CERHA HEMPEL’s Post

🔒 Could a simple locker create a taxable presence? 🏡 Could a “home office” be the effective place of management?   These and other related questions underscore the intricate and often surprising complexity of international tax obligations that our 'Managing Permanent Establishment and Tax Residence Risk' webinar touched upon. Our expert speakers Caroline Borgers, Daniele Buchler, Cyril Boussion, Roberto Egori, Benjamin Twardosz, and moderator Dr. Christian Hundeshagen delved into these areas of international taxation, illustrating the tax implications that can arise in cross-border operations. Key insights from the webinar: ⚪ Determining the effective place of management: The place of strategic as well as day-to-day management decisions – including the preparation of such decisions – can significantly affect tax liabilities across jurisdictions. ⚪ Evolving understanding of permanent establishment: The focus is now on undisclosed or hidden permanent establishments from which sales support services to foreign group entities have been provided. ⚪ Measures to mitigate tax risks and exposures: Strategies like a review of set-up/local footprint and transfer pricing, as well as voluntary disclosure procedures were discussed. This webinar served as a testament to Linklaters’ commitment to ensuring we remain at the top regarding tax law. A big thank you to everyone who attended and contributed. Stay connected for more thought-provoking discussions on cross-border tax strategies and complexities! Feel free to reach out to one of the speakers in case you missed the webinar – we are happy to provide you with further insights. #Linklaters #Webinar #TaxLaw #Compliance

[WEBINAR] Scopri i principali insights dal webinar "Managing Permanent Establishment and Tax Residence Risk", insieme a Roberto Egori, Partner Tax di Linklaters Italy 👇

🔔 Approval of the Pillar Two law by the Luxembourg Parliament 📝 On 20 December 2023, draft law no. 8292, transposing the EU Council Directive 2022/2523 of 14 December 2022 (“Pillar Two Directive”) into Luxembourg national law, was adopted by the Luxembourg Parliament. 🔎 The Law aims to ensure that multinational enterprise groups and significant large domestic groups pay a minimum level of tax of 15%. It incorporates amendments proposed by the Luxembourg Government in November 2023 in order to be aligned with administrative guidance issued by the OECD. 👉 Read more: https://lnkd.in/eDNJdi2G 🧐 Should you require any assistance in assessing the impact of the Law on your organisation, do not hesitate to reach out to our experts ➡️ Jean-Nicolas Bourtembourg, Partner, Head of Tax & Transfer Pricing or Alain Verbeken, Director, Tax - Financial Services. #Tax #PillarTwoLaw #Luxembourg #GrantThornton

Australia has released its long-awaited revised proposals on public country-by-country reporting for consultation. There is now greater alignment with other global tax transparency standards, but still a bit that groups will need to work through to prepare ahead of reporting deadlines. See KPMG's detailed article on the changes here: https://lnkd.in/dSPavqWj Jenny W. Tim Keeling Phil Beswick #taxtransparency

Look What PwC Made the Australian Government Have to Do: The Australian government released exposure draft legislation yesterday in response to “the PwC matter” and the funniest part is the special email they made to receive comments: [email protected]. Not ConsultingReponse or Sept23TaxReform, specifically PwCResponse. In four separate exposure drafts that amend the Taxation Administration Act 1953 (TAA) and/or the Tax Agent Services Act 2009 (TASA), […] The post Look What PwC Made the Australian Government Have to Do appeared first on Going Concern. https://bit.ly/3t3RpDG

𝐁𝐄𝐏𝐒 𝐏𝐢𝐥𝐥𝐚𝐫 2 𝐢𝐧 𝐒𝐨𝐮𝐭𝐡𝐞𝐚𝐬𝐭 𝐀𝐬𝐢𝐚: 𝐔𝐧𝐝𝐞𝐫𝐬𝐭𝐚𝐧𝐝𝐢𝐧𝐠 𝐢𝐭𝐬 𝐈𝐦𝐩𝐚𝐜𝐭 𝐚𝐧𝐝 𝐀𝐝𝐨𝐩𝐭𝐢𝐨𝐧 𝐛𝐲 𝐓𝐚𝐱 𝐀𝐮𝐭𝐡𝐨𝐫𝐢𝐭𝐢𝐞𝐬 Join us tomorrow for a webinar with Wolters Kluwer to discuss the adoption and implementation of the OCED Pillar 2 Model rules by tax authorities in Southeast Asia. During the webinar, we will be discussing: The key elements of Pillar 2; The adoption of Pillar 2 across Southeast Asia; and How to be prepared for the implementation of Pillar 2 https://lnkd.in/gJZ-eJGE

Last but not least, here is the third and final article of our Deloitte - OECD interview series on #itr! Thanks for reading and stay tuned for our next article in #itr on Financial Services Transfer Pricing. We will then examine the latest trends in the banking sector and the transfer pricing dimension of funding arrangements. Stay tuned! #deloitte, #deloittetax, #tax, #transferpricing, #oecdtax, #itr

The implementation of Pillar Two, the global minimum tax, in some jurisdictions from the beginning of this year (among others, the Netherlands), marks a paradigm shift in the framework of international taxation. In this briefing, BDO sets out ten of the most significant practical challenges that we meet during our daily conversations with our clients, more specifically for private equity. #tax #privateequity #bdo Tom Bijkerk Koos van der Kemp

Pillar 2: Tax Alert Series (1 of 4: Scope of the rules)  Stay tuned for next episodes Deloitte #internationaltax #alternativeinvestments #luxembourg

EY Midweek tax news: - Court of Appeal considers meaning of ‘arrangements’ for the purposes of anti-avoidance rules on exchange of shares - King’s Speech on the State Opening of Parliament - HMRC publishes new Guidelines for Compliance document: work qualifying as R&D for tax purposes - Cyprus confirms agreement with Pillar Two safe harbours to allow EU Directive to proceed - OECD and country officials discuss BEPS 2.0 Pillars One and Two and other OECD tax work - How workforce mobility can navigate AI and global legislative changes: webcast 15 November - Trade Talking Points – 2 November 2023 - The EU's Carbon Border Adjustment Mechanism: the practical implications