. In this article, we highlight some of the recent tax updates in Nigeria in the first quarter of 2024.

Mauritius lacks transfer specific transfer pricing legislation, but the Income Tax Act 1995's Section 75 applies the arm’s length principle to assess related party transaction terms.

Recent tax determinations taken by the Tax Appeals Tribunal (TAT/Tribunal) have caused some disquiet within the PE and VC sector in Kenya.

The Ghanaian government implemented VAT provisions from the VAT Act of 2013 on January 1, 2024, as part of its post-COVID-19 economic recovery program.

Recent tax developments from eight countries on the continent.

In France, losses incurred by a company in a given fiscal year can be carried forward to offset profits in subsequent years, without time limit.

WTS advised Dussmann Technical Solutions GmbH on the financial aspects of the acquisition of regelmatic GmbH.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

WTS advised the industrial holding company Adcuram on the tax aspects of a carve-out

WTS, a global full-service provider of tax advisory and financial & deal advisory services, has advised funds advised by Crosslantic Capital on an investment in the Heidelberg-based scale-up Instaffo, ...

WTS has advised funds advised by Crosslantic Capital on an investment in the Heidelberg-based scale-up Instaffo

South Africa applies a residence basis of taxation, subjecting South African tax residents to tax on worldwide income and capital gains, while non-resident taxpayers are subject to income tax on South African source income or income that is deemed to be from a South African source.

In line with the constitutional power to make relevant executive Orders and the provisions of the Nigerian Oil and Gas Industry Content Development Act, 2010, the President of the Federal Republic of Nigeria enacted the Oil and Gas Companies.

On 27^th February 2024, the Federal Government of Nigeria launched the Expatriate Employment Levy Handbook which introduced the Expatriate Employment Levy, a mandatory contribution levied on employers of expats in Nigeria.

Mandatory e-invoicing for B2B transactions is becoming more important globally, particularly in Europe. This overview aids tax advisors and companies adapting to these regulations across jurisdictions.

WTS, a global full-service provider of tax and financial & deal advisory services, has appointed Michel Braun as Chief AI Officer (CAIO).

The Brazilian consumption taxation is world-famous for its high complexity, especially due to its many taxes, plurality of taxing entities and relevant laws, different tax regimes.

WTS provided tax advice to the founders of Valispace GmbH on the sale to Altium

Discover the OECD/G20's latest report on Pillar One's Amount B, released on February 19, 2024, simplifying transfer pricing for multinational enterprises

With Pillar Two enacted in over 25 jurisdictions, it's crucial for calendar-year companies to understand the forecasted impacts on their Q1 2024 income tax provisions. Discover the checklist of action items curated by GTM, our member firm in the US, to navigate the complexities of new tax regulations.

In 2019, the Ghana Revenue Authority (GRA) in exercise of its statutory duty conducted a tax audit of Seadrill Ghana Operations Limited from January 2012 to December 2018. 

Indonesia's new transfer pricing guidelines are enshrined in the Minister of Finance Regulation 172/2023 ("MoFR-172").

Major changes to the 30% tax ruling in the Netherlands starting 2024: gradual decrease of tax benefit.

In its decision of 23.3.2023, the Austrian Supreme Administrative Court declined the qualification of a Cyprus-based intermediary holding company for a refund of Austrian withholding taxes on dividend payments under the EU Parent Subsidiary Directive.

An amendment to the first schedule of the Income Tax, 2015 (Act 896) resulted in a new annual graduated tax scale for resident individuals.

In a bold move towards self-sufficiency, Zimbabwe embarks on a journey of domestic resource mobilization with a bouquet of tax measures blossoming in 2024.

Zambia's 2024 Budget aims to unlock economic potential through policy consistency and implementation. Growth is projected to rise from 4% in 2023 to 4.8% in 2024.

The term ‘beneficial ownership’ (‘BO’) has a somewhat elusive meaning.

Transfer pricing in Senegal has taken a significant step forward in terms of aligning with international taxation norms, marked by the Minister of Finance's order on 1 August 2023, detailing transfer pricing documentation content.

Globally, the tax ecosystem is shaped by Court/Tax Tribunal decisions and executive directions.

The Income Tax Act (“Act”) has been in existence since 1974. 

The Angolan Parliament has approved and published in the Official Gazette, Law no. 14/23, of 28 December introducing substantial adjustments to the provisions of the VAT Code.

UAE Corporate Tax law (‘CT Law’) has become effective from 1 June 2023 with the Corporate Tax rate of 9% within the GCC region.

The Pillar II initiative adapts the taxation of large groups to appropriately consider digitalisation and globalisation.

Remote working has increased significantly since the beginning of COVID-19.

As remote work becomes more prevalent, companies need to be aware of the tax issues associated with their employees’ presence in foreign jurisdictions.

The Supreme Court of Pakistan has recently ruled on the Snamprogetti Engineering case, adjudicating the controversy involving the existence of a permanent establishment and chargeability to tax of Pakistan-source income under the Pakistan-Netherlands Double Taxation Treaty.

The receipt of royalty and fees for technical services (‘FTS’) for non-residents is deemed to accrue or arise in India.

France has introduced the principle of gradually making the use of electronic invoicing compulsory from 2019 (law no. 2019-1479).

Singapore Budget 2024: Navigating Economic Challenges with Strategic Business Support

WTS and Peters Schönberger & Partner (PSP) are founding an AI joint venture that could shake up the industry. This is because it allows control functions to build their own generative AI applications. It puts pressure on consulting firms and tool providers because it turns their customers into kings.

Recent tax developments from eight countries on the continent.

The Greek Ministry of Finance and the Independent Authority of Public Revenue have introduced myDATA (my Digital Accounting and Tax Application) in 2020.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

In his latest Autumn Statement, the Chancellor of the Exchequer, Jeremy Hunt announced a variety of measures that will impact the financial services industry.

Serbia, as a frontier market with communist past, has had struggles in developing its local capital market: roughly 5.000 Serbian residents are investing in publicly traded shares.

On 17 June 2021, the European Court of Justice issued a ruling on joined Cases C-58/20 and C-59/20 (the “DBKAG & K decision”), stating that both the right to use software and specific administrative services may fall within the exemption provided for in that provision.

On 19 December 2023, the Supreme Administrative Court handed down its judgment in case number II FSK 2108/20 concerning interest on overpaid WHT for foreign investment funds.

The new Treaty is of particular importance and may therefore be of particular interest to asset managers as well as real estate investors / promoters in view of changes relating to collective investment vehicles and pension funds and changes pertaining to the allocation of taxing rights to shares in “real estate rich” companies.

REITs can invest in real estate assets located in India, either directly or through holding companies and/ or special purpose vehicles (‘SPVs’).

In its decision of 20 April 2023, the Cologne Fiscal Court awards a Belgian insurance company a refund of German WHT suffered on German portfolio dividends in 2009 under the free movement of capital of European law.

This revision of German VAT law is particularly important for international asset managers with offices in Germany and international investment advisors.

The French tax administration tried to increase the scope of French withholding tax by increasing the beneficial ownership requirements in cases where French banks acquire shares temporally from foreign shareholders.

A couple of months ago, the e-invoicing and e-reporting reform was still foreseen to progressively enter into force as from 1 July 2024, with a timetable extending until 1 January 2026.

For many years now, Poland has been introducing solutions aimed at the digitization of VAT.

The Belgian government submitted its proposal for a mandatory B2B invoicing scheme.

Explore the dynamic tax landscape of post-pandemic Asia Pacific with this insightful brochure on regional tax developments, economic outlook, and opportunities for businesses in 2024.

Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

Pascal Saint-Amans, the former Director of the Centre for Tax Policy and Administration at the OECD, joined us at our Tax Directors Meeting 2023 in Singapore to share his expertise on a range of critical tax topics.

For FYs opened as from 1 January, 2023, groups have the possibility to set up a captive reinsurance company in France whose purpose is to exclusively reinsure the own risks of the group.

Several changes to the Finnish transfer tax legislation became effective on 1 January 2024.

From 2024, the so-called government austerity consolidation package will come into force in the Czech Republic, bringing changes to up to 60 legal regulations. Most of the changes are proposed to take effect from 1 January 2024.

In September 2023, the Austrian Supreme Administrative Court filed a preliminary ruling request with the European Court of Justice concerning the Austrian investment funds legislation.

Australia has firmly committed to implementing Pillar Two, which will ensure that multinational enterprises with annual global revenue of EUR750 million or more pay a minimum tax rate of 15% on their global income.

News on tax developments affecting the international Financial Services industry.

The consulting firm WTS Advisory has advised Mechanical Power Supply B.V. on the sale of the ENERCON supplier...

Christian Schiessl becomes new Co-Head of the International Corporate Tax (ICT) Service Line at WTS Global

Germany had already applied for the introduction of mandatory electronic invoicing as a special measure under Art. 395 of the VAT Directive in 2022. By decision of 25 July 2023, the Council of the European Union approved this approach.

Payroll & Accounting Services are being expanded in Leipzig.

This article examines the Paris Administrative Court of Appeal's ruling on corporate income tax and residency, reshaping how tax treaties are interpreted.

The Belgian government's proposed draft program law on the cayman tax faces scrutiny for introducing extensive changes, prompting concerns about its logic, potential legal challenges, and its perceived bias towards tax authorities.

A comprehensive guide to the latest in corporate tax strategies and regulations across Latin America.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

The legislative steps concerning e-invoices, real-time transactional reporting and the expansion of the OSS/IOSS scheme and platform economy as a result of implementing the ViDA initiative, have slowly been introduced in Sweden.

Starting from 1 January 2024, invoices for B2B transactions having the place of supply in Romania must be submitted through the RO e-Factura system. 

During his Budget Speech on 10^th October 2023, Minister for Finance, Michael McGrath announced that the Irish Revenue Commissioners would launch a Public Consultation focusing on “how we can use digital advances to modernise Ireland’s VAT Invoicing and Reporting System” for B2B and B2G VAT reporting.

Spanish Act 18/2022 of September 28 on company creation and growth introduces a range of new measures including the e-invoice, which is mandatory for all exchanges between businesses and professionals.

The UK Tax Authority, HMRC, has sought to introduce digital VAT reporting in the UK via its Making Tax Digital for VAT (MTDfV) program

The digital age has led to a growing need to combat VAT fraud, minimize the VAT gap and modernize the EU's VAT system in response to the demands of today’s digital economy.

Since 1 April 2020 all public organisations and private companies can require e-invoices from their suppliers in Finland.

WTS advised the Swiss energy group Varo Energy ("VARO" for short) on the tax aspects of the acquisition of elexon GmbH, a company specializing in logistics fleets and charging infrastructure.

In October 2023, the Federal Inland Revenue Service (FIRS) issued a guideline on desk examination, tax audit, investigation and inquiry processes to offer clarifications on the nature and scope of the FIRS’ inquiry process to avoid conflict of roles thereby replacing prior communications on the subject.

WTS Africa has premier local tax firms, law firms, and advisors that ensure our updated knowledge of local laws and practices in 50 out of 54 countries on the African continent.

The High Court in Kenya delivered a judgement allowing an investment deduction in respect of capital expenditure incurred on the construction of a building and installation of machinery. The judgment is significant from the point of view of prospective application as well as construction of tax statutes. 

In April 2020, a first proposal for a new Swedish Withholding Tax Act was referred for consultation by the Swedish Ministry of Finance.

On the 14 September 2023, HM Revenue and Customs (HMRC) published draft legislation, of particular interest to UK companies listing securities on non-UK exchanges, providing for the removal of the 1.5% charge to UK stamp duty and stamp duty reserve tax on certain issues and transfers.

On Budget Day 2023 (19 September 2023), legislative proposals were published for 2024 and onwards that could impact the real estate and the financial services industries.

In April 2020, a first proposal for a new Swedish Withholding Tax Act was referred for consultation by the Swedish Ministry of Finance.

Serbia is an emerging tech hub in Europe. Consequently, Serbia introduced Law on digital assets (Law) in 2021 to regulate and promote Web3, being one of few European countries introducing such legislation.

The issue of mandatory beneficial owner testing in the application of WHT exemptions on dividend payments has been a bone of contention generating disputes with Polish tax authorities since 2019.

Angel Tax is an anti-abuse provision wherein Indian closely held companies are subject to tax on the excess of the issue price received over the fair market value of the shares.

Around mid-July the Hungarian Parliament finally approved a bill, which technically “transfers several provisions on certain financial-related taxes to the relevant sector-specific laws as of 1 August 2023.

Recently, the German Ministry of Finance (MoF) presented two new important draft pieces of tax rules in many ways relevant for the international Financial Services industry.

To invigorate the capital market and enhance the confidence of investors, the State Taxation Administration (“STA”) has announced the extension of a series of tax incentive policies.

On 21 June 2023, Belgium and the Netherlands signed the new double tax treaty. This treaty was a long-awaited one since the last version dated from 5 June 2001.

The tremendous effort of the government to increase the tax net and promote voluntarily tax compliance, there has been a new tax amendment passed by parliament and assented to by the president.

News on tax developments affecting the international Financial Services industry.

Workation is no longer a foreign word. Workation has established itself in our linguistic usage and it is simply impossible to imagine the modern working world without it.

WTS Global and FTI Consulting have co-created the first Tax Sustainability Index of its kind

The German tax authorities, together with the legislator, are aiming for mandatory electronic invoicing for certain business transactions as early as January 1, 2025. The amended requirements show clear parallels to the European Commission's proposed directive "ViDA - VAT in the Digital Age".

US taxpayers are a subject to both foreign as well as local regulation on their worldwide income. To avoid a potential double taxation US provides a Foreign Tax Credit. Learn more about it and gain a thorough understanding of key tax provisions.

In terms of section 9D of the Income Tax Act 58 of 1962, income tax is imposed on South African shareholders of ‘controlled foreign companies’ on the income earned by the CFC in certain circumstances.

Senegalese tax legislation references the arm's length principle since the 2018 Finance Act, particularly in Article 17, paragraph 1 of the General Tax Code, and provides for related party notion.

The Federal Inland Revenue Service recently published Guidelines for the Refund of Value Added Tax paid by Diplomats, Missions and International Organisations on Goods and Services purchased to provide such qualified persons with a framework for processing such requests for VAT refunds.

Mauritius is increasingly popular as a platform for Fund Managers to structure investment funds, including Collective Investment Scheme(“CIS”) and Closed-End Fund (“CEF”) vehicles, targeting Africa and Asia. 

Recently, the issue of the corporate tax residency of companies incorporated outside Kenya has arisen, especially for multi-national enterprises with a business presence or related entities in Kenya.

In 2023, with the conflict involving Russian Federation and Ukraine, the global economy has been volatile, and several countries have been facing economic difficulties, inter alia, inflation especially in Europe and in the USA.

Recent tax developments from six countries on the continent.

Types of bilateral agreement governing insurance of foreign workers: comprehensive, so-called social policy agreements; social security agreements; and healthcare cooperation agreements.

The high court on 10 November 2022 gave a ruling on Coca-Cola Eequatorial Africa limited vs. the commissioner general.

On September 29, 2023, the Brazilian Federal Revenue Service issued Normative Instruction 2.161 (IN 2.161) regulating the new Transfer Pricing rules introduced by Law 14.596/23. The application of the new rules will be mandatory as of January 1, 2024.

In its decision of 23.3.2023 the Austrian Supreme Administrative Court declined the qualification of a Cyprus-based intermediary holding company for a refund of Austrian withholding taxes on dividend payments under the EU Parent Subsidiary Directive.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

The donation will provide 120 girls in rural government schools with a year's supply of sanitary products. This will assist in addressing the Period Poverty plaguing them. 

Ministry of Finance and State Taxation Administration has won praise from individuals at work, foreign and Chinese, by announcing in one breathe a four-year extension to three set of soon-expiring employee-favored individual income tax policies, postponing their expiry date to the end of 2027.

This Budget Day Special from Atlas Tax Lawyers outlines important proposals in the Dutch 2024 Tax Plan and additional bills for you.

The Supreme Court has recently ruled on the application of the exemption of dividends paid by Spanish entities to their parent companies in the European Union (EU) by virtue of the provisions of Article 14.1.h) of the Law on Non-Resident Income Tax (“LIRNR”).

WTS assisted the PARATUS Group in the complete acquisition of DB Soft S.L. in financial and tax matters

WTS Digital is strengthening its partnership with Irish tax tool provider Taxback International (TBI).

VAT obligations of Italian PEs/FEs: recent instructions by the Revenue Agency may be critical to business practice

What businesses in Asia need to know in light of the recent export and sanctions developments and the US-China trade tensions

Double taxation agreements (DTAs) with 38 "unfriendly" states were temporarily suspended.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

In its recent ruling of July 13, 2023, the European Court of Justice clarified that a breach of the employer's obligation to notify the Unemployment Agency in mass dismissal proceedings pursuant to sec. 17 para. 3 sentence 1 of the German Unfair Dismissals Act (KSchG) does not lead to the invalidity of the subsequent dismissals.

On 17 July 2023, the OECD (i.e. the Inclusive Framework, “IF”) published various new documents relating to the introduction of Pillar Two. In this article, we present an initial overview of the key aspects covered in these documents.

In this latest edition of the WTS Transfer Pricing Newsletter, our colleagues from 13 countries provided an update on recently introduced legislations and cases.

WTS has opened a new special exhibition entitled "Real/Irreal" in the new building of its Munich headquarters as part of its existing commitment to art

In a recent decision dated May 22, 2023, the LAG ruled that works councils have a right of co-determination with regard to the "how" of recording working hours.

New Law No. 7456 introduces significant changes to tax legislation and provides support to employers in the aftermath of the 2023 earthquakes.

Find out the latest on the implementation of public CbCR in the Netherlands and what it means for multinational enterprises. Discover key details and important next steps in this newsflash.

As in the past, for the year 2023 we would like to share with you the recent or expected changes in VAT and GST regulations and compliance obligations across various countries. 

WTS has advised Fiber Experts Deutschland GmbH, a construction company specialized in the expansion of broadband networks, on the tax aspects of its acquisition of Eschborns´ Elecnet GmbH

Recent tax developments from six countries on the continent.

Discover the latest insights from Lee & Ko, our trusted tax experts in South Korea, in their article published in Bloomberg Tax. Uncover the groundbreaking developments of South Korea's Pillar Two rules and explore their implications for foreign multinational enterprises operating in the country.

WTS has advised the international healthcare software company CGM on the acquisition of a majority holding in the patient portal provider m.Doc 

On March 30, the UK government published both their response to the “Review of Net Zero” and the “Powering Up Britain” energy security plans. 

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

Carbon Border Adjustment Mechanism (CBAM) will start operating from October 2023. In this article, get an overview of the CBAM and reporting obligations. 

News on tax developments affecting the international Financial Services industry.

Obtaining a Work Permit in Vietnam has become more difficult and time-consuming. Get an overview of all issues related to obtaining a work permit, visa, and temporary resident card.

Decree 8/2023 of the Minister of Energy was published on 2 June 2023, which finally clarified the amounts of the EPR fees payable from July.

An update from Austria, Bulgaria, Germany, Poland, Sweden, and the United Kingdom

How data analytics can add value using the example of a global transfer pricing documentation projects

The Whistleblower Protection Act is expected to come into force in Germany in mid-June 2023

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

How data analytics can add value using the example of a global transfer pricing documentation project

The Ringbeck Group has acquired Rüdiger Brandenburg Garten-, Landschafts- und Sportplatzbau GmbH.

With the Polish implementation of the "SUP Directive" entering into force, businesses will now face new compliance duties aimed at reducing the environmental impact of certain plastic products.

As a result of the new amendments in Portugal, the contribution on single use packaging made of aluminium (or a multi-material containing aluminium) will apply from 1 September 2023.

Tackling plastics pollution and waste at the global, regional and national levels. 

The Supreme Court declares the existence of discrimination in the taxation of non-resident hedge funds when receiving dividends from Spanish companies

The European Court of Justice for the first time ever positions itself on the claim for damages under Art. 82 of the General Data Protection Regulation and its requirements

It is our pleasure to present to you the second edition of our WTS Global Mergers & Acquisitions Newsletter 2023. Presenting updates from 9 countries with a focus on the international M&A industry.

The Spanish Government has approved several tax measures which have come into force in 2023.

As of 2022, Polish CIT regulations contain a new definition for beneficial owner. The Voivodship Administrative Court in Lublin examined complaints against the refusals to issue preference opinions, presenting its own assessment of genuine business activity criteria.

The Federal Government has enforced certain taxation measures through promulgation of the Finance (Supplementary) Act 2023, effective from 24 February 2023.

The ever-evolving nature of tax law in Nigeria results in regular updates in ICT regime. Find out some of the recent and proposed changes to Nigeria’s ICT laws.

Effective from 1st January 2023, the Law introduces a range of tax measures that multinational enterprises (MNEs) operating in Italy may find noteworthy.

On 8 January 2023, the six-month grace period lapsed from the notification of the United Sates to Hungary regarding the termination of its double tax treaty. 

1 March 2023 saw the amended protocol to the double taxation agreement between the United Arab Emirates and Austria enter into force. Whilst the protocol has various implications for residents of Austria, the changes regarding withholding tax on dividends mainly affect residents of the UAE.

In the long-standing conflict regarding the harmonisation of domestic general anti-avoidance rules (“GAARs”) vs treaty law, the Argentine Tax Court sided with the Argentine Revenue Service in an attempt to enhance the goals and principles contained in the Argentine Double Tax Conventions.

For the benefit of the tax deductibility of credit losses enshrined in the IFL 2023, banking and financial institutions are required to meet certain substantive and formal requirements.

Although provisional measure 1152/22 is generally known for introducing new Transfer Pricing rules in Brazil, aiming at an alignment with the OECD standards, it also provides for relevant new rules on the deduction of royalties for Corporate Income Tax and social contribution on profits purposes.

The European Court of Justice for the first time ever positions itself on the claim for damages under Art. 82 of the General Data Protection Regulation and its requirements

WTS has advised the international healthcare software company CGM on the acquisition of a majority holding in the patient portal provider m.Doc 

Inevitable on the employer's side is a well-founded internal information about the nature, scope and purpose of the data collection as well as the processing

Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

Conclusion and consequences for practice: What companies must pay attention to in the future

WTS has advised alternative lodging specialist Bob W. on tax and financial matters related to its acquisition of Charly Hospitality

The Federal Ministry of Labour and Social Affairs  has answered the question of "how" to record working time

With a view to facilitating transfer pricing reporting properly, the Hungarian Ministry of Finance has published a 25-page document at the end of March.

Recent tax developments from six countries on the continent.

WTS Legal, the legal advisory arm of the WTS Group, strengthened its Munich office at the beginning of April

Bertil Kapff will be speaking at an online event on 01.06.2023

WTS Vietnam has donated 60 million VND (approximately 2,500 EUR) - the prize WTS Vietnam won from the latest sustainability campaign #ForTheGreaterGood organized by WTS Global. 

WTS advised the investment platform PARATUS, founded by Greenpeak Partners, on the acquisition of a majority stake in IMAGE Group in financial and tax matters
 

WTS welcomes Ulrike Schellert as new board member

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

In the context of the transaction, Telio was supported by an interdisciplinary transaction team from WTS

Turkey launches new Corporate Tax Law No. 7440 on Tax Amnesty and Tax Debt Restructuring including a one-off so-called “earthquake tax”.

Insights on the latest developments in terms of VAT and GST across the globe

News on tax developments affecting the international Financial Services industry

WTS is expanding its Asset Management & Financial Services advisory with the addition of Dr. Frank Wilbert

As in the past, for the year 2023 we would like to share with you the recent or expected changes in VAT and GST regulations and compliance obligations across various countries. 

News on tax developments affecting the international Financial Services industry.

News on trade and customs developments from all over the world

News on trade and customs developments from all over the world.

Telework and hybrid work are present as never before. In the case of multi-state workers, this can unfortu­nately bring about a mandatory social insurance in the other country.

The status of remote work in the Labour Code has been changed to a permanent option, rather than one applicable just in relation to the COVID-19 pandemic.

Ensuring greater social justice in the distribution of the tax burden" is one of the objectives pursued by the Amending Finance Law (LFR) for the year 2022.

The concern that the expatriates’ IIT burden might surge after 2023 may revive again.

To increase the efficiency of the organisation’s workforce, many companies have started to implement their global mobility strategies to empower flexibility and to adapt to hybrid and remote working methods.

The Portuguese Law No. 18/2022 approved on 25 August had relevant changes to Law No. 23/2007, also known as “the Foreigner’s Law”, introducing a new Portuguese visa type called the “Digital Nomad visa”.

August 2022 saw the Nigerian Ministry of the Interior release a circular informing the public of a revised Handbook on Expatriate Quota Administration.

As of 1 January 2022, companies that qualify as a withholding agent for Dutch wage tax and so-called collective administering organisations are obliged to notify the Dutch tax authorities of payments made to per­sons who are not on the payroll

With a series of recently published rulings, the Italian Tax Authorities have provided some helpful interpretations of recurring cross-border tax issues.

2023 is starting with significant changes for employees and employers in Hungary: the introduction of new tax allowances, a new type of leave and the minimum wage increasing.

On 22 December 2022, France and Switzerland reached an agreement on the taxation of home office income.

The 1 January 2022 a new expat tax regime introduced in Belgium that provides for a favourable income tax (and social security) treatment for employees, directors and researchers recruited abroad or seconded to Belgium.

The Administrative Court recently decided that an exemption with progression is to be applied to persons with unlimited tax liability in Austria even if they are resident abroad.

The Australian government has committed to expand the Pacific Australia Labour Mobility (PALM) scheme as follows

WTS Taxise has bolstered its Transfer Pricing (TP) practice through its cooperation with Adnan Begic as Senior TP Specialist & Consultant. Adnan’s expertise further builds on the growing TP offering of WTS Taxise and WTS Global in Asia Pacific.

WTS Global will automate its VAT compliance processes with Taxback International’s revolutionary Comply platform

WTS Global will automate its VAT compliance processes with Taxback International’s revolutionary Comply platform

WTS welcomes the new partner Christiane Noatsch to the Berlin office

The Supreme Court of Ghana upheld the provisions of the Revenue Administration Act, 2016, Act 915 (as amended) and High Court (Civil Procedure) Rules, 2004 (C.I 47) of pay now and argue later in the case brought before the Supreme Court by Richard Amo-Hene.

We are pleased to present the 1st edition of our WTS Global Mobility Newsletter for 2023.

In this edition our member firm WTS Klient summarises important changes affecting multiple areas, from labour law to transfer pricing.

In December 2022, the Council of the European Union and the European Parliament reached a provisional agreement on the Carbon Border Adjustment Mechanism (CBAM). CBAM is one of the EU's climate actions, designed to prevent the offset of the EU's efforts to reduce greenhouse gas (GHG) emissions.

The Swiss tax practice already applied strict substance requirements for the acceptance of international investments or group structures.

The consolidation system can be applied for a period of five fiscal years, starting with the next fiscal year following the one when the request is submitted.

Recent months have seen Polish tax regulations regarding restructurings significantly amended and further changes are also expected.

During the past 18 months, the French Supreme Administrative Court (Conseil d’Etat) has rendered several decisions requalifying capital gains realised by managers of companies

Chinese entities are often indirectly transferred in M&A cases.

One of the relevant topics is the tax treatment of contingent considerations and any other type of price adjustments and their effects on the tax amortisation of goodwill.

A common challenge in M&A transactions is to achieve a tax-effective interest deduction with regard to the acquisition funding.

In the case of a share deal, a regular focus point is the economic treatment of the distributable profits of the target company.

When and where are we taxed on income from employer securities in Hungary?

In the latest WTS CEE article, the most important changes affecting income tax are summarised.

Intra-group financing in Austria, alongside the interest rate, a particular strong focus is placed by the tax authorities on whether the debt instrument might be re-qualified into “hidden equity”. Thus, there should be documentation on the capital structure of the borrower, transparency of the loan agreement as well as the arm's length character of the terms and conditions.

WTS Global Mergers & Acquisitions Newsletter presenting updates from 8 countries with a focus on the international M&A industry

It is our pleasure to present to you the first edition of our WTS Global Mergers & Acquisitions Newsletter 2023. Presenting updates from 8 countries with a focus on the international M&A industry.

Temporary and permanent reliefs bring simplifications.

New year, new legislation – which means that this year, just like at the beginning of every year, the focus is on changes to the tax rules. One of the most important changes affecting most Hungarian taxpayers in 2023 is the amendment of the transfer pricing documentation rules.

With extensive energy cost relief packages, national governments are trying to mitigate the dramatic effects on their economies and private households. For companies, there is a need for action on various fronts. These measures apply in Germany, Poland, and the UK, for example.

On 20 December 2022, the OECD/G20 GloBE Inclusive Framework released its Pillar Two Safe Harbour and Penalty Relief guidance document. Read an article about the key elements of the transitional and potential permanent safe harbours from our tax experts in Belgium.

Read an article from GTM, U.S. alliance partner of WTS Global, on how to avoid pitfalls related to the consistency rule in the allocation and apportionment of deductions to the residual grouping in applying the GILTI high-tax exception.

WTS is continuing the expansion of its multi-award-winning VAT practice with the addition of Christoph Gach

This month marks five years of VAT in the UAE. This document is an excellent report from Dhruva Advisors LLP on how VAT regulations evolved in the UAE, what the challenges are and what the future for VAT will bring.

The Finance Ministry published an announcement dated 20 Dec 2022 on the base rate and margin notice for transfer pricing purposes in personal income tax (PIT) and corporate income tax (CIT). The announcement came into force on 1 January 2023.

The new Spanish tax on non-reusable plastic packaging came into effect on 1 January 2023. Several documents published by the Spanish tax authorities, as well as a ministerial order published in December 2022, provide new guidelines about compliance with this tax.

Ship pooling arrangements have become more common as shipowners seek greater efficiencies in the deployment of their vessels.

The fundamental purpose to introduce PHC regulations was to increase the attractiveness of Poland as a location for setting up holding companies.

15 December 2022 saw the Council of the European Union reach its unanimous agreement on the “Council Directive on ensuring a global minimum level of taxation for multinational and large-scale domestic groups” in a written procedure.

On 8 August, the new Colombian government introduced a new tax reform bill before Congress.

The approval of the Multilateral BEPS Convention contains the list of reservations and notifications made by the Chinese government, which becomes effective from 1 September 2022.

In a recent case, the Austrian Fiscal Court had to decide whether withholding taxes that cannot be fully credited in the respective tax year can be carried forward to the following years.

As of 30 August 2022, the Argentine Revenue Service (“ARS”) decided to suspend the Mandatory Disclosure Framework (“MDF”), which was created by the agency by means of general resolution no. 4838/2020, enacted in October 2020.

New rulings regarding local research tax credits paving the way for consistently deducing the local research tax credits and/or similar subsidies from any R&D cost-plus services provided by eligible French companies

A summary of the 2022 Tax Reform Act, which contains recommendations for updating the Transfer Pricing rules.

The Superior Court of Justice has decided that, until further legislative measures are taken, the so-called PRL 60 method must be calculated in a specific way. Our article sheds light on the decision and elaborates on the main practical implications.

The Argentine Tax Court has recently ruled on an interesting Transfer Pricing case, concerning the timing of benchmarking a transfer of goods. Further details about this case can be found in the article.

Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

The Klient group that provides complex business and financial consulting services will continue operating as a single company under the name of WTS Klient Business Advisory Ltd. from January. 

Provisional Measure (MP) 1152, published on December 29, 2022, substantially amended the Brazilian transfer pricing rules currently in force for transactions carried out between related parties, with the purpose of aligning them with the OECD Guidelines.

The new law significantly tightens obligations to cooperate with the revenue authorities in the area of transfer pricing.

The draft legislation provides for regulations to be introduced that would require taxpayers to produce (and provide upon request) TP documentation in a specified format in line with the OECD recommended approach (such as Master file and Local file). In addition, HM Revenue & Customs proposed the introduction of a Summary Audit Trail. The UK had previously implemented the Country-by-Country Reporting requirement.

Temporary and permanent reliefs bring simplifications.

The Indonesian government introduced an additional three Transfer Pricing methods that provide further guidance on certain related party transactions. Our colleagues summarize the key aspects of this legislative development.

This autumn has seen hard-fought victories of Ukrainian defenders at the frontline, criminal attacks on Ukrainian critical energy infrastructure, resulting in severe power shortages (which I had the dubious pleasure to experience while writing this note), and…Ukrainian taxpayers’ struggling to comply with the Transfer Pricing reporting deadline.

Cash pooling is a form of money management to ensure that all related companies in the supply chain will have enough cashflow to conduct their business. This can either be carried out by the actual transfer of money or by notation between companies. In any case, the OECD rules require that all related companies charge the market interest rate.

Since 2018, the Senegalese government has instituted reporting and documentary obligations in Transfer Pricing in accordance with the OECD BEPS actions 8-10, 12 and 13. However, it must be recognized that Transfer Pricing tax litigation is not yet abundant in Senegal, even though the regulatory framework is constantly being strengthened as a result of the various tax reforms that have already been discussed in previous issues of this newsletter.

July 4, 2022 saw the Saudi Tax Authority, Zakat, Tax & Customs Authority, issue a document for public consultation regarding proposed amendments to the Transfer Price bylaws to be applied to Zakat payers. The document was valid for public consultation until July 30, 2022. Zakat, Tax & Customs Authority has issued results relating to the public comments received on the public consultation platform.

The interest of the Polish Tax Authorities in benchmarking studies increases. Benchmarking studies are being carefully audited and regularly challenged during the tax controls, resulting in tax assessments and further tax proceedings before the administrative courts.

The Italian Tax Agency has issued instructions, through Circular Letter No. 16/E of May 24, 2022, with respect to the correct and practical use of the "arm's length range" for the application of the Italian Transfer Pricing rules.

Based on the recent decision of the Austrian Financial Court, liability commissions must be charged from the start of the loan agreement, reductions in the Transfer Pricing with respect to deliveries of goods must be credibly demonstrated and the arm's length interest must be charged for supplier credits.

Intra-group financing in Austria, alongside the interest rate, a particular strong focus is placed by the tax authorities on whether the debt instrument might be re-qualified into “hidden equity”. Thus, there should be documentation on the capital structure of the borrower, transparency of the loan agreement as well as the arm's length character of the terms and conditions.

In this latest edition of the WTS Transfer Pricing Newsletter, our colleagues from 13 countries provided an update on recently introduced legislations and cases.

The year-end is the time to look ahead and to prepare for the global developments in terms of VAT and GST – some of which we would like to share with you in our fourth edition of the WTS Global VAT Newsletter 2022.

VAT deduction rules are different during the year and at the end of the year, so particular attention has to be paid in order to properly detect the initial and the final terms for VAT deduction.

China proceeds with the roll-out of its e-invoicing regime.

Romania modifies the VAT rates for specific activities.

In this latest edition of the WTS Transfer Pricing Newsletter, our colleagues from 13 countries provided an update on recently introduced legislations and cases.

The German government presented to the public a memorandum on future legislative measures to improve the financing of investments and to facilitate capital market access for companies, especially start-ups, growth companies and SMEs.

Switzerland is planning various changes to its VAT system not only as of 1 January 2023, but also indicating amendments for 2024.

Poland undertakes a reassessment of the preconditions for a fixed establishment.

Windfall tax, i.e. tax on unexpected profits, is introduced into the Czech tax system as a subcategory of corporate income tax. It is intended to be an additional taxation of corporations that generate unexpected profits as a result of energy prices and interest rates increase.

In March 2022, the central government urged for intensified measures on tax administration on HNWIs, echoed by local tax authorities launching plans to reignite HNWIs-focused tax inspections, leading to a surge in tax audit cases on HNWIs.

The double tax treaty between Belgium and Luxembourg gives the opportunity for Luxembourg residents to lower the Belgian withholding tax rate of 30% to 15% and even in some cases to 10% for Belgian sourced dividends.

n the context of the latest budgetary measures, a decision has been taken to intensify the taxation of the financial intermediaries (banks, insurance companies and investment undertakings). The changes are therefore aimed at the entire financial sector.

The UK Autumn Statement 2022 issued by Chancellor Jeremy Hunt, reverses much of the changes introduced by the Truss government and seeks to put the UK economy back on track.

In July 2021, Law 11/2021 of 9 July was published in Spain, on measures to prevent and combat tax fraud.

As of 1 February 2016, Poland has had a banking tax. The tax is charged on the amount by which the taxpayer's total assets exceed the applicable statutory threshold.

With the reply to ruling No. 5078 of 12 October 2022, the Italian tax authorities issued important indications as to whether digital currency mining activity should be subject to VAT and direct taxation.

In the course of the German Investment Tax Reform 2018, the taxation of investment funds and their German investors changed fundamentally.

On Thursday the 27th of October 2022, the Belgian Constitutional Court has delivered its long-awaited judgment on the constitutionality of the annual tax on securities accounts introduced by the Act of February 17, 2021 (hereafter “ATSA”).

On November 15, 2022 the Austrian Ministry of Finance (MoF) published an information letter on the attribution of dividends for income tax purposes. The letter follows the decision of the Austrian Supreme Administrative Court concerning short-term Cum-Ex-Trades and withholding tax refunds.

In its ruling of 06.10.2022 (C-250/21), the ECJ had to deal with the VAT exemption of sub-participations in loans. 

The tax burden for services imported into Brazil will be reduced.

The year-end is the time to look ahead and to prepare for the global developments in terms of VAT and GST – some of which we would like to share with you in our fourth edition of the WTS Global VAT Newsletter 2022.

Shanghai has revised its regulations to encourage multinational companies to set up regional headquarters (RHQs) in Shanghai.

This case is an application filed by Afia African Village Limited (AAVL) “Applicant” seeking to invoke the supervisory jurisdiction of the Supreme Court to quash the ruling of the High Court. 

On 24th November 2022, Mr. Ken Ofori-Atta, the Minister in Charge of Finance and Economic Planning presented to the Parliament of Ghana a draft budget for the fiscal year of 2023.

News on tax developments affecting the international Financial Services industry

News on tax developments affecting the international Financial Services industry.

All EU member states to introduce global 15% minimum tax by the end of 2023!

All EU member states to introduce global 15% minimum tax by the end of 2023!

In the period 2020-2021, the Chilean Internal Revenue Service launched a new wave of tax audits with a focus on TP compliance and the substance of declared transactions.

Kenya’s 2022 Finance Act amended various provisions of the income tax law.

Due to the COVID-19 pandemic, a lot of employees who used to work abroad have been forced to work from home. In order to mitigate the impact, Luxembourg concluded so-called ‘COVID agreements’ with its neighbouring countries in 2020.

The Australian Government consolidated the Seasonal Worker Programme (SWP) and Pacific Labour Scheme (PLS) and operated under the PALM scheme with one visa stream and improvements to cut red tape and improve worker welfare.

WTS has advised the private equity investor KKA Partners from Berlin on the acquisition of a majority stake in the Cho-Time Group companies with multiple locations in Germany and Greece.

We are delighted to announce that WTS Partner Roland Holz has been appointed as new Head for the M&A WTS Global Service Line

Since 1 January 2019, special taxation rules have applied to vouchers.

As a consequence, input taxes could only be claimed back by using the special VAT refund procedure.

Following the new regime for value-added tax for non-resident persons in Nigeria, the Federal Inland Revenue Service (FIRS) issued ‘The Guidelines on Simplified Compliance for Value Added Tax (VAT) for Non-Resident Suppliers’ (the guidelines).

Zakat, Tax & Customs Authority (ZATCA) revealed that the implementation of the linking and integration phase for e-invoicing will start on 1 January 2023

Due to the extraordinary burdens for the German taxpayers and tax authorities as a result of the impact of Covid-19, the war in the Ukraine and extensive new land tax declaration requirements in Germany

The VAT regime applicable to distance sales has been amended as of 1 July 2021.

The Austrian Supreme Administrative Court affirmed a claim to interest with respect to input tax surpluses and, by way of legal analogy

Switzerland will implement the BEPS 2.0 Pillar Two minimum taxation by introducing a new minimum tax at the federal level.

We are delighted to announce that Roland Holz, Partner at WTS Germany, has been appointed as new Head for the M&A WTS Global Service Line.

On 20 July 2022, the UK government released the draft legislation on the Pillar 2 In­come Inclusion Rule (IIR) along with its response to the public consultation on the UK implementation of Pillar 2.

South Africa (‘SA’) has a long-standing history of being an attractive market for foreign investors and serving as a gateway for investing into the rest of Africa.

The Zakat, tax, & customs authority (‘ZATCA’) announced the re-launch of the initiative to abolish fines and exemption from penalties regarding all tax laws managed by ZATCA for a period of six months

The discussion on whether remote working could generate a permanent establishment (“PE”) dates back to 2012

The scope of changes is broad and some of them, if they finally enter into force, may have a cross-border impact.

The federal government has recently introduced various changes in the corporate tax rate structure with the Finance Bill 2022.

The Amsterdam Court of Appeal denied the dividend withholding tax exemption for a distribution to a Belgian family holding company due to lack of substance.

Traditionally, the government of Kenya has been introducing changes to tax laws every year, mainly through an annual finance act.

Digital service tax is covered in the OECD’s Pillar One. If Pillar One is finally released, digital service tax that is unilaterally implemented must be abolished.

In its decision, the French supreme tax court (Conseil d’Etat) had to decide whether, in the presence of intermediary companies, the treaty with the state of residence of the beneficial owner should be applied

On 1 June 2022, the Austrian Ministry of Finance (MoF) issued a statement (EAS 3436), saying that it is changing its understanding of how certain IT services are qualified in the double tax treaty (DTT) with China.

The Argentine Revenue Service (“ARS”) considered that the Belgium Company Solvay S.A. (“Solvay”) had a PE in the country during the years 2001 to 2006

Recently the US corporate alternative minimum tax (AMT) was resurrected by the Inflation Reduction Act of 2022. It is structured in a significantly different way than the previous one and only applicable to select corporate taxpayer’s. Meanwhile it is still unclear how the US AMT will interact with the OECD Pillar Two rules.

Manufacturers and importers of products made of single-use plastic will contribute to the costs of municipal waste disposal in parks and streets in future through a new special levy. Until now, the general public has borne the costs of cleaning up and disposing of carelessly discarded waste. According to the Federal government’s plans, this situation is now about to change. 

In its Judgment of 17 May 2022 (published on 29 September 2022), in Case VII R 2/19 "Hamamatsu", the German Federal Fiscal Court (Bundesfinanzhof, BFH) rejected the appeal filed on points of law

On August 11, 2022, the U.S. Court of Appeals for the Federal Circuit (“CAFC”) issued its decision on Meyer Corporation v. U.S.

The Customs Declaration Service (CDS) has now officially replaced CHIEF as the customs declaration system for imports into the UK.

With its ruling of 11 May 2022 (n.14908), the Italian Supreme Court stated the principle that penalties must be proportional to the Customs Law violation committed

China’s customs has relaxed the rules for the voluntary disclosure of breaches in customs matters through a recently released circular,

On 5 September 2022, the Brazilian government approved Law 14440/2022, which, by amending Law 11945/2009

On 8 November 2022, the Court of Justice of the European Union (CJEU) issued a long-awaited (landmark) decision in the Fiat-Chrysler state aid case.

On 4 July 2022, the UK Government released a consultation outlining an updated approach sovereign immunity from direct taxation.

On 6 and 7 July 2022, the Italian Supreme Court ruled in multiple cases that Italian WHT levied on Italian dividends distributed to non-Italian investment funds is incompatible with EU law.

The development of crypto assets (“CA”) unavoidably changes the landscape of the financial industry sector.

16 June 2022 saw the ECJ issue its judgement in the case C-572 - “ACC Silicones”,

Under the parent-subsidiary regime, dividends received by a parent company are exempt from corporate income tax (CIT)

On 12 August 2022, the Ministry of Finance published a preliminary draft government proposal concerning a so-called exit tax on private individuals.

Over the summer, the Czech Financial Administration announced that it had com­menced an inspection campaign focused on the taxation of income related to crypto­currencies

As of 30 May 2022, tech firms in 17 provincial or city regions in China have been given a hassle-free channel to raise foreign loans.

The Austrian tax reform 2022 (Abgabenänderungsgesetz 2022 –AbgÄG 2022) brings various changes to the taxation of investment income.

Post-Covid Asia Pacific recovery promises new opportunities for businesses. However, the need to replenish coffers, the changing international tax and geo-political landscape will pose challenges for tax regulators and tax leaders.

The Spanish government has recently published the draft State General Budget for 2023 which includes several relevant tax modifications. 

News on trade and customs developments from all over the world

The Federal Fiscal Court in September 2022 published its judgment 
in the famous Hamamatsu case and has given some very interesting statements in the field of customs valuation. It will be interesting to see how this judgment will influence the world of customs for intra company transactions where a margin-based transfer price is used.

On October 24, 2022, the Netherlands published the draft bill on Pillar Two called ‘Minimum Tax Rate Act 2024’ (news item). This draft bill is open for public consultation until December 5, 2022.

An Austrian Fiscal Court (BFG) decision, which referred to ECJ case law, has held that the Austrian group tax regime’s limitations conflict with EU fundamental freedoms. If the BFG ruling is confirmed by the Austrian Supreme Administrative Court (VwGH), then a substantial easing in forming Austrian tax groups within multinational enterprises could be ahead.

News on trade and customs developments from all over the world.

The Value Added Tax Act, 2013 has been amended by the Value Added Tax (Amendment) Act which came into force on 12 September 2022. 

Interview with Dieter Becker, Managing Director WTS Advisory

Overview of the procedural specifics and technical issues to consider in the five steps published by the OECD.

WTS is further expanding its market-leading VAT division. The team, which won the 2022 JUVE award of “VAT Firm of the Year”, was recently reinforced with the addition of four new partners: three of them joining from international advisory divisions and one from within the company

On 20 July 2022, the UK government published draft legislation on the Pillar Two Income Inclusion Rule (IIR) and its response to the public consultation on the UK Implementation of Pillar Two with the governmental position in the key areas.

The EU aims to cut greenhouse gas emissions by at least 55 percent by 2030 compared to the levels of 1990