Newsletter International Tax & Permanent Establishments

• 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: FTI Consulting – Tax Implications of the 2021 UK Budget
• United States of America: Debt Financing in the U.S. – What a foreign investor needs to know

Austria: Construction PE – Austrian MoF on influence of trial runs and subcontracting
Azerbaijan: Amendments to the Tax Code of Azerbaijan
Benin: Permanent Establishments – forthcoming developments after introduction of public-private partnership law
Chile: Permanent establishment – a modern concept?
Indonesia: Development of permanent establishment in Indonesia
Malaysia: Permanent establishment: a total revamp or just a formality?
The Netherlands: Changing (Dutch) permanent establishment
Pakistan: Permanent establishment tax regime – key developments and issues
Senegal: For a contract concluded between a Senegalese company and a foreign one, are all the products necessarily subject to corporate income tax (CIT) in Senegal?
Vietnam: Permanent establishment (PE) in Vietnam