In May 2004, the German Federal Ministry of Finance issued an updated and revised version of the comprehensive regulations that guide the tax authorities in their application of the Foreign Transactions Tax Law (Aussensteuergesetz - AStG). The revised regulations (published in the German Federal Gazette Part I 2004, special issue 1/2004) supersede those of December 1994 and reflect subsequent legislation and high court decisions
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort