Sydney, Australia

Australian Temporary Resident Rules

By David Lechem, Stephen Jankelowitz and Robert Moylan, Ageis

In this global world, incentives are offered by some countries to encourage investment and immigration. Australian tax residents are taxed on worldwide income including income from assets held indirectly through interests in foreign companies or trusts. In 2006, Australia introduced a regime where Australian tax residents who are temporary residents can apply significant tax concessions in respect of their foreign income and gains.

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New Administrative Principles “VWG 2020” on Transfer Pricing in Germany 2020

By Oliver Biernat, Benefitax GmbH

German companies or permanent establishments that are involved in intragroup cross-border services exceeding a value of EUR 600,000 p.a., or in intragroup cross-border supplies exceeding a value of EUR 6 million p.a., must present transfer pricing documentation to the German tax authorities that corresponds to strict and detailed German regulations. Companies that do not fulfil this obligation, or cannot prove that the transfer prices are correct, must expect severe penalties of up to EUR 1 million and may be faced with a high profit estimation from the tax offce.

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Construction workers

IR35 Risks with Overseas Parent Companies or Overseas Contracts

By Alan Rajah, Lawrence Grant

From 06 April 2021, the new UK IR35 off-payroll working rules come into force for the private sector. The responsibility for assessing IR35 will now pass to the end client. The end client will be required to review the arrangement with the contractor providing services via their Personal Service Company (PSC) and determine whether the status of the engagement is a deemed employment.

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Kolkata City, India

Indian Investment Income – Income Tax Paradigm Shift

By Anjali Kukreja and Raghu Marwah, R.N. Marwah & Co. LLP

Globally, investors and companies are attempting to move out of China following the COVID-19 pandemic and are analysing alternative jurisdictions offering a high return on capital, low tax costs, and ease of doing business. India is seen as a very attractive destination based on these investor criteria. The world is today witnessing excess liquidity, due to slashed interest rates and different emergency measures taken by various countries to counter the pandemic-led economic fallout.

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Frankfurt, Germany

COVID-19 and Its Effects on Transfer Prices of Routine Companies

By Oliver Biernat, Benefitax GmbH

COVID-19 currently has a massive impact on our lives and our economy. Many companies experience declining sales and profits, some industries even struggle to survive. Therefore, in internationally operating groups the question arises as to how the unplanned fluctuations in operating results can be adequately taken into account and documented in transfer prices.

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Port Louis, Mauritius

Termination of DTA between Zambia & Mauritius

By Graeme Saggers, Nolands

The Zambian Government announced the termination of the Double Taxation Agreement (“DTA”) between the Government of the Republic of Zambia and the Government of the Republic of Mauritius on the 22nd of June 2020 by way of a written notice of termination given to Mauritius.

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ECJ Decision “Aures Holdings”

By Brigitte Jakoby, Jakoby Dr Baumhof – Wirtschaftsprüfer Steuerberater Rechtsanwälte

In the matter “Aures Holdings” (AH), the European Court of Justice (ECJ) had to evaluate whether the transfer of the administrative seat of a company from one Member State to another could involve the transfer of losses between Member States. AH is a company incorporated under the Netherland’s law, whose registered seat and place of effective management were originally located in the Netherlands. AH was a tax resident of the Netherlands (unlimited tax liability) and incurred a loss of EUR 2,792,187.00 in the financial year 2007. On 01 January 2008, AH initially set up a permanent establishment in the Czech Republic and on 01 January 2009 transferred its place of effective management to the address of the permanent establishment. In this context, AH also transferred its tax residence to the Czech Republic and applied to the Czech tax authorities for the deduction of the loss which had been incurred in the Netherlands until 2007.

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