Tax & Legal

      • nivo slider image nivo slider image nivo slider image

    Tax & Legal

      Post-dissolution profits and losses from foreign P.E. attributable to foreign country

      The Supreme Tax Court has held that the profit from the release of a provision no longer required arising from a foreign permanent establishment long after closure falls under the business profits clause of the relevant double tax treaty and is thus taxable in the foreign country.

      Compensation for loss of office taxable in Switzerland despite mutual agreement to contrary

      The Supreme Tax Court has held that compensation for loss of office is taxable in the state of residence under the German/Swiss tax treaty and not in the state of employment. A mutual agreement between the two revenue authorities to the contrary is not to be applied for lack of an adequate legal basis.

      VAT on asset leasing

      The finance ministry has added a passage on asset leasing to its VAT Implementation Decree to the effect that entry by the leasing company into the transaction before delivery of the asset to the customer renders the lessor the purchaser, whereas entry afterwards qualifies the leasing transaction as VAT-free finance.