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In the case C-812/19 Danske Bank A/S v Skatteverket (Danske), the Court of Justice of the European Union (CJEU) has held that the Danish VAT group head office is a separate taxable person to its Swedish branch for VAT purposes. The Court also commented on the territoriality of VAT groups which may affect EU Member States with a “whole legal entity” VAT grouping approach.
The COVID-19 mutual agreement between Switzerland and France for cross-border commuters has been extended
On 10th March 2021, the French and Swiss governments announced that the terms of this agreement have been further extended until 30th June.
In May 2020 the French and Swiss governments issued details of a provisional mutual agreement concerning cross-border workers who would otherwise have lost their cross-border tax status due to government-imposed travel restrictions. Both countries agreed to apply the same tax treatment to cross-border workers as if they had physically crossed the border to go to their usual place of work.
Real estate transactions in Switzerland by UK nationals are subject to new conditions which are in force as of 1st March 2021 with retroactive effect from 1st January 2021. Knowledge of the legal protection of the acquired rights and particularities of the applicable framework are crucial to plan residential real estate investments.
Switzerland, located geographically in the heart of Europe is associated with mountain peaks rather than a global maritime reach. However the country has one of the largest maritime merchant fleets in the world (11th in size globally, close behind the UK).
To strengthen the attraction of Switzerland to companies that operate and manage maritime activities, the Swiss Federal Government recently issued a consultation draft with regard to the introduction of a ‘tonnage tax concept’. The proposed (simplified) law is that the taxable ‘profit’ of eligible companies would be based on cargo volume (‘net tonnage’) rather than operating profits or volume of cargoes carried. The tax would be optional, and companies could choose instead to be taxed by current methods.
Managing global transfer pricing documentation - Get to know Deloitte's new technology solution "TP Digital DoX" on 23 March at 3.00PM CET
Join our upcoming webinar on 23 March 2021 at 3.00pm CET to discuss the operational management of a global transfer pricing documentation and introduce Deloitte's new technology solution "TP Digital DoX".
The next generation of our transfer pricing documentation technology is here!
Evolving implications from the OECD’s Action 13 guidance are forcing businesses to find more efficient, integrated means to manage TP documentation processes. Most complex businesses are considering adopting a centralised TP documentation approach and are examining their TP on a unified, global/regional basis. Meanwhile, tax audit activity is on the rise as authorities seek to expand their tax bases.
The ever-evolving role of an Automatic Exchange of Information (AEOI) responsible person - Join our live training on 3 March at 16.00 CET
Both US FATCA and the OECD’s Common Reporting Standard (CRS) require Financial Institutions (FIs) to put in place processes, procedures and overall governance to enable accurate reporting of information about the FI’s account holders and/or controlling persons thereof, to certain tax authorities. These rules, which are commonly referred to as the Automatic Exchange of Information (AEOI), have become business as usual over the past six years. However, these rules are practically complex to implement and maintain, and can expose FIs to significant risks. Key challenges include manual processes, local expertise requirements, systems interfacing, documentation and data deficiencies, and requirements that are often unclear and continuously change. Jurisdictions around the globe are starting to take audit action.
New disruptive and constantly evolving technology is rapidly transforming businesses. Companies are investing in big data, automation, and artificial intelligence solutions to enhance their business capabilities. The 2020 pandemic has also forced companies to accelerate the existing digitalisation plans to have data and processes continuously available and operable in a secure manner to ensure continuity of the business.
A ‘future ready’ tax function needs tax data management and analytics resources at its fingertips to support the business. S/4HANA provides both, the key is understanding how to use it to ensure your data is right first time and aligned to your business needs, whilst improving your control environment to fulfil tax compliance - without huge manual effort. How can your organisation improve it’s data organisation?
New test and quarantine reduction strategy: requirement for a negative PCR test as of 8 February 2021
On 27 January 2021 the Federal Council took a range of decisions to further contain and overcome the coronavirus pandemic. As of 8 February 2021, a new test and quarantine reduction strategy will be in place and traveller contact data will be collected more comprehensively.
The Swiss Federal Tax Administration (SFTA) has reacted to the Federal Court decision dated 21 February 2020 ruling out that there is a (partial) VAT succession for Asset Deals, and published its intended practice in a first draft.
The outlined practice implies a very strict and lean interpretation of the Federal Court Case. According to this practice, a VAT succession in case of a transfer of a partial business only applies if said transfer takes place between closely related parties. Further details around the implementation of the practice, such as whether the SFTA intends to audit the VAT belongings of a transferred partial business at the transferee and based on what documentation, were not mentioned. This is to be figured out based on the general rules applicable.
U.S. Expatriation – would you be considered a “covered expatriate” and subject to the punitive exit tax?
The U.S. imposes tax on worldwide income without taking into consideration where its citizens or Greencard holders (GCH) reside. Recent data indicates that many dual citizens and GCHs living outside the US are expatriating in significant numbers to alleviate themselves of their annual U.S. tax burden. The U.S. Federal Register showed that 5,816 renunciations were recorded in the first six months of 2020, a significant increase from 2019. Given the current high level of uncertainty and far-reaching consequences of COVID-19 on world economies, now could be the ideal time to expatriate in considering if your net worth exceeds the $2 million threshold. The main question for most contemplating expatriation is what are the tax consequences?