Topic: Tax & Transfer Pricing

AGN EMEA Taxation Task Force (TTF) Newsletter

A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalization of the economy and global tax efficient structures set-up by large multinational enterprises (MNEs). The Global Anti-Base Erosion (GloBE) Rules are an important component of this plan and ensure large MNEs pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. This is also known as “Pillar 2” (hereinafter also shortly referred to as “P2”) and will be relevant for strategic tax structuring of MNEs.

A summary of tax facts of countries/territories in the Asia Pacific region

A collection of transfer pricing summaries of countries/territories in the Asia Pacific region

Inside this issue: Richard Ashby, Chairman of the AGN Asia Pacific Tax Committee provides a short message. Helen Wong & Pierre Gargatte at Acclime in China provides insight into the Hong Kong budget 2024-25. Erik Eneddy at DHK in Jakarta shares information on the new Indonesia payroll tax for employees, and Vimala Devi at BSL in Singapore recaps on the Singapore Budget 2024.

A summary of each article follows. Download the publication for a comprehensive read.

AGN EMEA Tax Committee News.

The requirement to create transfer pricing documentation impacts not just large corporations, but also small and medium-sized businesses (SME’s), who often lack awareness of this obligation. It’s crucial to address this issue promptly to prevent time constraints and potential penalties from tax authorities if documentation becomes necessary.

Read on for a summary of the obligations that exist in Germany and what you should be prepared for.

AGN EMEA Tax Committee News.

Following the publication of the Finance Act 2024 in France, the four main points you should know include:

1. Minimum taxation in France
2. Phasing out CVAE (Company Value Added Contribution)
3. Electronic invoice
4. Green tax credit

AGN EMEA Tax Committee News

Public Country-by-Country Reporting – To what extent do large companies contribute to public prosperity through their taxes? Public Country-by-Country Reporting (CbCR) is a regulatory requirement for corporations to disclose detailed financial and operational information on a country-by-country basis.

Inside this issue, Mandy Liu at AGN Member Firm Acclime in China provides insight into Individual Income Tax (IIT). Vimala Devi at AGN Member Firm BSL in Singapore provides insight into new legislations, effective as of 1 Jan 2024, relating to the gains from the sale or disposal of a foreign asset.

A summary of each article follows. Download the publication for a comprehensive read.

From AGN EMEA Tax Committee members and AGN tax correspondents

Permanent Establishment and Fixed Business Facility for Service Providers in Germany: A foreign company operating in Germany must be assessed from a tax perspective to decide whether the establishment is a ‘permanent establishment’ or not. The existence of a permanent establishment has various consequences, especially Germany’s right to tax the income attributable to the permanent establishment in Germany.

AGN EMEA Tax Committee News.

EU Directive 2018/822 (known as ‘DAC 6’) amended and significantly expanded the existing Directive on administrative cooperation in the field of taxation (2011/16) by introducing a reporting regime for professional advisers where they are involved in tax planning which meets certain hallmarks.