-
December 2013
December 18, 2013
The German Federal Tax Court has put the Federal Ministry of Finance in its place, writes Thomas Küffner of KÜFFNER MAUNZ LANGER ZUGMAIER
-
December 17, 2013
The 11 EU member states looking to adopt a financial transaction tax (FTT) have discussed proposals for a narrower version of the tax to get it past stalled negotiations.
-
December 16, 2013
The UK has come third in a poll of countries that are best-placed to capitalise on a boost in international trade.
-
December 01, 2013
Stefan Ditsch of PwC gives an overview of recent tax developments and a selection of major law changes, tax court decisions and administrative rulings.
-
December 01, 2013
Susann van der Ham and Ina Sprenger of PwC critically discuss the recently issued draft ordinance on income allocation of permanent establishments as a further implementation step of the Authorised OECD Approach (AOA) into German tax law.
-
December 01, 2013
Ulf Andresen, Jobst Wilmanns and Oliver von Schweinitz of PwC look at the tax and transfer pricing implications of a separation of investment banking from commercial banking.
-
December 01, 2013
Jens Müller-Lee and Peter Imhof of PwC discuss recent news and developments on organisational integration and their consequences on VAT grouping in Germany.
-
December 01, 2013
The issues surrounding changes to the German VAT Implementing Code have been addressed. But has the Federal Ministry of Finance solved them all? Ronny Langer of KÜFFNER MAUNZ LANGER ZUGMAIER investigates.
-
December 01, 2013
Maik Heggmair, Kai Schwinger and Nicolas Boehlke of WTS recount their experiences with Chinese tax law and related party transactions between Germany and China from a German perspective.
-
November 2013
November 27, 2013
Oliver Rosenberg, partner at Linklaters in Dusseldorf, summarises a June decision of the Federal Tax Court (FTC) which clarifies the interpretation of Article 1 paragraph 7 and Article 2 paragraph 10 of the Germany/US Income and Capital Tax Treaty (1989) (amended 2006) (DTT US 2006). Article 1 paragraph 7 of the DTT US 2006 is particularly relevant and important for the treatment of hybrid entities under the treaty.
-
November 22, 2013
Four jurisdictions have received the thumbs-down from their peers in new compliance ratings issued by the OECD's Global Forum on Transparency and Exchange of Information for Tax Purposes.
-
November 12, 2013
Oliver Rosenberg, partner at Linklaters in Dusseldorf, discusses the treatment of interest payments from a German partnership to its foreign partners, including why there is an increased risk of double taxation as a result of the new section 50d paragraph 10 of the German Income Tax Act (ITA).
-
November 06, 2013
In its circular of October 23 2013, the Federal Ministry of Finance made statements regarding the effectiveness of VAT clauses in contracts for the purchase of immovable property, reports Oliver Zugmaier of küffner maunz langer zugmaier.
-
November 06, 2013
Morrison & Foerster is launching an office in Berlin, taking nine partners from Hogan Lovells in the city.
-
November 01, 2013
Developing countries often impose withholding tax on payments for certain offshore services. Companies should be aware of where in the world this occurs and the potential protection under tax treaties so they can plan accordingly, says Konstantin Korobchenko of EY and the University of Leiden.
-
November 01, 2013
Ulf Andresen and Jobst Wilmanns of PwC in Frankfurt, explain how Germany’s new profit allocation rules for insurance permanent establishments (PE) potentially discriminate against foreign insurers.
-
November 01, 2013
-
October 2013
October 30, 2013
The German Federal Fiscal Court passed its judgment (XI R 4/11) regarding VAT deduction for players’ agent commissions on August 28 2013. The key question is whether the players’ agents render services to the soccer club, writes Oliver Zugmaier of küffner maunz langer zugmaier.
-
October 24, 2013
The European Commission said the regime contravenes certain provisions in the EU’s Code of Conduct on Taxation. The code is voluntary, but if the UK does not acknowledge the opinion (delivered to finance ministers on Tuesday) it would be the first time a member state’s government has ignored a commission opinion.
-
October 22, 2013
Find out which firms have been ranked in World Tax 2014, the annual directory of the leading tax advisory and law firms, is now live online.
-
October 18, 2013
US corporate tax reform could be good news for European multinationals if it forces other OECD countries to drive their own rates down yet further, according to a panel at the Irish Tax Institute’s global tax policy conference in Dublin today.
-
October 16, 2013
The UK has signed agreements to automatically share tax information with the Isle of Man and South Africa as it builds on initiatives aimed at greater cooperation on tax issues.
-
October 14, 2013
Harm Oortwijn, director of international tax and reporting at Paramount Pictures and owner/director of EA Tax Services, looks at trends regarding international tax transparency including the role of tax treaties, and analyses why greater cooperation via information exchange mechanisms is necessary.
-
October 09, 2013
The fiscal authority is to impose VAT on the cross-border provision of a company car at the residence of the final consumer. This means that an employer now has to pay foreign VAT if employees have their residence in another EU member state and receive a company car which is also for private use, writes Ronny Langer of küffner maunz langer zugmaier.
-
October 09, 2013
Articles 306-310 of the EU-VAT-Directive contain a special scheme for travel agents’ services, explains Ronny Langer of küffner maunz langer zugmaier.
-
October 01, 2013
The German fiscal authority will impose VAT on the cross-border provision of a company car at the residence of the final consumer. This means that an employer now has to pay foreign VAT if employees have their residence in another EU member state and receive a company car that is also for private use.
-
September 2013
September 25, 2013
After a long time of discussions and after many postponements, the obligation to provide proof for zero-rated intra-Community supplies finally changes with effect from October 1 2013, writes Ronny Langer of küffner maunz langer zugmaier.
-
September 18, 2013
By the judgment of March 13 2013 (3 K 235/10), the tax court Munich recognised partnerships, for the first time, as being potential controlled members of a VAT group. This judgment allows plenty of scope for companies and also contributes to tenure neutrality, explains Thomas Küffner of küffner maunz langer zugmaier.
-
September 18, 2013
After last week’s opinion from the European Council's legal service stated that part of the residence principle of the proposed European financial transaction tax (FTT) is incompatible with European law, some proponents feared the worst. But the end is not necessarily nigh.
-
September 16, 2013
The IRS has published "technical corrections" to the final FATCA regulations, reports Burt Staples & Maner
-
September 10, 2013
G20 leaders met in St. Petersburg last week, with international taxation once again high on the agenda.
-
September 05, 2013
Internationally coordinated efforts to update taxation rules have never been stronger. With these changes come new challenges for taxpayers. Brian Tully, vice president and head of ONESOURCE Transfer Pricing for the Tax & Accounting business of Thomson Reuters, explains why embracing transparency and technology will stand taxpayers in good stead for future reforms.
-
September 04, 2013
While G20 rhetoric repeatedly trumpets tackling tax evasion as a key action item, events in Syria are likely to dominate proceedings in Russia. Tax will not be sidelined for long, though.
-
August 2013
August 14, 2013
The third edition of International Tax Review’s Tax Controversy Leaders guide is out now. Find out who the top-rated disputes specialists are in your jurisdiction.
-
August 07, 2013
Ronny Langer of küffner maunz langer zugmaier looks at the VAT exemption for advisory services regarding investment recommendations for investment management companies.
-
July 2013
July 24, 2013
London Mayor Boris Johnson has called on German, Italian and Spanish banks to move their headquarters to London to avoid the financial transaction tax (FTT). But in doing so he has failed to understand how the tax will actually work.
-
July 23, 2013
Now the dust from last week’s G20 finance ministers’ meeting in Moscow is beginning to settle, the question is to what extent the OECD’s action plan for tackling base erosion and profit shifting (BEPS) marks a turning point in the history of international taxation, and whether the timeframes outlined in the report are realistic.
-
July 19, 2013
The OECD Action Plan for tackling base erosion and profit shifting (BEPS) was unveiled this morning at the G20 meeting of finance ministers in Moscow. The plan discusses a timeframe of between 12 and 24 months for implementing action and outlines how the OECD will work with national states to improve the overall tax take and clamp down on tax arbitrage by addressing perceived flaws in international rules.
-
July 17, 2013
Germany remains concerned about the competitive disadvantage it feels it is being placed under by the existence of European patent box regimes such as the UK Patent Box and the Dutch Innovation Box.
-
July 15, 2013
The implementation of the Foreign Account Tax Compliance Act (Fatca) will not begin on January 1 next year, after all.
-
July 07, 2013
Baker & McKenzie has promoted 15 members of its global tax team to the position of partner.
-
July 01, 2013
-
June 2013
June 25, 2013
David Cameron, UK Prime Minister, championed progress on the issues of tax and transparency by placing them at the top of his agenda for the UK’s chairmanship of the G8. But now the summit is over, and the Lough Erne Declaration has been released, the question is whether his efforts were successful whether the issues have simply been kicked into the long grass.
-
June 18, 2013
George Osborne, UK Chancellor of the Exchequer, said more progress has been made on countering tax secrecy and corporate tax evasion in the last 24 hours than in the previous 24 years. But conflicting messages could yet stall concrete agreements.
-
June 06, 2013
German state tax ministers are concerned about the country’s potential loss of competitive advantage because of new intellectual property tax incentives being offered by other EU member states such as the UK.
-
June 05, 2013
Germany is in the final stage of implementing the Alternative Investment Fund Managers Directive (AIFM-Directive), with implementation due by July 22 2013. But German real estate investment trusts (REITs) could be subject to new regulation, too.
-
May 2013
May 29, 2013
France and Germany have been among the strongest backers of the financial transaction tax (FTT), but opposition is rising in both countries.
-
May 29, 2013
The German Federal Central Tax Office has renewed its warnings to taxpayers of VAT fraud in the country’s energy market.
-
May 22, 2013
As EU leaders prepare to meet later today to discuss the financial transaction tax (FTT) and improving the efficiency of tax collection, progress must be made on agreeing the scope of the FTT. Even if a consensus emerges, the original timetable for implementation may be delayed to January 2015.
-
May 22, 2013
Jeffrey Owens, the OECD’s former head of tax, and Mick Moore, of the University of Sussex, believe their 10 point action plan for the G8 summit next month could achieve fairer taxation of multinationals, improve tax transparency and help developing countries build up their tax capacity.
-
May 20, 2013
International Tax Review has produced tax disputes reference guides for 26 countries. The guides look at how multinationals can avoid and manage tax disputes in each jurisdiction as well as offering insight about the future litigation strategies of individual tax authorities.
-
May 16, 2013
Germany’s intent to incorporate mandatory binding arbitration provisions in current and future double taxation agreements (DTA) should allow taxpayers to eliminate the risk of double taxation in cross-border cases and help them exert pressure on tax authorities to reduce the length of disputes.
-
May 16, 2013
Rosneft, the Russian energy company, was named as European in-house team of the year for direct tax at International Tax Review’s European Tax Awards last night.
-
May 03, 2013
-
April 2013
April 25, 2013
-
April 22, 2013
Pascal Saint-Amans, the head of tax at the OECD, has said the world is coming together over the issue of the automatic exchange of tax information.
-
April 16, 2013
After a joint statement from the finance ministers of France, Germany, Italy, Spain and the UK (the G5) that they will push for greater exchange of bank information, other countries have signalled their willingness to join the effort.
-
April 16, 2013
-
April 10, 2013
Foreign financial institutions (FFIs) now have a good indication of the information they will need to register for compliant status, under America’s Foreign Account Tax Compliance Act (FATCA), and the detail the Internal Revenue Service’s monthly list of compliant FFIs could include.
-
April 09, 2013
Olli Rehn, European Union Economic and Monetary Affairs Commissioner, has called for greater harmonisation in EU taxation policy.
-
April 08, 2013
In-house tax departments, both big and small, have extra chances at recognition at International Tax Review’s European Tax Awards 2013 presentation at the Dorchester hotel in London on May 15.
-
April 03, 2013
The German government has proposed a new law amending the VAT invoicing requirements for the supply of goods between EU member states in line with a decision of the European Court of Justice (ECJ). If approved, it may increase administrative costs for businesses.
-
April 03, 2013
The research has now started for the new edition of World Tax and the first edition of World Transfer Pricing, International Tax Review's directories of leading tax and transfer pricing firms around the world.
-
March 2013
March 27, 2013
-
March 26, 2013
-
March 26, 2013
-
March 26, 2013
Freshfields Bruckhaus Deringer is making up three new tax partners in its latest round of promotions.
-
March 25, 2013
The new group set up as a technical advisory body to the International Accounting Standards Board (IASB) will consist of members from 12 accounting standard-setters around the world, including the Financial Accounting Standards Board in the US.
-
March 20, 2013
The lack of certainty on the VAT status of bundled supplies is causing problems for taxpayers across Europe, according to advisers at Baker & McKenzie’s ITEM conference in London.
-
March 20, 2013
The OECD’s work on base erosion and profit shifting (BEPS) could impact how an establishment for VAT purposes is defined by governments, according to Baker & McKenzie’s head of VAT in the UK at the firm’s ITEM conference in London.
-
March 19, 2013
-
March 13, 2013
Special investment funds received some good news last week when the European Court of Justice (ECJ) decided they were exempt from paying VAT on third party advisory services.
-
February 2013
February 19, 2013
France, Germany and the UK have called on their G20 partners to implement global rules to combat corporate tax avoidance. The call follows the release of an OECD report into base erosion and profit shifting, which said existing international tax rules have gone unchanged for almost a century and have failed to keep pace with globalisation and the constantly evolving business environment.
-
February 12, 2013
Germany is on the verge of enacting a company tax Bill which would impact multinationals with investments in German tax consolidated groups (organschaft).
-
February 07, 2013
The European Court of Justice (ECJ) has ruled that the supply of services for a leased asset and the supply of the leasing services themselves must be regarded as distinct and independent supplies of services for VAT purposes in a case involving BGZ Leasing.
-
February 07, 2013
A Portuguese arbitration court (Tribunal Arbitral) denied the tax authority’s transfer pricing challenge of a multinational’s cash pooling arrangement because its use of the comparable uncontrolled price (CUP) method was inappropriate. The case should alert Portuguese taxpayers to review the arm’s-length nature of their cash pooling arrangements.
-
February 06, 2013
IRS information reporting councils; FATCA compliance; German investment fund taxation to align with AIFMD; Netherlands’ call for international action against tax avoidance; Australian carbon tax; UK VAT cut; Russian tax disputes; CRA on TEI audit targets
-
February 01, 2013
-
January 2013
January 30, 2013
The German federal government today introduced the draft Act Amending the German Investment Tax Act and Other Acts (GITA-AIFM) to adapt the German tax laws to the new regulatory regimes which implement the European Alternative Investment Fund Managers Directive (AIFMD) into German law, thereby commencing the legislative enactment process.
-
January 29, 2013
The Dutch parliament has been debating the country’s role in international taxation and its position within the global network that facilitates tax avoidance, concluding that the issue of tax avoidance must be dealt with at an international level.
-
January 24, 2013
The European Tax Awards are back in 2013, even bigger and better than before.
-
January 18, 2013
The US Treasury and IRS have published 544 pages of final regulations about how the controversial information reporting legislation should work.
-
January 16, 2013
Tax expert Michael Puls has joined the Dusseldorf office of Luther Rechtsanwaltsgesellschaft mbH – Taxand Germany.