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WTS Global Newsletters

Global Customs Financial Services International Corporate Tax Mergers & Acquisitions Global Mobility Transfer Pricing Global VAT

Newsletter Subscription

Global Customs

#1/2023
WTS Customs
Newsletter
News on trade and customs developments from all over the world
#3/2022
WTS Customs
Newsletter
News on trade and customs developments from all over the world
#2/2022
WTS Customs
Newsletter
News on trade and customs developments from all over the world
#1/2022
WTS Customs
Newsletter
News on trade and customs developments from all over the world

News on trade and customs developments from all over the world

  • China: China boosting offshore trading business
  • Netherlands: DMS: The new Dutch Customs declaration system
  • United Kingdom: Upcoming deadlines for import and export measures in the UK
  • Vietnam: “Royalty” fees for imported goods
  • Germany: Restrictive measures against Russia and Belarus due to the war of aggression against Ukraine – Current developments
View PDF

News on trade and customs developments from all over the world

Brazil: Benefits of the drawback regime extended to some services

China: China’s customs relaxes voluntary disclosure rules

Italy: Penalties for customs violations must be proportionate: the Italian Supreme Court takes a clear position against the more than proportional increase in penalties for customs law violations

United Kingdom: UK developments on CDS

United States: Applicability of the First Sale Rule for Non-market Economies

Germany: Appeal in “Hamamatsu” case rejected by German Federal Fiscal Court

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News on trade and customs developments from all over the world

China: Export tax rebate made easy

Italy: The contrast between the digitalization of the bill of import and the requirements for deducting Import VAT

United Kingdom: Brexit 2022 update – 2

Vietnam: Goods labeling

UK/EU: EU Sanctions developments on Russia/Ukraine

Germany/EU: Restrictive measures against Russia and Belarus due to the war of aggression against Ukraine – Current developments

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News on trade and customs developments from all over the world

Austria: Customs law thwarts VAT law

Belgium: E-commerce: Belgium changes VAT rules on importer of record

Brazil: Brazilian Superior Court of Justice defines the calculation of penalty and interest on drawback

Brazil: Ex-Tariff saved from extinction

China: Major updates in China customs

France: The Goods and Services Tax Code – (A way to clarify the applicable rules!)

Hungary: Changes to customs administration in Hungary

Italy: Importer not established in the EU – operative clarifications

Senegal: The recent customs reforms of 20 December 2021

Singapore: Asia’s FTA Spree: benefits galore for businesses but caveat emptor

Sweden: Swedish Import VAT – Is Swedish Customs the competent authority?

United Kingdom: National Security and Investment Act

United Kingdom: Brexit 2022 update

United States: Outcome of “De Minimis” will have Major Effects on E-Commerce Importations and the US FTZ Program

Vietnam: Import of software to Vietnam

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Financial Services

#1/2023
WTS Financial Services
Newsletter
News from thirteen European countries with a focus on the international Financial Services industry
#4/2022
WTS Financial Services
Newsletter
News from nine European countries with a focus on the international Financial Services industry
#3/2022
WTS Financial Services
Newsletter
News from nine European countries with a focus on the international Financial Services industry
#2/2022
WTS Financial Services
Newsletter
News from nine European countries with a focus on the international Financial Services industry

News from thirteen European countries with a focus on the international Financial Services industry

  • Hot Topic: Foreign investors in US real property interest – Final regulations on FIRPTA tax exemption for Qualified Foreign Pension Funds (QFPF) issued)
     
  • Austria: Married couples are not entitled to apply jointly for refund of capital gains tax
     
  • Belgium: Possibility for non-resident investment funds to reclaim Belgian source tax (incl. WHT); Dividends; Interest payments; Belgian real estate income
     
  • Denmark: Danish Supreme Court (Højesteret) issues final judgement in the beneficial owner cases on dividends
     
  • Finland: Recent Finnish case law considering the tax (WHT) exemption of foreign investment funds
     
  • France: An opportunity of tax refund for foreign life insurance companies receiving French source dividends; Quick insight into key VAT measures expected for 2023 and 2024
     
  • Germany: International Private Equity funds, the return of capital and German fund investors
     
  • India: Key tax proposals arising from the Union Budget
     
  • Italy: The Italian Investment Management Exemption: a new safe harbor for asset manager of foreign investment vehicles
     
  • Philippines: WHT on Income of Foreign Investors in Philippine Securities
     
  • Poland: Reference for preliminary ruling on Polish CIT exemption for self-managed foreign investment funds; Finance Minister's public tax ruling on disclosure duties of real estate companies
     
  • Portugal: ECJ rules that marketing of shares in common funds falls within the scope of the Council Directive concerning indirect taxes on the raising of capital(Case C-656/21)
     
  • Sweden: Three Finnish public sector pension institutions may be comparable with the Swedish AP funds and be granted a refund of WHT levied on dividend income
     
  • United Kingdom: UK IME Investment Transactions List updated with crypto assets
View PDF

News from nine European countries with a focus on the international Financial Services industry

Sub-participations in loans - ECJ judgement of 6 October 2022 (C-250/21)

Consequences of the Cum-Ex-Trades on WHT refund and relief in Austria

The Belgian Constitutional Court decides on the annual tax on securities accounts (ATSA)

Additional taxes for the Belgian financial sector and snowball effect for Belgian regulated investment companies (tax-on-tax)

Reclaim opportunity re Belgian WHT for Luxembourg SICAVs

China: Tax audits on private wealth

Czech Republic: Windfall tax

Draft bill to improve attractiveness of Germany as a Financial Services location

Germany: Court decision: taxation of realized capital gains from fund units in the context of the 2018 tax reform

Italian Tax authorities rule on VAT and income taxes on mining activity

Poland: Changes to banking tax

Changes on Spanish SICAVs

United Kingdom: Autumn Statement 2022 impacts financial institutions

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News from nine European countries with a focus on the international Financial Services industry

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

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News from nine European countries with a focus on the international Financial Services industry

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

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International Corporate Tax

#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

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

View PDF

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

View PDF

Mergers & Acquisitions

#1/2023
WTS Mergers & Acquisitions
Newsletter
Updates from 8 countries with a focus on the international M&A industry

Updates from 8 countries with a focus on the international M&A industry

  • Austria: Reserved dividends in the case of share deals
  • Belgium: Leveraged distributions challenged by the tax authorities
  • Brazil: Impact of contingent consideration on tax amortisation of goodwill
  • China: Case study – indirect share transfer
  • France: Management package – back to reality?
  • Poland: Latest amendments to the Polish restructuring law
  • Romania: Consolidation for corporate income tax purposes
  • Switzerland: Substance requirements for international investments or group structures
  • General: Deals news
View PDF

Global Mobility

#1/2023
WTS Global Mobility
Newsletter
Brief overview of recent or expected changes in the area of Global Mobility
#1/2022
WTS Global Mobility
Newsletter
Brief overview of recent or expected changes in the area of Global Mobility
#2/2021
WTS Global Mobility
Newsletter
#workfromanywhere – Time to balance the benefits and risks
#1/2021
WTS Global Mobility
Newsletter
Brief overview of recent or expected changes in the area of Global Mobility in 11 selected countries

Brief overview of recent or expected changes in the area of Global Mobility

  • Australia: Pacific Australia Labour Mobility expansion
  • Austria: Income Tax - exemption with progression for non-residents.
  • Belgium: Belgian expat tax regime now extended to foreign non-profit organisations
  • China: IIT benefits continue for another year
  • France & Switzerland: Agreement on the taxation of home office income
  • Germany: New Framework for telework between Germany and Austria
  • Hungary: Tax allowances and leave in 2023
  • Italy: New interpretations of recurring cross-border tax issues
  • Netherlands: Exchange of information obligation
  • Nigeria: Recent updates on immigration rules
  • Poland: New rules on remote work and business trips
  • Portugal: Digital Nomad visa and taxation of crypto asset-derived income
  • Saudi Arabia: Tax implications of global mobility in KSA.
  • Senegal: Senegal raises its personal income tax shield to 43%
     
View PDF

Brief overview of recent or expected changes in the area of Global Mobility

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

View PDF

#workfromanywhere – Time to balance the benefits and risks

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

View PDF

Brief overview of recent or expected changes in the area of Global Mobility in 11 selected countries

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

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View more

Transfer Pricing

#3/2022
WTS Transfer Pricing
Newsletter
Transfer Pricing Newsletter: Update on the recent news and cases in 13 countries
#2/2022
WTS Transfer Pricing
Newsletter
Transfer Pricing Newsletter: Update on the recent news and cases in 14 countries
#1/2022
WTS Transfer Pricing
Newsletter
Transfer Pricing Newsletter: Update on the recent news and cases in 15 countries
#3/2021
WTS Transfer Pricing
Newsletter
Transfer Pricing Newsletter: Update on the recent news and cases in 15 countries

Transfer Pricing Newsletter: Update on the recent news and cases in 13 countries

Argentina: Argentine Tax Court ruling on “Cargill” Transfer Pricing Case

Austria: Intra-Group Financing – Austrian Specifics

Austria: Decision of the Austrian Financial Court regarding Transfer Pricing

Brazil: Superior Court of Justice rules out illegal Methodology to calculate the PRL 60 Method

Chile: 2022 Tax Reform Bill Proposal to update Transfer Pricing Regulations in Chile

France: Research Tax Credit and Subsidies Synergies with Transfer Pricing

Indonesia: Introduction of New Transfer Pricing Methods

Italy: New Arm's Length Range is set for Transfer Pricing

Poland: Administrative Courts condemn Tax Authorities’ unlawful Practices regarding the Questioning of Benchmarking Studies 

Saudi Arabia: Amending Transfer Pricing Instructions to apply to Zakat Payers

Senegal: Transfer Pricing: Systematizing the Control of Reporting Obligations

Thailand: Cash Pooling between related Companies

Ukraine: The War is not an excuse to ignore Transfer Pricing Compliance

United Kingdom: Draft Legislation on the UK TP Documentation Requirements

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Transfer Pricing Newsletter: Update on the recent news and cases in 14 countries

Europe

Austria: New Info from the Austrian Ministry of Finance – Mutual Agreement Procedure and Arbitration Procedure

Denmark: Mandatory Submission of Transfer Pricing Documentation in Denmark during 2022

France: The SAP Case: The Difficulty for Tax Courts when Handling Negative Interest Rates

Hungary: TP Update

Ireland: The Irish Position on the proposed ATAD3 Directive

Italy: DAC6 Reporting: Year-End TP Adjustment

United Kingdom: APAs, ATCAs and HM Revenue and Customs Statistics


Further Countries

Argentina: Deemed Affiliation: Cross-Border Transactions with Low-Tax Jurisdictions

Brazil: Plan for Brazil’s Accession to the OECD: Changes to Transfer Pricing Rules

Chile: Practical Lessons learned from Transfer Pricing Audits in Chile

China: First Chinese Customs and Tax Collaborative Transfer Pricing Management Mechanism

India: The Indian Revenue’s Measures for effective Dispute Resolution

Kenya: A Fundamental Shift in the Transfer Pricing Regime in Kenya

Senegal: After joining the Multilateral Convention, a Step forward in the Fight against Tax Evasion & Avoidance

View PDF

Transfer Pricing Newsletter: Update on the recent news and cases in 15 countries

Europe

Austria: No annual CbCR notification required since 1 January 2022

Czech Republic: The Czech Supreme Administrative Court’s thoughts on related party definition

France: The RKS case: shades of nuance in TP by the French Supreme Administrative Court

Germany: New case law on the determination of arm’s length interest rates for intercompany loans

Ireland: TP Compliance requirements in Ireland

Italy: New rules on TP documentation

The Netherlands: Netherlands disallows unilateral downward TP adjustments

Poland: Polish regulations on “indirect” transactions with tax havens

Portugal: Amendments to Transfer Pricing legislation

United Kingdom: Outcome of the UK consultation on TP documentation  

Ukraine: Ukrainian Ministry of Finance clarifies new TP rules on business purpose

Further Countries

Brazil: Effects of extinction of LIBOR rate to Brazilian TP controls

China: Deduction of interest charged by related parties  

New Zealand: New BEPS disclosure guidance and preparation forms

Taiwan: Taiwan CFC rules will be implemented as of 2023 in response to the Global Minimum Tax

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Transfer Pricing Newsletter: Update on the recent news and cases in 15 countries

Europe

Austria: New Austrian Transfer Pricing Guidelines 2021

Belgium: Belgian Transfer Pricing court case: a rare occurrence

France: The Engie Case: an ambitious new approach by the French Tax Administration

Germany: German Federal Ministry of Finance: Administrative Principles 2021 on Transfer Pricing published

Germany: Recent changes on German Tax Law concerning Transfer Pricing

Ukraine: State Tax Service intensifies TP control


Further Countries

Argentina: Transfer Pricing developments in Argentina

Benin: Transfer Pricing Update Benin

Chile: Migration of the approach of the Chilean Revenue Service to segments with greater fiscal impact

China: Responses to practical questions on the Transfer Pricing implications of the COVID-19 impacts15

Nigeria: Transfer Pricing Update on Nigerian TP case

Senegal: Implementation of Action 12 of BEPS project: a strengthened internal tax system

Taiwan: Supreme Administrative Court decides on one-time Transfer Pricing adjustments

Thailand: TP legal framework and practical insights

United States: The US’ role in global adoption of Pillar 1 and Pillar 2 / ongoing conversations in the US on tax reform / a status update on US tax reform

Vietnam: Transfer Pricing Update Vietnam

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View more

Global VAT

#1/2023
WTS Value Added Tax
Newsletter
Recent or expected changes in VAT and GST regulations and compliance duties in various EU and third countries
#4/2022
WTS Value Added Tax
Newsletter
Recent or expected changes in VAT and GST regulations and compliance duties in various EU and third countries
#3/2022
WTS Value Added Tax
Newsletter
Recent or expected changes in VAT and GST regulations and compliance duties in various EU and third countries
#2/2022
WTS Value Added Tax
Newsletter
Recent or expected changes in VAT and GST regulations and compliance duties in various EU and third countries

Recent or expected changes in VAT and GST regulations and compliance duties in various EU and third countries

EU Member-States

  • Belgium: Amendments to the VAT statute of limitations – VAT compliance impact
  • Italy: VAT refund in the case of late VAT registration
  • The Netherlands: Dutch Supreme Court clarifies the term "essentially new construction"
  • Poland: Mandatory e-invoicing as of 2024

Further countries

  • Kingdom of Saudi Arabia: Rules and procedures for VAT recovery by licensed real estate developers
  • Nigeria: Expected changes to VAT law in 2023
View PDF

Recent or expected changes in VAT and GST regulations and compliance duties in various EU and third countries

EU Member-States

Italy: VAT deduction and year-end peculiarities

Poland: recent developments regarding the fixed establishment in Poland

Romania: changes to Romanian Fiscal Code as of 1 January 2023

Further countries

Brazil: federal government reduces tax burden on the import of services

China: national VAT e-invoicing targeted this year

Switzerland: changes to the Swiss VAT landscape as of 1 January 2023

View PDF

Recent or expected changes in VAT and GST regulations and compliance duties in various EU and third countries

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

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Recent or expected changes in VAT and GST regulations and compliance duties in various EU and third countries

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

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