NEWS
Comparative table on tax regime holding companies
Law & Numbers presents a comparative study on tax regime holding companies. To see the full study, click on the picture : Contributors : Switzerland : Yves Auberson - Felten Assa & Associés France : Céline Boisselier - TGS Avocats United States (USA) : Gregory M. McKenzie - FischerBroyles LLP Hungary : Pal Jalsovszky - Jalsovszky Law Firm [...]
Tax alert : taxation of cryptocurrencies in Portugal
Please find below a tax alert on the portugal taxation of cryptocurrencies presented by João Valadas Coriel, Managing Partner of Valadas Coriel & Associados (VCA), our member firm in Portugal. https://www.youtube.com/watch?v=wtF-3Jz8ylw
Portugal : Prime Minister announces intention to end NHR tax programme (Non-Habitual Resident)
Prime Minister António Costa announced on Monday that the state intends to end the Non-Habitual Residents Programme (NHR) in 2024 and will no longer accept taxpayer registrations from next year. However, the Prime Minister wasn’t clear on whether he intended to put an end to the whole scheme and how the new guidelines would be applied, and he [...]
Suspension of numerous dispositions of Tax Treaties by Russia
As you may know, on 8/8/2023 the Russian President has issued a decree on 'the suspension by the Russian Federation of specific provisions of the international tax treaties of the Russian Federation'. The decree suspends various provisions of Tax treaties with 38 "unfriendly foreign states". Are suspended art. 5 (definition of PE), art. 6 to 22 (allocation of [...]
How to compute taxable income of Reverse Hybrid Entities in Luxembourg ?
The Luxembourg Tax Authority (“L.T.A.”) has released on the 9th of June2023 a circular LIR N°168 quarter/1 providing guidance on the computation of taxable income of Reverse Hybrid Entities. A new form to be filed electronically for transparent entities together with Frequently Asked Questions guidance on how to fill in such form are now also available on the website [...]
Teleworking and permanent establishment (PE) risk
The question I would like to address is linked to the new work practices after the Corona crisis. I mean the new tendency in many companies of allowing staff or certain staff members to telework. This new tendency does not raise any problem from taxation point of view if the telework takes place within the same jurisdiction. But [...]
Taxation of a secondary residence in France held by a Belgian tax resident (in French)
Presented by Marylène Bonny-Grandil, Lawyer at Paris Bar and André Bailleux, Lawyer at Brussels Bar Introduction by Axelle Keles, Lawyer at Paris Bar and Coordinator of Law & Numbers
Creation of a subsidiary in Hungary by a German investor
Presented by Pal Jalsovszky Jalsovszky, Lawyer at Budapest Bar and Christoph Möslein, Lawyer at Munich Bar Introduction by Axelle Keles, Lawyer at Paris Bar and Coordinator of Law & Numbers
The impatriate tax regime in Luxembourg and Portugal
Presented by Sofia Quental, Lawyer at Lisbon Bar and Bernard Felten, Lawyer at Luxembourg Bar and Geneva Bar Introduction by Axelle Keles, Lawyer at Paris Bar and Coordinator of Law & Numbers
Luxembourg Tax Update – 2023 Budget Law
Technical change Legalization of the current administrative practice in terms of deadline for filing tax returns. The 2023 budget law has extended the filing deadline for corporate income tax, municipal business tax, net wealth tax and personal income tax returns from 31 March to 31 December. VAT rates amendments Effective as from 1 January 2023 VAT Cut by [...]
Law & Numbers is welcoming a new member: Portugal (represented by João Valadas Coriel of Valadas Coriel & Associados)
We are pleased to welcome João Valadas Coriel to our international network of tax lawyers as a new Portuguese member of our network. Who is João Valadas Coriel ? João Valadas Coriel is an Attorney at law specialised in tax law, registered with the Lisbon Bar. He works in Portuguese, English, French, Spanish and Italian. His practice areas [...]
DAC 6 Directive and local implementation in European Union (EU)
DAC 6 is an EU Directive that introduces Mandatory Disclosure Obligations for a wide range of cross-border tax arrangements. EU Countries have aligned their national laws quite closely to the DAC6 Directive but some countries went beyond the content of such Directive adding extra requirements. Addressing these differences is the purpose of this COUNTRY PER COUNTRY review. Click [...]
Tax regime holding companies (as at January 1st, 2021)
To consult the table, please click here : Law & Numbers - table on tax regime of holding companies
Tax News Hungary : SUPREME COURT: VAT ON BAD DEBTS IS TO BE REFUNDED
In its verdicts in the Di Mauro and the Porr cases, the ECJ has given a green light to the reclaim of VAT on bad debts. Notwithstanding, Hungarian taxpayers still had to launch domestic procedures to enforce their rights to reclaim. The Hungarian Supreme Court has recently announced its first decisions in such cases, for the benefit of [...]
Tax News Hungary : NAV TO HAVE ACCESS TO DUBAI-BASED SHELL COMPANIES’ DATA
Based on a new OECD standard, tax authorities will be better placed to monitor the activities of companies registered in tax havens and to access their key financial data. Although it remains to be seen how the Hungarian tax authority will use this information, several popular tax minimisation strategies may be affected. To read the full article, click [...]
Interview with Mr. Bernard Felten of Felten & Associés (Luxembourg)
Bernard Felten Luxembourg member of the network Felten & Associés Network coordinator : Hello Bernard You represent Luxembourg in our Law & Numbers network of tax lawyers. We would like to get to know you a little better. If you agree, we will ask you some questions. Bernard Felten : My pleasure ! Network coordinator : [...]
Interview with Mr. Ambrogio Novelli from «Studio Legale Novelli» (Italy)
Ambrogio Novelli Italian member of the network Studio Legale Novelli Network coordinator: Hello Mr. Novelli, You represent Italy in our Law & Numbers network of tax lawyers. We would like to get to know you a little better. If you agree, we will ask you some questions. Ambrogio Novelli : Yes, with great pleasure. Network [...]
Interview with Pál Jalsovszky from Jalsovszky Law Firm, Budapest (Hungary)
Pál Jalsovszky Hungarian Member of the network Jalsovszky Law Firm Network coordinator : Hello Pál, You represent Hungary in our Law & Numbers network of tax lawyers. We would like to get to know you a little better. If you agree, we will ask you some questions. Network coordinator : What was your background that led you [...]