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    Monday 27 May 2019
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    Article May 2019

    The Double Taxation Treaty (DTT) arm's length principle has no blocking effect where a group loan is unsecured

     

    In a departure from its previous case law, the German Federal Tax Court ruled in its judgment on 27 February 2019 (Case No. I R 73/16) that Art. 9 (1) of The Organisation for Economic Co-operation and Development (OECD) Model Convention (or Art. 9 of the DTT with Belgium in the case being litigated) does not prohibit an income adjustment pursuant to section 1 (1) of the Foreign Tax Act (AStG) where an unsecured loan group is written off. 

    Article May 2019

    VAT obligations of limited taxpayer electronic service providers

     

    With the Law No. 7061 published in 2017, an important step was taken in the Value Added Tax Law regarding the taxation of electronic commerce. From 1 January 2018, services provided in an electronic environment by natural or legal entities who do not have a residence, workplace, legal centre and business center in Turkey were subject to VAT to natural entities who do not have VAT liability in Turkey. 

    Article May 2019

    Standardized transfer pricing documentation regulation?

     

    The three-tiered documentation structure consisting of the master file, local file and the Country-by-Country Reporting (CbCR) have been implemented in Hungary as of 2018.

    Article May 2019

    The managing director of a company as a permanent representative from a German perspective

     

    The question of whether a managing director, as an officer of a company, may be a permanent representative under S13 of the German Tax Code (abgabenordnung), so that a share of the profits may be taxable in the state in which the company is operating, has been controversially disputed.

    Article April 2019

    National approaches of different aspects and practice relating to Shareholder Agreements

     

    Transfer restrictions: shares do not necessarily belong in a shareholders’ agreement. Enforceability of shareholder arrangements in The Netherlands. Shareholders’ agreements - Validity, effectiveness and enforceability in Spain.

    Article April 2019

    New law and effects at national and international level

     

    The impact of General Data Protection Regulation (GDPR), on the European employment regulations. First experiences with GDPR in Germany. The Pacte Law: Reinforcement control of foreign investments in France.

    Article April 2019

    Global entrepreneurs survey

     

    Saffery Champness' 2018 survey of entrepreneurs was extended to include responses received by colleagues in firms from Nexia global network, Nexia International, providing data from 22 countries around the world and allowing Saffery to see how the UK business environment and the attitude of UK entrepreneurs differs from the rest of the world. 

    Article March 2019

    Switzerland: Withholding tax - relaxation on refunds

     

    The Finance (Miscellaneous Provisions) Act 2018 was promulgated on 9 August 2018 which contained the tax measures as announced in the budget speech delivered on 14 June 2018.

    Article February 2019

    U.S.: Section 163(j) interest limitation rules

     

    A business operating as a corporation, pass through entity, or sole proprietorship is generally allowed a deduction for interest expense paid or accrued in calculating its federal taxable income under Section 163 of the Internal Revenue Code.

    Article February 2019

    Tax efficient remittances to the UK

     

    Ordinarily, taxpayers who are resident in the UK pay tax on their worldwide income and gains, wherever they arise. However, taxpayers who are resident but not domiciled (“non-doms”) in the UK can instead elect, subject to certain conditions, to be taxed on the remittance basis of taxation.

    Article February 2019

    Making tax digital – New UK VAT compliance requirements to be introduced from April 2019

     

    Making Tax Digital (MTD) is HM Revenue & Customs’ (HMRC’s) strategy to modernise the UK tax system. As well as improving HMRC’s own internal systems, MTD involves mandatory digital record keeping and reporting by taxpayers.

    Article February 2019

    First sale of residence or business offices in Turkey to foreigners is without VAT!

     

    In recent years, in the face of recession in the construction sector which is the main force of economic growth in Turkey's economy, a number of changes have been made to government's applied fiscal policy in order to increase the demand for the industry.

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