Taxation

Italy: Horizontal tax consolidation

By Lodovico Comploj and Martin Lechner, Pichler Dejori Comploj & Partner

In order to prevent an infringement of the European principles of non-discrimination and freedom of establishment, the Italian government introduced important changes to the domestic tax consolidation rules.

Lawrence Grant Recovers GBP 50k from French VAT Authorities

Lawrence Grant, Chartered Accountants were recently successful in recovering GBP 50k in input VAT that was deducted by French VAT authorities, after the VAT was held by the French VAT authorities for almost one year.

Load, Aim, Misfire! A look at the practical implications of the additional 3% SDLT rate

By Alex Barnes, Memery Crystal LLP

It’s almost a year now since the Government in the UK introduced the additional 3% Stamp Duty Land Tax (SDLT) rate on certain purchases of dwellings. This was no doubt done partially to raise revenue, but in the main was probably to appeal to voters by once again targeting those ‘nasty wealthy landlords’. As is often the case with new or additional taxes, this tax hike is prone to misfire and in many cases it’s not those that the Government was probably seeking to target who actually bear the brunt of the change.

Major reforms of French investments taxation

By Prof. Robert Anthony, Anthony & Cie

Wealth tax 2011

Only taxpayers possessing assets over M € 1.3 have an obligation to declare and to pay Wealth Tax (on September 30th, 2011). Wealth tax 2012: As from 2012, a new tax threshold at two levels is established, applicable from the first euro:
  • 0.25 % for assets between M € l.3 and M€3
  • 0.5 % abov

Mexico "sugar tax" is in fact extensive tax reform

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By Sergio Guerrero Rosas, Guerrero y Santana, S.C.

After receiving the opinion of the Commission of Finance and Public Credit, last month the Mexican Congress approved the economic package proposed by President Peña Nieto on 8 September 2013. The package includes substantial amendments to, as well as the repeal and enactment of, various tax laws. The objective of the proposal is to generate employment and support the economy through a counter-cyclical effort. However, no programmes have been created or launched to stimulate investment or employment.

Mexico’s tax reforms to date and what to expect next

By Sergio Guerrero Rosas, Guerrero y Santana, S.C.

President Peña Nieto’s controversial “sugar tax” was brought into force a year ago, targeting high calorie foods to the tune of 8% of their value. While the jury is still out as to whether it has had the desired effect on the population and the various burdens, what has become an issue of far greater significance is the success or otherwise of the more substantial reform package to which the sugar tax belonged.

Kassel, Germany

Multilateral Instrument Signed

By Bernhard Schwechel, FACT GmbH

On 7 June 2017, almost 70 countries including Germany signed the so-called ‘Multilateral Instrument’ (MLI) in Paris. This is a product of the OECD’s BEPS project and designed to dynamically adjust a multitude of existing bilateral double taxation treaties (BDTs) between member countries to internationally accepted standards - faster than would be possible using individual bilateral negotiating procedures.

Negative consequences of using the wrong VAT ID

By Carina Langegger and Manfred Leitinger, Prodinger & Partner

The ECJ decision issued on 22 April 2010 (Case C-539/08) regarding intra-community acquisitions between and Facet BV/Facet Trading BV showed that small formal invoicing mistakes can have significant implications for tax. The consequence of a purchaser using a VAT ID differing from the VAT ID of the country where the supply ends is that the purchaser becomes liable for VAT in both countries (where the supply ends and in the country of the VAT ID which was used). However, the right of VAT deduction would only be granted in the country where the delivery ends.

Netherlands: Competitive customs and VAT climate

By Toon Hasselman, LIMES International B.V.

The Customs Administration of the Netherlands is known for its practical and pro-active approach towards facilitating international trade and optimising customs and VAT procedures. Since the abolition of the internal border in 1993, the authorities have issued regulations to facilitate the import and distribution of goods into the EU via the Netherlands.

New changes to the French wealth tax

By Prof. Robert Anthony, Anthony & Cie

On April 12th the French government announced new changes to the wealth tax which are expected to be adopted by the Parliament by mid July at the latest.

Frankfurt

New German License Barrier

By Oliver Biernat, Benefitax GmbH

Implementing BEPS action plan 5, Germany will introduce partial or entire non-deductibility for preferentially taxed intra-group royalties (license barrier) as of 1 January 2018. The aim of the new Sec. 4j in the German Income Tax Act is to protect the German tax base during the transitional period until 30 June 2021, during which time countries will still be allowed to continue extending current benefits to existing beneficiaries of IP regimes.

New start for a standard passenger vehicle taxation in the EU

13 million new vehicles are registered in the European Union every year. Nevertheless the registration tax and the vehicle tax are not harmonized within the EU. The EU commission recognizes the danger that there could be a double vehicle taxation of citizens and companies due to lack of harmonization. In order to prevent this, the commission presented regulations for passenger vehicle taxation in a notification on December 14, 2012 and recommended proceedings for implementation to the member countries.

New Tax Regime in the Republic of Cyprus

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By Marios Eliades, M. Eliades & Partners LLC

The House of Representatives of the Republic of Cyprus has introduced new legislation relating to the intellectual property regime,  interest deductibility, group relief and deemed distribution of dividends. The new legislation became effective 1st January 2012.

Prague, Czech Republic, Christmas Market

New Transfer Pricing Guidelines Issued

By Richard Jahoda Jr, Grinex Czech Republic

The highly anticipated new edition of the OECD’s Transfer Pricing Guidelines was issued on 10 July 2017. It mainly reflects a consolidation of changes resulting from the BEPS project. Probably the greatest change in the 2017 edition is in the chapter on the arm’s length principle, in part explaining the identification of commercial or financial relations.

NON HABITUAL RESIDENT – The Portuguese special tax regime for inbounds

By Sérgio Ramos, Pontes, Baptista & Associados

In addition to the wonderful Southern European climate and culture, Portugal provides an excellent quality of life and an active environment tor investors and businessman that wish to have a residence and business in Europe.

OECD presents united front against aggressive tax optimization

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The revenue that states are losing due to international tax optimization by large companies is back into the focus of the Organization for Economic Co-operation and Development (OECD). According to the OECD study "Addressing Base Erosion and Profit Shifting", multinational corporations are eroding the tax base and disproportionately shifting their profits.

Outbound payments under close scrutiny by the Chinese tax authority

By Ricky W. P. Wong, Wong Brothers & Co

In recent years, the Chinese tax authority has intensified its efforts to control outbound inter-group service fees and royalty charges. In July 2014, the State Administration of Taxation (SAT) released an internal circular (“Circular (2014) No. 146”) asking local tax authorities to initiate detailed investigations on all significant outbound service fee payments and royalty charges made by domestic enterprises to their overseas related parties between 2004 and 2013, with a view to identifying avoidance schemes for profit shifting.

Overseas property owners in the UK: The honeymoon is over!

By Alan Rajah, Lawrence Grant, Chartered Accountants

The UK's unique exemption from Capital Gains Tax (CGT) for non-UK residents has been reformed with the government's realisation that tax should be paid on gains arising from the sale of UK residential properties. Currently, most foreign property owners in the UK are not subject to CGT and this article
outlines the changes to the UK's CGT regime for non-residents which will come into effect from 6 April 2015.

Ownership Taxation in France

By Prof Robert Anthony, Anthony & Cie

Naturally, foreign property owners wish to invest in a way which protects their inheritance and minimises their taxes. France is known to be a high tax jurisdiction. Currently, wealth tax exists, although this may no longer be the case under a new conservative government.

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