Newsletter International Tax & Permanent Establishments

• Argentina: Tax court rules on PE under Belgium-Argentina tax treaty
• Austria: Double taxation risk in connection with software as a 
• France: Double tax treaties: application of the double tax treaties and beneficial ownership CE, 20 May 2022, n° 444451 Sté Planet 
• Indonesia: The development of the OECD’s two-pillar solution in Indonesia
• Kenya: National tax policy: a more certain future tax regime
• Netherlands: The saga on the withholding tax exemption continues
• Pakistan: Changes in the corporate tax rate structure
• Poland: Polish deal 2.0 – further changes in Corporate Income Tax 
• Portugal: Remote permanent establishment/remote work 
• Saudi Arabia: Zakat, tax, & customs authority re-launches tax amnesty initiative
• South Africa: The modernisation of South Africa’s tax and exchange control regime 
• United Kingdom: Pillar 2: draft Income Inclusion Rule (IIR) legislation and consultation response 

Argentina: Argentine Supreme Court rules on treaty shopping in the context  of the Argentina-Chile Double Tax Treaty
Brazil: Victory of taxpayers in the Federal Administrative Tax Court: overlapping of Double Tax Treaties and Brazilian CFC rules 
China: New challenges and impacts brought by Pillar Two to Chinese companies
Germany: Pillar Two
India and Austria: International project business – India: Tax trap offshore supplies 
Italy: Italian rules on hybrid mismatches 
Netherlands: ATAD3 
Pakistan: ATIR rules on taxability of split contract arrangements under Pakistan-China Double Tax Treaty 
Poland: Pay and refund – new WHT collection mechanism for passive payments
Singapore and Indonesia: New Singapore-Indonesia Double Tax Agreement takes effect 
Vietnam: Tax exposure of the PE 

Europe: European Commission Communication on Business Taxation for the 21st century
Austria: Austrian Supreme Administrative Court on beneficial ownership of trademarks
China: Will an expatriate’s China tax position change due to COVID-19?
France: The French Supreme Court refers to the international definitions of permanent establishment
Germany: German registered IP of foreigners subject to tax in Germany
Italy: Step-up and realignment procedure for businesses
Netherlands: Proposal to disallow unilateral downward transfer pricing adjustments
Russia: Russian Federal Tax Service on intragroup services by MNCs to subsidiaries located in Russian Federation
Spain: 5% taxation on dividends and capital gains
United Kingdom: Tax Implications of the 2021 UK Budget
United States of America: Debt Financing in the U.S. – What a foreign investor needs to know

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