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Susann van der Ham and Guido Schepers of PwC discuss the recently approved ordinance on the application of the arm’s-length principle to permanent establishments (PEs), addressing the impact of the introduced section 39 of the ordinance on the attribution of profits to dependent agent PEs in Germany to analyse whether the ordinance approval signals the start of an era of dependent agent PE discussions.

Hilmar Erb and Sebastian Lattmann of PwC explore new amendments to Germany’s self-disclosure rules, which have contributed to an increased compliance burden for taxpayers in 2015.

The former co-head of Bingham's tax group has found a new home.

Mutual agreement procedures (MAPs) and advance pricing agreements (APA) between India and the US hint at closer ties between the two nations and reinforce India’s desire to be seen as an investor friendly country.

The Indian government will not appeal the Bombay High Court (HC) ruling which concluded Vodafone was not accountable for a 3,200 crore ($525 million) tax demand.

The landscape of international taxation is changing. The OECD’s BEPS project is likely to rewrite the rules governing international taxation in a way that has not been seen since the League of Nations shaped existing rules in the 1920s. A key component of this is taxation of the financial sector. Various sector-specific tax laws have been proposed. This is providing those in the sector with plenty to think about. One such figure is Mariano Giralt, Managing Director, Tax Services, at BNY Mellon. He talks to Matthew Gilleard about some of the key tax developments impacting financial services.

Anastasia Sagianni For some multinationals operating in Serbia in 2013 it was not the first year of implementation of the transfer pricing rules. The law governing this area has been present in Serbia for more than a decade. More specifically, transfer pricing rules have been present since July 1 2001, but the Serbian Rulebook that was enacted on July 2013 gave clarity to the country's transfer pricing rules. Nonetheless, multinational companies operating in Serbia already had their transfer pricing policies in place due mainly to the fact that their headquarters were in countries with established transfer pricing rules. For the large majority of entities, 2014 was the first year of implementation regarding transactions that took place during 2013. For those entities the procedure was demanding both for their financial departments and their advisers.

With multilateral projects due for final delivery, and many of 2014’s key themes lingering on, 2015 comes with a lot of unfinished business.

Arantxa de Luis As is common knowledge, article 211 of Council Directive 2006/112/EC of November 28 2006 (VAT Directive) leaves it to the member states to lay down rules for payment in respect of the importation of goods and provides the option to establish that VAT on import need not be paid at the time of the import but rather in the periodic tax return. This election permits avoiding the financial effect derived for taxable persons from having to pay the import VAT and then recover it through deduction in the periodic VAT returns.

Andrés Edelstein