PwC

Tax & Legal

Tax & Legal News – Issue 1, January 2012


Issue 1, 2012

Includes: PwC Reports, Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC

This edition includes:

PwC Reports

Tax changes for 2012
Bank levy double tax treaty with the UK
Double tax treaty with Liechtenstein

Official Pronouncements

Agreement with UK on redundancy payments
Minimum tax – payment suspension
No provision for set off of excess receipts against future income
Finance ministry refuses foreign parent of Organschaft
Only one regular place of work with same employer
2011 export documentation rules can be followed first quarter 2012
Debts automatically bad on opening insolvency proceedings

Supreme Tax Court Cases

Vehicle lessor to provide for planned loss on sale
Compulsory product registration costs incurred on date of application
Declining rate loan interest to be spread over term of the loan
Private equity fund earns trading income
Marketable securities to be written down to year-end rate
Write-down of units held in investment funds
EU royalty payments to be taxed net
Organisational integration of VAT group must be enforceable by parent
Intra-community supply, even if pick-up agent conceals prior resale
No VAT exemption for fraudulent intra-community supply
VAT on building with solar generator deductible on notional turnover
Cinema snacks taxed at reduced rate of VAT
No exemption for danger or readiness money for essential services
Only partial foreign tax credit on repeated gifts

From Europe

Parent/Subsidiary Directive recast
Germany’s dividend withholding tax hinders free movement of capital
Dutch exit tax excessively burdensome
VAT-free business transfer despite only short-term lease of premises
Sale of bad debts without recourse not a provision of services
Aviation fuel duty exemtion only for aircraft used to provide services
Court of Auditors can insist on auditing a nation’s VAT systems

From PwC

Breaking news

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