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Newsletter International Tax & Permanent Establishments

2019

#1/2023

WTS ICT

Newsletter

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

#2/2022

WTS ICT

Newsletter

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

#1/2022

WTS ICT

Newsletter

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

#1/2021

WTS ICT

Newsletter

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

Argentina: Suspension of the Argentine Mandatory Disclosure Framework

Austria: No carryforward of withholding taxes

China: China has approved the Multilateral BEPS Convention

Colombia: Colombian tax reform bill 2022

Germany: Council of the EU reaches agreement on global minimum taxation (Pillar Two)

Poland: Polish holding companies as of 2023

Singapore: Tax treatment of ship pooling arrangements
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Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

Argentina: Tax court rules on PE under Belgium-Argentina tax treaty

Austria: Double taxation risk in connection with software as a service

France: Double tax treaties: application of the double tax treaties and beneficial ownership CE, 20 May 2022, n° 444451 Sté Planet

Indonesia: The development of the OECD’s two-pillar solution in Indonesia

Kenya: National tax policy: a more certain future tax regime

Netherlands: The saga on the withholding tax exemption continues

Pakistan: Changes in the corporate tax rate structure

Poland: Polish deal 2.0 – further changes in Corporate Income Tax

Portugal: Remote permanent establishment/remote work

Saudi Arabia: Zakat, tax, & customs authority re-launches tax amnesty initiative

South Africa: The modernisation of South Africa’s tax and exchange control regime

United Kingdom: Pillar 2: draft Income Inclusion Rule (IIR) legislation and consultation response
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Changes in international tax law and country-specific tax law developments with respect to cross-border transactions

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

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
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#1/2019

WTS ICT

Newsletter

Changes in international tax law and country-specific developments with respect to the taxation of permanent establishments in 10 selected countries

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
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