After more than two decades of discussions, the National Congress approved, and the President of the Republic enacted the final text of the Constitutional Amendment n. 132/2023, known as the Brazilian Tax Reform on...more
The government has just issued an amendment n°5374 to the draft Finance Bill for 2024 aimed at clarifying the VAT regime applicable to the para-hotel and serviced residences sector, following the Administrative Supreme Court...more
Zgodnie z projektem Rozporządzenia Ministra Zdrowia opublikowanym 2 maja na stronach Rządowego Centrum Legislacji, 1 lipca 2023 r. stan zagrożenia epidemiologicznego ma zostać odwołany. Projekt skierowano do uzgodnień i...more
According to the draft Decree of the Minister of Health published on 2 May on the Government Legislation Centre’s website, the state of epidemic emergency is scheduled to be terminated on 1 July 2023. The draft has been sent...more
Whilst the default position is that supplies of land and buildings are usually exempt from VAT (the sale of new commercial buildings excepted), landowners of commercial property will often choose to opt to tax their property...more
Tulum, Cabo, Cancun, and Playa del Carmen are not only wonderful vacation destinations in Mexico, they are also very attractive destinations for American investors. Clients interested in acquiring real estate in Mexico, often...more
Due to the anonymity of non-fungible tokens’ (“NFTs”) transactions, sellers face practical difficulties in determining whether or not they should charge Spanish Value Added Tax (“VAT”) to the buyers on sales through online...more
As part of the Edinburgh Reforms announced by the UK Government (link back to “UK FS Reforms”), the UK Government has launched a public consultation on the VAT treatment of fund management. The consultation, published on 9...more
Approximately 30% of the global market is related to intellectual property. While intangible goods cannot be touched or seen, they are all too real. For companies around the world, one of the most important intangible assets...more
The Spanish Tax Authorities (“STA”) have issued the first ruling analysing the Value Added Tax (“VAT”) treatment of the sale of non-fungible tokens (“NFTs”) that grant the buyer a right to use an underlying digital artwork....more
Welcome to February’s edition of our UK Tax Round Up. This month’s edition includes updated guidance on the VAT treatment of contractual termination payments, updated HMRC guidance on the assessment of “substantial”...more
HM Revenue and Customs (HMRC) now considers that charges made by businesses to their customers to withdraw early from agreements to supply goods or services are payments for a supply and potentially subject to value added-tax...more
In this roundup, we look at some of the key cases in corporate and real estate tax from December 2021 to January 2022, including the value–added tax (VAT) decisions on input VAT that was not passed on to final consumers and...more
Taxpayers can now withdraw from the VAT exemption for financial and fund management services, as well as services concerning foreign currency exchange, coins and banknotes....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
In Claims Advisory Group v HMRC, The Upper Tribunal (UT) has confirmed that the service of claiming compensation on behalf of third parties for mis-sold payment protection insurance (PPI), is subject to VAT and not exempt...more
UK General Tax Developments - Stamp Duty and COVID-19 - Since the start of the first UK lockdown in March 2020, HMRC has been accepting that documents can be stamped electronically. HMRC has now confirmed that, where...more
The UK government is pressing ahead with its proposal to require large businesses to notify their “uncertain tax positions” to HMRC. ...more
UK Case Law Developments - Tax avoidance motive did not prevent availability of share for share exchange treatment - In Euromoney Institutional Investor plc v HMRC, the FTT held that the share for share exchange...more
Spring Budget and Tax Day - After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more
UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more
The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more
UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more
UK COVID-19 Developments - Extension of support for employed and self-employed workers - On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more