Tax & Legal

Tax & Legal News – Issue 4, October 2017

In this issue: PwC Reports, Official pronouncements, Tax Court Cases and From Europe

From PwC
Forfeiture of Loss relief: further referral to Constitutional Court
Trade tax on profits from disposal of partnership interest unconstitutional?
European Commission proposes far-reaching reform of the EU VAT system
Bundesrat reacts positively to exchange of information for tax-saving schemes
Automatic exchange of financial account information has commenced
Transparency Register: registration obligations from 1 October 2017
New US tax reform framework released

Official Pronouncements
VAT grouping and input VAT deduction for holding companies
Country-by-Country Reports: German Ministry of Finance releases circular

Tax Court Cases
5-year tax deferral on transfer of roll-over relief provision also applied retroactively
German exclusion from withholding tax relief in conflict with EU law?
Imputed VAT taxation and margin-scheme taxation before ECJ
No pro-rata reduction of tax-free allowance for non-resident beneficiaries

From Europe
Profit participation rights at fixed rate is interest under German-Austrian tax treaty
Disallowance of discount on delivery of pharmaceuticals in breach of EU VAT law?
ECJ to clarify invoice requirements for deduction of input VAT
Refusal to deduct French social security contributions not compatible with EU law