WTS Global Newsletters

• 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

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

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

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

Austria: Withholding tax refund for intermediary holding in Cyprus denied

India: Doubling of withholding tax on royalty & FTS

Pakistan: Pakistan Supreme Court rules on the controversy involving service PE 

Poland: Post-pandemic approach to ‘home office’ – PE or not?

Portugal: Remote working is here to stay

Saudi Arabia: New special economic zones to be established in Saudi Arabia

Switzerland: Pillar II – implementation in Switzerland

United Arab Emirates: Corporate Tax in UAE: impact on non-residents

• Argentina: New precedent on the conflicts between domestic GAARs vs treaty law
• Austria: UAE shareholders now face Austrian withholding tax on dividends
• Brazil: Proposed changes to the Brazilian rules on the tax deduction of royalties
• Hungary: Termination of the double tax treaty between the United States of America and Hungary
• Italy: International tax amendments in the Italian Budget Law for 2023
• Nigeria: Updates in international corporate tax (ICT) in Nigeria
• Pakistan: Changes in the capital gains tax regime
• Poland: Another twist in the interpretation of “beneficial ownership”
• Senegal: Banking sector: the introduction by the GTC (general tax code) of the deductibility of losses on doubtful or disputed debts through the initial finance law for the year 2023
• Spain: Tax measures introduced in Spain for 2023

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

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 

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%
 

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

EU Member-States

• Germany: Mandatory electronic invoices for domestic B2B transactions - discussion proposal
• The Netherlands I: Dutch Court decision on VAT treatment of Park Sleep Fly
• The Netherlands II: Internal positions published by the Dutch Tax Administration
• Poland: The dispute resolved: charging of electric vehicles classified as supply of goods
• Spain: Direct debit of tax debts in Spain

Further countries

• China: Input VAT refunds being scrutinised
• Switzerland: Increase of Swiss VAT rates as of 2024

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

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

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