Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
Each year, the Internal Revenue Service of Chile (SII) updates its Tax Schemes Catalog. This guide contains a list of operations that may be declared elusive by applying the General Anti-Elusiveness Rule. The catalog's...more
The modification of the French administrative guidelines puts an end to an asymmetrical situation where the taxpayers had 2 years to claim incorrectly invoiced VAT and the French tax authorities had 3 years to reassess...more
Back in November 2023, the Amsterdam High Court ruled that the interest received by X BV (a notary firm) for funds in its trust account qualifies as VAT exempt turnover. According to the High Court, the interest received by X...more
En Conceptos 907362 del 26 de julio de 2021 y 90112 del 14 de febrero de 2022, la Dirección de Impuestos y Aduanas Nacionales (DIAN) de Colombia, había limitado el descuento en el impuesto sobre la renta del impuesto sobre...more
W 2022 r. na stronie Rządowego Centrum Legislacji opublikowano projekt Ustawy o zmianie ustawy — Kodeks spółek handlowych oraz niektórych innych ustaw (dalej: „Projekt”). Zakłada on dodanie do Kodeksu Spółek Handlowych...more
In 2022, a bill aimed at amending the Polish Commercial Companies Code and certain other Acts was published on the website of the Government Legislation Centre (hereinafter: the “Project”). The Project adds provisions to the...more
Key Takeaways - ..The Joint Chiefs of Global Tax Enforcement (J5) issued its first intelligence bulletin providing guidance to banks, law enforcement partners and private investigators regarding indicators of potential...more
The Spanish Tax Authorities ("STA") have issued the first ruling analysing the existence of a permanent establishment ("PE") in Spain due to an employee who worked from home during and after the COVID-19 lockdown. In this...more
A “Kafkaesque” bank customer service experience in France has led to a “Right to be Forgotten” own-goal. Following a decision handed down by the judicial tribunal of Grenoble, France, on 7 February 2022, a French bank has...more
Italian tax authorities address for the first time the VAT regime applicable to the assignment of NPLs. On the very last day of 2021 the Italian Revenue Agency issued a remarkable ruling (no. 79/E) on the VAT regime...more
On 1 July 2021, the “Act Amending the German Real Estate Transfer Tax Act” came into force. The legislative reform was previously the subject of public debate for several years and is still the subject of controversial...more
This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer...more
On 11 March 2021, the Luxembourg Tax Authorities published a Circular providing guidance on the process for initiating the mutual agreement procedure (“MAP”) under bilateral income tax treaties and explaining the interaction...more
Takeaways - While the Trade and Cooperation Agreement (TCA) includes new commitments by the parties on tax, certain EU-derived tax rules will remain relevant in the UK. - That is actually a good thing in one respect: UK...more
On 1 December, 2020, the Luxembourg tax authorities issued circular L.I.R 147/2, 166/2 and eval. n°63 on the application of EU Directive 2011/96 on the common system of taxation applicable in the case of parent companies and...more
Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more
La Dirección de Impuestos y Aduanas Nacionales (DIAN) el pasado 27 de noviembre de 2020 expidió la Resolución No. 106, por medio de la cual se establece la obligación de informar las ventas exentas de IVA en Colombia de que...more
Our International Tax Transparency Update will cover DAC6, the UK’s Trust Registration Service and other global registration requirements that may be relevant for businesses. The importance of these requirements cannot be...more
UK COVID-19 Developments - UK Prime Minister’s statement on COVID-19 - On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more
Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more
The Spanish Official Gazette published last October 16th legislation enacting a new indirect Tax on Certain Digital Services to be levied on On-line Advertising and Intermediation Services, as well as on Data Transfers...more
KEY POINTS - The UK Regulations, finalised on 13 January 2020, will only apply in relation to direct EU taxes. - The Legal Professional Privilege exemption is still unclear. - Penalties have been capped at £5,000. ...more
Key Points - Coming into force on 1 July 2020, EU DAC6 Regulations will require intermediaries in certain cross-border arrangements to disclose activity to tax authorities. - The DAC will apply retroactively to affected...more
OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more