The non-association of tax liability and civil law transactions in Germany

By Niels Webersinn, nbs partners

In Germany, there is a saying with regard to legal proceedings – on the high seas and in court, you are in God's hands. Despite all the efforts of the tax advisors and lawyers to pursue fundamentally promising paths with clients and to take realistic procedural steps in order to protect them from unnecessary adversity, the statement proves true time and again.

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Final loss deduction in Germany - Youngest ECJ case law

By Ingo Prang and Marcus Rösen, KPP Steuerberatungsgesellschaft mbH

The German Federal Fiscal Court (BFH) had submitted a request for a preliminary ruling to the European Court of Justice (ECJ) regarding the deduction of so-called final losses for EU foreign permanent establishments (PEs). In the most recently published ruling of 09 September 2022 (ref. C-538/20), the ECJ ruled that the freedom of establishment does not preclude the non-deductibility of final losses in EU-exemption PE cases.

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Lausanne, Switzerland

Tax aspects of the revision of the stock corporation law in Switzerland

By Cédric-Olivier Jenoure and Sascha Wohlgemuth, Bratschi Ltd.

In Switzerland on 01 January 2023 the new stock corporation law came into force. One change is that stock corporations and limited liability companies may express their nominal capital not only in Swiss francs (CHF), but also in EUR, USD, GBP, or JPY if this is their functional currency. However, it is mandatory that at the time of incorporation the equivalent value is at least CHF 100,000 for stock corporations, and CHF 20,000 for limited liability companies.

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Transfer Pricing in Singapore

By Eddie Lee, Robert Yam & Co. PAC

1. Introduction

Transfer Pricing (“TP”) is an essential aspect of the regulatory requirements in Singapore for companies which have intra-group transactions or related party transactions (“RPTs”) in Singapore and if they expand their businesses outside Singapore. TP rules require that those RPTs are conducted at arm's length prices, which refers to prices that would be agreed upon by unrelated parties in similar situations.

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film crew

Australia’s tax incentives for the screen industry

By Gary Williams, Rosenfeld, Kant & Co.

Since a major overhaul of Australia's screen industry tax incentives in 2008, television and film makers from around the world have been attracted to Australia for producing content, accessing post- production facilities, and/or using Australia as a filming location.

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Sydney, Australia

Proposed changes to Australia’s thin capitalisation rules

By Tony Nunes and Susan Ma, Kelly + Partners Chartered Accountants

In the October 2022 Federal Budget, the Australian government announced potential changes to Australia's thin capitalisation rules to adopt the OECD's recommended approach in BEPS Action 4. A draft legislation is currently undergoing a consultation process until 13 April 2023 (the Draft). The changes, if enacted, will apply to multinational business operating in Australia (except banks and financial entities) with at least AUD 2 million in tax deductions for interest expenditures, for income years commencing on or after 01 July 2023.

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Mexico City, Mexico

A quick overview of the controlling beneficiary figure in Mexico

By Prof Sergio Guerrero Rosas, Guerrero y Santana

For as long as taxes have been around, tax authorities have designed mechanisms to ensure the collection of payment, and taxpayers have devised mechanisms to minimise its burden in a never- ending cat-and-mouse game. The figure of controlling beneficiary is one the latest updates in this endeavour.

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