Tax & Legal

Tax & Legal News – Issue 4, June 2018

Some of the topics in this issue: Administration amends circular on treaty-shopping rules, Pensions paid abroad subject to limited tax liability, ECJ – Denmark to set-off final losses of foreign EU-branch.

Official Pronouncements
Federal Finance Ministry circular on the tax treatment of salaries for tax treaty purposes is updated
Federal Ministry of Finance amends earlier circular on treaty-shopping rules

Tax Court Cases
Input VAT deduction available despite missing details on the date of supply
Pensions paid abroad subject to limited tax liability
Statutory interest rate levied on late payment of taxes no longer up-to-date?
Principle of deemed single uniform compensation
Curtailment of loss relief: Lower tax court allows suspension of payment

From Europe
ECJ – Refusal to set-off EU-branch losses in Denmark not compatible with EU law
ECJ decision German on CFC regulations
Latest Updates from OECD/EU in the tax avoidance arena
ECOFIN-Council formally accepts the changes to the Mutual Assistance Directive in relation to cross border reporting