WTS Global Newsletters

• Austria: Changes in the taxation of investment income by way of the Austrian tax reform 2022
• China: Green channel for foreign loans to high-tech firms
• Czech Republic: Taxation of cryptocurrencies & required capital of self-governed investment funds
• Finland: Exit tax proposed for individuals
• France: French Supreme Tax Court validates the possibility of charging foreign tax credits on the share of costs and expenses on dividends
• Germany: ECJ judgement in the case “ACC Silicones” - C-572/20 & draft administrative guidance on duties of cooperation related to crypto assets & new regulation on crypto fund units
• Indonesia: Taxation of crypto asset transactions, new regulation as of 30 March 2022
• Italy: Important update on WHT reclaims due to recent Supreme Court decisions Poland: Interest on overpaid WHT for third-country investment and pension funds - SAC requests CJEU
• United Kingdom: Sovereign immunity from direct taxation, Investment Management Exception, qualifying asset holding companies regime

Argentina: Summary of recent tax news relevant to the FS industry
Belgium: Luxembourg treaty exemption for the Annual Tax on Securities Accounts at risk?
Finland: CJEU dated 7 April 2022 (C-342/20): Finnish WHT exemption in conflict with free movement of capital &
Finland: Finnish Tax Administration reveals malicious companies set up for tax evasion “as a service”
France: Intra-group interest – improvement for taxpayersGermany: Final administrative decree on crypto assets & Decision in ECJ case C-641/17 & “CPP” & Federal Tax Court on cum-/ex-transactions
Italy: Tax ruling on WHT exemption and foreign investment funds (dated 30 March 2022)
Poland: Two Supreme Administrative Court decisions on cryptocurrencies and interest on overpayment
United Kingdom: Changes to Economic Crime Act 2022 & Plans of HMRCs Business Risk Review & Crypto asset developments & Changes to the US Qualified Intermediary Agreement

Hot topic: ECJ landmark decision in the case C-545/19 (AEVN) dated 17 March 2022
Hot topic: OECD Commentary on Pillar Two
Austria: Supreme Administrative Court on foreign Trusts
Belgium: New fund type – Belgian ELTIF
Belgium: WHT reclaim
China: Change in taxation of equity investments
Czech Republic: New Czech government & increase of interest rate
France: Tax measures on gains from the sale of digital assets
Germany: Economic ownership and securities lending & WHT on crypto fund units
Netherlands: Government proposal to curb dividend stripping
Poland: Supreme Administrative Court on beneficial ownership & Indirect transactions with tax havens
Sweden: WHT for pension funds & VAT treatment of interchange fees in Sweden
UK: HMRC on Implementation of Pillar Two, ISA compliance and Uncertain Tax Treatment & Review of UK funds regime

Recent EU developments with respect to WHT
Argentina: Tightening of the foreign exchange control framework, increase of Corporate Income Tax, taxation of crypto currencies, & Supreme Court decision on interest deduction
Austria: Draft bill on new Austrian tax regime for crypto currencies published  
Czech Republic: Act on Investment Companies and Investment Funds & Green Tax  
Finland: CJEU Advocate General Opinion (C-342/20) on tax exemption criteria designed for contractual funds & Changes to the interest deduction limitation rules 
France: VAT option for banking and financial services (draft bill) 
Germany: Impact of recent Coalition Agreement on the FS industry, Revised CFC rules & Introduction of check the box regime 
India: Taxation of Dividend income 
Ireland: The taxation of crypto currency in Ireland 
Netherlands: Court decisions on German real estate investment fund with Dutch real estate income & Dividend tax refund for UK pension fund 
Poland: Polish Deal – selected WHT issues (incl CIVs) 
Slovenia: Taxation of crypto currencies 
Sweden: Proposed tax on credit institutions & Postponement of new WHT Act 
Switzerland: Reform of Swiss WHT regime & New legal framework on implementation of international tax agreements 

Australia: Pacific Australia Labour Mobility (PALM)
Austria: Establishment of a PE through home office activity
Chile: Global mobility in Chile
China: Expatriates’ tax position affected by staycation
Germany/China: Treaty override regarding German assignees working for a Chinese company
Czech Republic: Flat tax in the Czech Republic
France: French pension “impatriate” regime: exemption from affiliation and from payment of pension contributions
Hungary: Working days instead of calendar days and clarification of the concept of base salary
Italy: Italian source pensions paid to non-resident individuals
Luxembourg: Luxembourg cross-border workers situation since 30 June 2022
Netherlands: Update on the 30% ruling and change in the share option tax regime
Switzerland: Swiss source tax revision – notable changes
Thailand: Long-term Resident Program (LTR)
Ukraine: Taxation of individuals working remotely on Ukrainian projects
Germany/Ukraine: Treaty override regarding Ukrainian employees working in Germany
Vietnam: Work permit issues

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

Austria: Wage withholding tax for foreign employers abolished

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

China: Tax honeymoon for expatriates ending on 31 December 2021

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

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

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

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

Russian Federation: Migration and Personal Income tax updates 2021

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

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

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

Austria: Home Office work in Austria and consequences due to Covid-19
Chile: COVID-19 crisis, forced permanency and PE
China: Does the coronavirus cause any impact on the IIT of individuals stranded in China?
Costa Rica: Tax treatment for employees staying in Costa Rica
Czech Republic: The influence of anti-COVID measures on tax residence and affiliation to social insurance regulations
Germany: Stay compliant when working from home
Hungary: Expat employees working from home
Italy: Issues related to working from home or remotely during the Covid crisis
Kenya: Virtual work – Tax considerations of the new normal
The Netherlands: Working from home due to the coronavirus: the Dutch tax impact
Poland: COVID-19 tax and social security guidelines still to come
Portugal: Working remotely from Portuguese home office due to thepandemic and beyond
The Russian Federation: Stuck in Russia due to the Corona pandemic
Sweden: Swedish tax liability for individuals during COVID-19
Turkey: Working remotely from Turkey
Ukraine: Migration and taxation issues in times of COVID-19
Vietnam: Does having an employee in Vietnam create a permanent establishment?

EU Member-States

• Austria I: New interest rule for overdue VAT credits and claims
• Austria II: No Reverse Charge Mechanism in case of rental revenues of foreign property owners
• France: Spontaneous regularization of French VAT on distance sales by foreign operators
• Germany I: Annual VAT returns: New deadlines and interest rules
• Germany II: Federal Fiscal Court: Transfer of vouchers in distribution chains

Further countries

• KSA: E-Invoicing Phase II “linkage and integration”
• Nigeria: Guideline on VAT requirements of non-resident digital service providers

EU Member-States

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

Further countries

Chile: VAT changes for services
China: VAT measures to tackle business contraction
Nigeria: VAT obligations of non-resident digital service providers
Vietnam: VAT rate reductions

EU Member-States

Austria: Change in the VAT treatment of rental revenues of foreign property owners
Belgium: VAT registration with a fiscal representative, new rules on guarantees
France: Changes in sight
Germany/EU: Changes to Intrastat reporting
Hungary: VAT changes from 2022
Italy: E-invoicing via SDI extension
The Netherlands: Developments for investment funds and VAT fiscal unities
Poland: Voluntary e-invoice as of 1 January 2022
 

Further countries

China: Changes to indirect tax surcharges
Kingdom of Saudi Arabia: Changes to VAT, invoicing and customs charges
Singapore: Expanding the scope of application of GST
Ukraine: New VAT regulations taking effect in 2022

EU Member-States

Austria: Higher court confirms the granting of interest for overdue VAT credits
France: First flavour of the planned ambitious e-invoicing and e-reporting reform
Germany I: Sale of admission tickets for events, non-objection regulation
Germany II: Postponed: warranty commitments granted for remuneration as insurance transaction
Hungary: eVAT – What does the new draft eVAT return mean for taxpayers?
Poland: Further changes in the Polish VAT Act
Romania: Implementation of the Standard Audit File for Tax (SAF-T)

Further countries

Ukraine: Taxation of motivational fees