On 12 May 2022, a Dutch Court of Appeal (Gerechtshof`s-Hertogenbosch) issued a decision in a case concerning, inter alia, whether an arm`s length interest rate had been taken into account for a permanent establishment (PE) in Libya. More specifically, the question was whether the solvency of the Dutch legal entity had been correctly taken as a starting point and whether sufficient adjustments had been made to the increased risk profile of the Libyan state-owned institution. In the second part of KPMG`s tax transparency series, experts #tax and #ESG discuss key challenges and practical approaches to meaningful tax reporting. Read more: social.kpmg/gkaa85 Manoj Pardasani During our 2021 virtual tax and legal summits, 5,000 business leaders and tax professionals from 100 countries/jurisdictions gathered to explore emerging tax and business considerations, explain some of the challenges facing businesses in the post-COVID era, and examine opportunities for tax officials as services Tax are striving to evolve for 2021 and beyond. Thank you to everyone who participated in this unique series of virtual summits. The Agency found that the work performed by the Danish employee did not constitute a permanent establishment for the German group company, since the employee was not authorised to negotiate prices and contracts and to enter into legal commitments on behalf of the German group company. The Agency found that the employee`s tasks were not such that they could be considered to play a decisive role in the conclusion of agreements implemented at the level of the German group company. What are some of the key drivers of a more technology-driven operating model? KPMG`s tax chiefs, Jay Ayrton and Susie Cooke, discuss the latest ideas on tax transformation: social.kpmg/yhzzmd. #TaxTechnology #TaxReimagined KPMG`s Head of Tax for Africa opened the conference with an armchair discussion with KPMG EMA Region Tax Manager, who shared his experience working with the region`s tax leaders tasked with leading and developing their tax functions of the future.
If non-compliance previously resulted in a penalty of €10,000 per violation, the new rules provide for the following fines for legal entities that fail to disclose information, misdisclose information or do not retain the required information at the company`s registered office or branch: Our engaging and interactive program, Consisting of insightful presentations and panel discussions, as well as intimate panel discussions, this would help and prepare the region`s tax and finance leaders to think about the future of their tax, financial and business strategies. Today`s tax officials need to be aware of the changing tax landscape and keep abreast of cross-border tax policies. The 2022 edition of the Tax Guide for the Middle East and South Asia (MESA) – KPMG`s flagship publication on tax thought leadership in the MESA region – provides a summary of the general framework required to do business in each country, as well as an overview of tax and regulatory requirements. Email the team to learn more about our upcoming virtual summit and event. Discover some of the key takeaways from the summit sessions, the results of some polls conducted during the sessions, as well as new thought leaders based on key issues for the year, and let`s continue the discussion. This session, titled The future of tax & legal: Keeping global connected virtual meeting series, focused on compliance, policy and reputation issues that should be considered as we weather the initial shock and management of the novel coronavirus (COVID-19). The topics discussed are: The summit is expected to provide delegates with new and diverse perspectives on economic, geopolitical and regulatory macroeconomic trends affecting business and the tax community. The event was also a platform to better understand these issues and opportunities to be more agile and resilient. The case concerned a Danish tax resident who was employed as sales manager for Scandinavia by a Danish group company. The employee acted as Key Account Manager for existing customers on behalf of a German group company that developed and manufactured products for the Scandinavian region and was responsible for identifying new business opportunities and increasing the group`s sales in the region. The employee worked from Denmark and spent 90% of his time in Denmark. Given the scale of innovation needed to manage #ClimateChange, it is likely that businesses will be subject to both tax and non-tax measures.
For more information from KPMG`s tax and #ESG executives: social.kpmg/4wjqtg. Loek Helderman, Michael Hayes, David Linke, Hannah Hawkins, Chris Morgan, Becky Knight, Tim Sarson, Grant Wardell-Johnson #NetZero KPMG clients can follow summit sessions upon request In line with the comments made by Paolo Gentiloni (Commissioner for Economic Affairs) at the public hearing of the FISC Subcommittee on 27 June 2022 (see E-News issue 157), The Commission noted that it had already addressed the legal and economic aspects of a windfall profit tax on the EU. The Commission recognised that such a tax must be carefully designed in order to avoid undesirable market distortions. Although the Commission also noted that the design and introduction of a windfall profits tax is generally feasible, it was pointed out that some elements of complexity are being examined in more detail by the European Commission services. These concern the definition of extraordinary profits, temporal aspects and tax rates. According to the European Commission official, a more coordinated EU approach would be useful in shaping the taxation of windfall profits. To this end, the European Commission services are assessing whether more action can be taken at EU level in this area. The Commission also referred to its previous guidance on the application of tax measures to submarginal profits set out in Annex 2 of RePowerEU. What is emerging for the ever-changing tax ecosystem in the #EU? Join KPMG`s tax professionals for the latest developments in the financial services industry: social.kpmg/cr35um Raluca Enache, Sonia Galley, Christian Fischler, Peter Grant, Mark Semple, Nils Schmid, Nacera Beniken, Olivier Schneider, James Kelly #BEPS #ATAD3 #WithholdingTaxes An overview of KPMG`s regional tax centres, their services and region-specific information. #BEPS 2.0 is fast approaching. Learn about the latest developments in Pillars 1 and 2 with KPMG`s Tax Policy Leadership Group on November 8.
Register here: social.kpmg/cr35um Melissa Geiger, Vinod Kalloe, Manal S. Corwin, Conrad Turley, Grant Wardell-Johnson #OECD Europe is a pioneer in climate protection and a driver of the global environmental agenda, with the aim of becoming the first climate-neutral continent by 2050. It continues to develop a strong political system to achieve this goal through its European Green Deal, its Fit for 55 legislative package of July 2021 and its recently launched REPowerEU. The next virtual meeting in The future of tax & legal: Keeping connected globally series will provide an overview of possible requirements for cross-border corporate restructuring and other financing requirements. From a business, tax and legal perspective, “corporate restructuring in the post-pandemic world” includes the following: a lower district court had ruled on a distribution of debt and equity (relevant for the application of arm`s length distribution of interest expense) that differed significantly from the position of the taxpayer who had not taken into account debts – a deviation from the debt ratio. of the Netherlands legal person, the reasons why the taxable person had not been able to prove. Although much is still unknown, we have learned a lot since the beginning. This final webcast will be an opportunity to explore the changes we`ve seen and expectations for the future, as well as reflect on what you`ve told us along the way.