Kategorien: Tax & Legal Newsflash (24 gefunden)

  2. 21. März 2023

    Tax Insights from Global Structuring - Germany publishes Pil ...

    The Federal Ministry of Finance (MoF) published a draft law on March 20, to implement the ‘Pillar Two’ Directive ensuring a global minimum taxation for multinational groups and large domestic groups in the European Union (so-called Minimum Tax Directive Implementation Act - MinBestRL-UmsG). The publication of the German draft law follows the formal adoption by the EU Council to adopt Pillar Two on December 15, 2022.

    Kategorien: Legislation, Tax & Legal Newsflash
    Schlagwörter: Gesetzgebung, EU-Recht, Pillar Two
  4. 28. März 2022

    Compliance-Trap in International Insurance Programs

    We have been noticing an increased number of notifications to the Federal Central Tax Office during tax audits for the failure by German subsidiaries and permanent establishments to declare and pay over German Insurance Premium tax on premiums paid by a foreign group entity to an insurer domiciled outside the EU or EEA. This can prove very costly.

    Kategorien: Tax & Legal Newsflash
    Schlagwörter: Insurance / Versicherungen, secondary li ...
  5. 18. November 2021

    Foreign managing directors, board members & authorized signa ...

    Our Newsletter comments upon the recent trend of German tax authorities - particularly during wage tax audits - to consider whether a wage tax withholding obligation has arisen in cases where non-resident managing directors, board members and, in some cases, authorized signatories of German companies work for and in the interest of a German legal entity.

    Kategorien: Tax & Legal Newsflash
    Schlagwörter: Steuern / Tax
  6. 09. November 2021

    Tax & Legal Newsflash - Italy issues draft circular on hybri ...

    The Italian Tax Authorities (ITA) launched, on October 18, a public consultation on the draft interpretative Circular Letter (the ‘Draft Circular’), which, at 111 pages, covers the application of the hybrid mismatch arrangements rules (the ‘Hybrid Rules’) as governed by Legislative Decree 142/2018 (the ‘ATAD Decree’) that implements the ATAD Directives through domestic italian legislation.

    Kategorien: Tax & Legal Newsflash
    Schlagwörter: Steuern / Tax
  20. 17. Mai 2019

    Newsflash: Supreme Tax Court changes its case law regarding ...

    According to the Supreme Tax Court in its ruling of 27 February 2019, published on 15 May 2019, and contrary to its previous case law, Article 9 (1) of the OECD Model Tax Convention, does not prohibit an income adjustment under domestic transfer pricing rules, where the write-off of an unsecured group loan is not recognised as a deduction from taxable profits.

    Kategorien: Tax & Legal Newsflash
    Schlagwörter: Steuern / Tax
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Björn Viebrock

Björn Viebrock

Partner
Düsseldorf

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