In practice, it is hard to determine whether a repair of movable tangible property is deemed to be a supply of goods, including installation, or a supply of services. Thus the Federal Ministry of Finance implemented a value ratio for the differentiation in its circular dated December 12 2012. However, caution is advised when applying this regulation, argue Thomas Küffner and Ronny Langer of küffner maunz langer zugmaier. It appears to be rather simple but is not applicable in every case.
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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