International Taxation
The realm of international taxation is our favourite discipline. We can resolve cross-border tax problems for you.
Equalisation tax, Czech implementation of the EU Directive
Further to our last article of May 2023, we would like to inform you about further developments in the area of Pillar 2, i.e. the implementation of Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation…
“Abuse of the law” coming up again – this time cross-border
Do you carry out cross-border transactions/structures?
Do you have sufficiently documented and supported reasons for performing them?
Does the subsequent operation of the group after the transactions/structures in question correspond to the…
New EU “FASTER” withholding tax rules draft has been published
Many Member States currently levy a withholding tax on dividends on shareholdings and interest on bond holdings paid to investors living abroad in the case of cross-border investments. However, investors must also pay income tax on the same income…
Groups of companies with consolidated revenues of more than EUR 750 million must prepare for a global minimum tax from the year 2024 already
As of 1 January 2024, an EU directive will come into force, under which the income of multinational and domestic groups in the EU with a consolidated turnover of a minimum of EUR 750 million will be subject to a 15% corporate income tax rate. From 1…
Overview and implications of the decision of the European Court of Justice (ECJ) of 27th April 2023 in case C-537/20
Proceedings I R 1/20 and I R 2/20, among others, are currently pending before the Federal Fiscal Court on the conformity of Sect. 11 of the German Investment Tax Act (GITA) 2004 with European law. The question is whether there is unequal treatment…
Measures to help the UK economy
Against a backdrop of high inflation and low growth, the first UK Budget for 18 months sees the Chancellor of the Exchequer, Jeremy Hunt, setting out the UK Government’s vision for delivering on three of the five key priorities announced by the…
Shell entities – changes in the draft of the new EU directive
At the beginning of 2022, we informed you about a new EU proposal for a Directive laying down rules to prevent the abuse of shell entities for tax purposes and amending Directive 2011/16/EU (the “Directive”) – the article can be found HERE.
The…
Do not forget to report exempt payments abroad for 2022 to the tax office by the end of January
By 31 January 2023 it is necessary to notify the tax administrator of all income for the year 2022 paid to tax non-residents that is normally subject to Czech withholding tax, but is for some reason exempt from tax or that an international treaty…
