News

99
December 12, 2020

With all due respect to the BBC, the imposition of such a “one-time” wealth tax would have a disastrous impact on the British economy. Capital flight would occur, much like what is happening already in Argentina (which brought in such a measure last week). Given the now noticeable shift in public discourse in favour of greater burdens being placed on successful business people, those with means should start thinking about reorganising their affairs. Second citizenship and permanent residency verticals are…

December 7, 2020

Like other major economies in 2020, the UK is facing a tax deficiency in light of covid-19 and the severe contraction of its economy. Governments are now looking to new tax revenue schemes and everything is on the table. The Portuguese Golden Visa Program tied to a fund investment is one such possibility, as it provides a functional result coupled with a financial product designed to create liquidity and ease of exit. Read More.

November 10, 2020

A very nice development in Portugal this week. Birthright citizenship will be henceforth allowed for those that are born in Portugal to parents that have been permanent residency for at least one year. Coupled with the country’s Golden Visa Program, this will push Portugal to the top of the list in terms of permanent residency and citizenship programs (through the backdoor). An outstanding piece is found at IMI Daily.

November 8, 2019

Austria’s Ministry of Finance has recently provided some guidance on the question of an Austrian home office as it applies to an Austrian tax resident employee and whether such a setup can qualify as an Austrian permanent establishment for a non-Austrian enterprise. A permanent establishment for Austrian domestic tax purposes is a fixed place through which an enterprise’s business is carried out. Such an establishment can be an employee’s private flat, provided that employee renders his/her work at least partly…

October 15, 2019

The Austrian tax court has recently opined on the question of dividend payments from Austria to an intermediate EU holding company which has no substance (while its EU parent does). Generally in Austria dividends paid out by Austrian corporations trigger a 27.5% withholding tax. Nevertheless, pursuant to the EU Parent/Subsidiary Directive applied in Austria, outbound dividends are totally exempt from withholding tax if the parent company fulfils the criteria as set out in the Directive and holds at least 10%…

December 15, 2018

In early November, the Austrian Data Protection Authority issued a directive that data processing operations in all cases requires a data protection impact assessment (DPIA). Under Europe’s new General Data Protection Regulation (GDPR), DPIA is required during data collection. The Austrian rule changes are bringing effect to GDPR into the national regime. Please note that failure to carry out a DPIA can result in fines up to EUR 10m or 2% of worldwide annual turnover. DPIA Examples Some examples include:…

September 19, 2018

Recently in August, Germany moved forward with a proposal directed against VAT avoidance relating to supplies of goods with a German nexus over online marketplaces. The bills expected to pass parliament in late fall and become effective as of January 1, 2019. Key elements entail: operators of online marketplaces shall be obliged to fulfil new documentation duties regarding providers of goods;  documentation requirements shall apply to any goods that touch Germany – if the shipment starts or ends in Germany;…

July 5, 2018

The EU has introduced new cross-border transaction reporting requirements. Recently in May, the EU quietly adopted Council Directive 2018/822/EU on the reporting of “potentially aggressive” cross-border tax-planning arrangements. Reporting requirements will kick-in on August 31st, 2020, after the Council Directive is implemented by EU Member States. What is important is that the Council Directive is simply an instruction to Member States to create new national laws according to the principles of the directive; the directive itself is not itself a…

June 6, 2018

On May 24th, the EC published proposals related to the promotion of the use of small and medium sized enterprise (SME) growth markets. The proposals are designed to give more flexibility for SME growth market operators as to whether they wish to impose obligations related to the production of semi-annual reports on SME debt-only issuers. The MiFID II Directive (2014/65/EU) created the SME growth market trading venue (a subset of MTFs) to… facilitate access to capital for SMEs and the…

June 24, 2016

On the 23rd of June, the UK voted to leave the European Union. Known as “Brexit”, the UK Government with now initiate Article 50 of the Lisbon Treaty, starting the two year procedure leading to the UK’s eventual withdrawal from the EU and, ultimately, to the establishment of a new relationship with its former EU partners. Whatever your position, it is clear that Brexit will have a significant impact across a wide range of sectors – financial services, trade, employment,…

© 2021 Steven M. Pepa

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99
December 12, 2020

With all due respect to the BBC, the imposition of such a “one-time” wealth tax would have a disastrous impact on the British economy. Capital flight would occur, much like what is happening already in Argentina (which brought in such a measure last week). Given the now noticeable shift in public discourse in favour of greater burdens being placed on successful business people, those with means should start thinking about reorganising their affairs. Second citizenship and permanent residency verticals are…

December 7, 2020

Like other major economies in 2020, the UK is facing a tax deficiency in light of covid-19 and the severe contraction of its economy. Governments are now looking to new tax revenue schemes and everything is on the table. The Portuguese Golden Visa Program tied to a fund investment is one such possibility, as it provides a functional result coupled with a financial product designed to create liquidity and ease of exit. Read More.

November 10, 2020

A very nice development in Portugal this week. Birthright citizenship will be henceforth allowed for those that are born in Portugal to parents that have been permanent residency for at least one year. Coupled with the country’s Golden Visa Program, this will push Portugal to the top of the list in terms of permanent residency and citizenship programs (through the backdoor). An outstanding piece is found at IMI Daily.

November 8, 2019

Austria’s Ministry of Finance has recently provided some guidance on the question of an Austrian home office as it applies to an Austrian tax resident employee and whether such a setup can qualify as an Austrian permanent establishment for a non-Austrian enterprise. A permanent establishment for Austrian domestic tax purposes is a fixed place through which an enterprise’s business is carried out. Such an establishment can be an employee’s private flat, provided that employee renders his/her work at least partly…

October 15, 2019

The Austrian tax court has recently opined on the question of dividend payments from Austria to an intermediate EU holding company which has no substance (while its EU parent does). Generally in Austria dividends paid out by Austrian corporations trigger a 27.5% withholding tax. Nevertheless, pursuant to the EU Parent/Subsidiary Directive applied in Austria, outbound dividends are totally exempt from withholding tax if the parent company fulfils the criteria as set out in the Directive and holds at least 10%…

December 15, 2018

In early November, the Austrian Data Protection Authority issued a directive that data processing operations in all cases requires a data protection impact assessment (DPIA). Under Europe’s new General Data Protection Regulation (GDPR), DPIA is required during data collection. The Austrian rule changes are bringing effect to GDPR into the national regime. Please note that failure to carry out a DPIA can result in fines up to EUR 10m or 2% of worldwide annual turnover. DPIA Examples Some examples include:…

September 19, 2018

Recently in August, Germany moved forward with a proposal directed against VAT avoidance relating to supplies of goods with a German nexus over online marketplaces. The bills expected to pass parliament in late fall and become effective as of January 1, 2019. Key elements entail: operators of online marketplaces shall be obliged to fulfil new documentation duties regarding providers of goods;  documentation requirements shall apply to any goods that touch Germany – if the shipment starts or ends in Germany;…

July 5, 2018

The EU has introduced new cross-border transaction reporting requirements. Recently in May, the EU quietly adopted Council Directive 2018/822/EU on the reporting of “potentially aggressive” cross-border tax-planning arrangements. Reporting requirements will kick-in on August 31st, 2020, after the Council Directive is implemented by EU Member States. What is important is that the Council Directive is simply an instruction to Member States to create new national laws according to the principles of the directive; the directive itself is not itself a…

June 6, 2018

On May 24th, the EC published proposals related to the promotion of the use of small and medium sized enterprise (SME) growth markets. The proposals are designed to give more flexibility for SME growth market operators as to whether they wish to impose obligations related to the production of semi-annual reports on SME debt-only issuers. The MiFID II Directive (2014/65/EU) created the SME growth market trading venue (a subset of MTFs) to… facilitate access to capital for SMEs and the…

June 24, 2016

On the 23rd of June, the UK voted to leave the European Union. Known as “Brexit”, the UK Government with now initiate Article 50 of the Lisbon Treaty, starting the two year procedure leading to the UK’s eventual withdrawal from the EU and, ultimately, to the establishment of a new relationship with its former EU partners. Whatever your position, it is clear that Brexit will have a significant impact across a wide range of sectors – financial services, trade, employment,…

99
December 12, 2020

With all due respect to the BBC, the imposition of such a “one-time” wealth tax would have a disastrous impact on the British economy. Capital flight would occur, much like what is happening already in Argentina (which brought in such a measure last week). Given the now noticeable shift in public discourse in favour of greater burdens being placed on successful business people, those with means should start thinking about reorganising their affairs. Second citizenship and permanent residency verticals are…

December 7, 2020

Like other major economies in 2020, the UK is facing a tax deficiency in light of covid-19 and the severe contraction of its economy. Governments are now looking to new tax revenue schemes and everything is on the table. The Portuguese Golden Visa Program tied to a fund investment is one such possibility, as it provides a functional result coupled with a financial product designed to create liquidity and ease of exit. Read More.

November 10, 2020

A very nice development in Portugal this week. Birthright citizenship will be henceforth allowed for those that are born in Portugal to parents that have been permanent residency for at least one year. Coupled with the country’s Golden Visa Program, this will push Portugal to the top of the list in terms of permanent residency and citizenship programs (through the backdoor). An outstanding piece is found at IMI Daily.

November 8, 2019

Austria’s Ministry of Finance has recently provided some guidance on the question of an Austrian home office as it applies to an Austrian tax resident employee and whether such a setup can qualify as an Austrian permanent establishment for a non-Austrian enterprise. A permanent establishment for Austrian domestic tax purposes is a fixed place through which an enterprise’s business is carried out. Such an establishment can be an employee’s private flat, provided that employee renders his/her work at least partly…

October 15, 2019

The Austrian tax court has recently opined on the question of dividend payments from Austria to an intermediate EU holding company which has no substance (while its EU parent does). Generally in Austria dividends paid out by Austrian corporations trigger a 27.5% withholding tax. Nevertheless, pursuant to the EU Parent/Subsidiary Directive applied in Austria, outbound dividends are totally exempt from withholding tax if the parent company fulfils the criteria as set out in the Directive and holds at least 10%…

December 15, 2018

In early November, the Austrian Data Protection Authority issued a directive that data processing operations in all cases requires a data protection impact assessment (DPIA). Under Europe’s new General Data Protection Regulation (GDPR), DPIA is required during data collection. The Austrian rule changes are bringing effect to GDPR into the national regime. Please note that failure to carry out a DPIA can result in fines up to EUR 10m or 2% of worldwide annual turnover. DPIA Examples Some examples include:…

September 19, 2018

Recently in August, Germany moved forward with a proposal directed against VAT avoidance relating to supplies of goods with a German nexus over online marketplaces. The bills expected to pass parliament in late fall and become effective as of January 1, 2019. Key elements entail: operators of online marketplaces shall be obliged to fulfil new documentation duties regarding providers of goods;  documentation requirements shall apply to any goods that touch Germany – if the shipment starts or ends in Germany;…

July 5, 2018

The EU has introduced new cross-border transaction reporting requirements. Recently in May, the EU quietly adopted Council Directive 2018/822/EU on the reporting of “potentially aggressive” cross-border tax-planning arrangements. Reporting requirements will kick-in on August 31st, 2020, after the Council Directive is implemented by EU Member States. What is important is that the Council Directive is simply an instruction to Member States to create new national laws according to the principles of the directive; the directive itself is not itself a…

June 6, 2018

On May 24th, the EC published proposals related to the promotion of the use of small and medium sized enterprise (SME) growth markets. The proposals are designed to give more flexibility for SME growth market operators as to whether they wish to impose obligations related to the production of semi-annual reports on SME debt-only issuers. The MiFID II Directive (2014/65/EU) created the SME growth market trading venue (a subset of MTFs) to… facilitate access to capital for SMEs and the…

June 24, 2016

On the 23rd of June, the UK voted to leave the European Union. Known as “Brexit”, the UK Government with now initiate Article 50 of the Lisbon Treaty, starting the two year procedure leading to the UK’s eventual withdrawal from the EU and, ultimately, to the establishment of a new relationship with its former EU partners. Whatever your position, it is clear that Brexit will have a significant impact across a wide range of sectors – financial services, trade, employment,…

99
December 12, 2020

With all due respect to the BBC, the imposition of such a “one-time” wealth tax would have a disastrous impact on the British economy. Capital flight would occur, much like what is happening already in Argentina (which brought in such a measure last week). Given the now noticeable shift in public discourse in favour of greater burdens being placed on successful business people, those with means should start thinking about reorganising their affairs. Second citizenship and permanent residency verticals are…

December 7, 2020

Like other major economies in 2020, the UK is facing a tax deficiency in light of covid-19 and the severe contraction of its economy. Governments are now looking to new tax revenue schemes and everything is on the table. The Portuguese Golden Visa Program tied to a fund investment is one such possibility, as it provides a functional result coupled with a financial product designed to create liquidity and ease of exit. Read More.

November 10, 2020

A very nice development in Portugal this week. Birthright citizenship will be henceforth allowed for those that are born in Portugal to parents that have been permanent residency for at least one year. Coupled with the country’s Golden Visa Program, this will push Portugal to the top of the list in terms of permanent residency and citizenship programs (through the backdoor). An outstanding piece is found at IMI Daily.

November 8, 2019

Austria’s Ministry of Finance has recently provided some guidance on the question of an Austrian home office as it applies to an Austrian tax resident employee and whether such a setup can qualify as an Austrian permanent establishment for a non-Austrian enterprise. A permanent establishment for Austrian domestic tax purposes is a fixed place through which an enterprise’s business is carried out. Such an establishment can be an employee’s private flat, provided that employee renders his/her work at least partly…

October 15, 2019

The Austrian tax court has recently opined on the question of dividend payments from Austria to an intermediate EU holding company which has no substance (while its EU parent does). Generally in Austria dividends paid out by Austrian corporations trigger a 27.5% withholding tax. Nevertheless, pursuant to the EU Parent/Subsidiary Directive applied in Austria, outbound dividends are totally exempt from withholding tax if the parent company fulfils the criteria as set out in the Directive and holds at least 10%…

December 15, 2018

In early November, the Austrian Data Protection Authority issued a directive that data processing operations in all cases requires a data protection impact assessment (DPIA). Under Europe’s new General Data Protection Regulation (GDPR), DPIA is required during data collection. The Austrian rule changes are bringing effect to GDPR into the national regime. Please note that failure to carry out a DPIA can result in fines up to EUR 10m or 2% of worldwide annual turnover. DPIA Examples Some examples include:…

September 19, 2018

Recently in August, Germany moved forward with a proposal directed against VAT avoidance relating to supplies of goods with a German nexus over online marketplaces. The bills expected to pass parliament in late fall and become effective as of January 1, 2019. Key elements entail: operators of online marketplaces shall be obliged to fulfil new documentation duties regarding providers of goods;  documentation requirements shall apply to any goods that touch Germany – if the shipment starts or ends in Germany;…

July 5, 2018

The EU has introduced new cross-border transaction reporting requirements. Recently in May, the EU quietly adopted Council Directive 2018/822/EU on the reporting of “potentially aggressive” cross-border tax-planning arrangements. Reporting requirements will kick-in on August 31st, 2020, after the Council Directive is implemented by EU Member States. What is important is that the Council Directive is simply an instruction to Member States to create new national laws according to the principles of the directive; the directive itself is not itself a…

June 6, 2018

On May 24th, the EC published proposals related to the promotion of the use of small and medium sized enterprise (SME) growth markets. The proposals are designed to give more flexibility for SME growth market operators as to whether they wish to impose obligations related to the production of semi-annual reports on SME debt-only issuers. The MiFID II Directive (2014/65/EU) created the SME growth market trading venue (a subset of MTFs) to… facilitate access to capital for SMEs and the…

June 24, 2016

On the 23rd of June, the UK voted to leave the European Union. Known as “Brexit”, the UK Government with now initiate Article 50 of the Lisbon Treaty, starting the two year procedure leading to the UK’s eventual withdrawal from the EU and, ultimately, to the establishment of a new relationship with its former EU partners. Whatever your position, it is clear that Brexit will have a significant impact across a wide range of sectors – financial services, trade, employment,…