Author: Ewa Suwińska – Licensed Tax Advisor INDEPENDENT TAX ADVISERS Warsaw, Poland E: [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

Polish Judgement of the Voivodship Administrative Court Dated  11 June 2024

The Polish Voivodship Administrative Court (in Gliwice), in its judgment of 11 June 2024, (ref. no. I SA/Gl 914/23), addressed the issue of creation of a permanent establishment [PE] when employing staff in a home office.

The case concerned whether a German company (Company) had or did not have its Poland registered office and management at the home office of its employees in Poland. The Company has employment contracts with two Polish tax residents. They were employed as a customer a support engineer and a product manager.… Read More

Author: Rakesh Ghirah LLM, Associate Partner VAT | Indirect Tax| Londen & Van Holland Amsterdam, Netherlands [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

Based on the Value Added Tax [VAT] Directive the VAT Law in the European Union is harmonized. In principle a 0% VAT rate applies to Business to Business [B2B] transactions where goods are supplied from one Member State to another. However, this 0% VAT rate can be exploited for carousel fraud, contributing significantly to the VAT Gap in Europe, which was estimated to be around €61 billion in 2021. The VAT Gap is the estimated overall difference between the expected theoretical VAT revenue and the amount actually collected.… Read More

Author: Christopher Klug BA, JD, LLM Basswood Counsel PLLC (formerly Klug Counsel PLLC) [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

When there is a cross-border merger and acquisition there are additional complexities to plan for, typical acquisition planning in one country may be different than in another country, and the resulting tax implications can be significant.  Basswood have represented both the acquiror and target in a number of cross-border acquisitions and getting the right result requires a careful analysis of the tax implications involved.  What may seem like a very small detail may have very serious tax implications that greatly impacts the result of the acquisition for either the acquiror or target.… Read More

Author: Gopu Rama Naidu FCA, FCCA, CPA under and Managing Partner KGRN Chartered Accountants LLC [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

Embracing the Corporate Tax Landscape in the UAE: Opportunities for Global Business Growth

The United Arab Emirates has recently ushered in a new era of fiscal policy with the implementation of Corporate Tax, effective from the tax periods commencing on or after June 1, 2023. This move is aimed at bolstering the nation’s economic diversification and aligning its tax practices with global standards. For international businesses considering a foothold or expansion in the Middle East, the UAE’s Corporate Tax framework offers compelling incentives and a strategic advantage.… Read More

Author: George Giannopoulos Partner [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

Law 5104/2024 (Tax Procedure Code) was published on April  20th 2024 being effective immediately.

The new Law indicates change in accounting – tax procedures and bring new procedures as well.

 

Efficiency measures

The main efficiency provisions of the Law 5104/2024 to update the Greece tax system include the following:

Pre-filled tax returns: obligation to prepare tax returns is abolished for taxpayers, who have income exclusively from wages and pensions. The tax return is automatically pre-filled by the IAPR (Independent Authority for Public Revenue) and is also automatically finalized if the taxpayer does not raise objections within the deadline for submitting the tax returns.… Read More

Originally Published in Spanish, Please look at the bottom of the article for the Spanish Version. Publicado originalmente en español, consulte la parte inferior del artículo para ver la versión en español.

 

Author: Lic. Salvador Pizano Moreno Gerente/ Manager [email protected]

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

Transfer pricing, an important and controllable aspect of international taxation, refers to the prices at which companies within an international corporate group transfer goods, services, or intangible assets between each other. The forward at paragraph 11 of the OECD Transfer Pricing Guides. Says

“These are the prices at which a company transfers tangible goods and intangible assets or provides services to associated companies.”… Read More

Author: By Dr. Filip Schade, Steuerberater, Master of Laws Wagemann + Partner PartG mbB, Berlin, E: [email protected]

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

In this article, I will give you a brief overview of the current economic situation in Germany and the reasons for this development. Following this, I will explain existing and planned tax incentives and subsidies and critically assess them. At the end of the article I will make four proposals for a more far-reaching reform of German tax law in order to make Germany attractive again as a business location for entrepreneurs and investors.

1. Current economic situation in Germany

First, I would like to say a few words about the current economic situation in Germany.… Read More

Author: Nicholas Raycroft, CPA Senior Manager, Tax Hendry Warren LLP | Chartered Professional Accountants E: [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

 

On June 9, 2022, the Canadian Government enacted the “UHT Act”. This tax is intended to discourage ownership of vacant or underused Canadian real estate.  We had previously provided an overview of the new UHT in our publication on February 23, 2023 https://www.integra-international.net/underused-housing-tax-uht-canada/.

Since February 23, 2023, the Canadian Government has released additional guidance and amended UHT Act legislation. We thought it would be helpful to provide an update on some of these changes. Note that these updates are based on the amended UHT Act legislation as drafted.… Read More

Author: Paul Ferreira, CPA President of Export Tax Management E: [email protected]

 

Edited by: Grant Gilmour, B.SC., MBA, CPA BC, CA, CPA AZ Integra Tax World Newsletter Editor E:  [email protected]

 

The IC-DISC is the most effective tax planning strategy for your clients who deliver their products for use outside of the United States. In 2017, the U.S. Congress enacted the Tax Cuts and Jobs Act of 2017. This landmark legislation provides permanence for the IC-DISC in 2018 and beyond. Many privately held companies that have products delivered to customers outside of the United States, including Canada and Mexico, are significantly reducing their US federal income taxes related to their export sales. The growing demand for U.S. products in emerging foreign markets has driven the demand for U.S.… Read More

Author: Mr. M.A. (Maxim) Boschman LL.M

Senior Manager Tax, specialized in (international) payroll taxes at Londen & Van Holland

The Dutch economy is mainly driven by human recourses (HR), knowledge and innovation. In order to attract foreign employees who bring specific knowledge to the table, the Dutch tax rules provide a favorable tax regime. This regime is called ‘the 30%-ruling’ and is applicable if certain conditions are met.

Dutch wage tax system and the 30%-ruling

In principle, everything (in money or in kind) reimbursed, given or provided to employees in that capacity is considered wage, subject to Dutch wage tax and social security contributions. Fortunately, there are certain exceptions, exemptions and benefits that could be enjoyed tax-free otherwise (e.g. have a nil-value for wage tax purposes).… Read More