International Taxes


Prepare to prove cross-border transactions

Where is the trend of tax audits for cross-border payments heading? Definitely to proving the fulfilment of the conditions for the application of preferential tax regimes, not only formally but also in practice. This is not an isolated trend. Globally, various instruments and measures of tax administrations have focused on achieving one thing in the last few years – preventing tax evasion and situations in which income is taxed in countries with lower or zero tax rates. And the easiest way to achieve this involves audits in companies, which pay the respective income abroad. 

25. 11. 2021

International letter of request and duration of the limitation period for tax assessment

A request for international cooperation, in other words, an international letter of request, is one of a range of instruments that the tax administrator can use in tax proceedings to assess tax correctly. Recently, the number of cases in which the tax administrator used this instrument in the inspection of cross-border transactions has been increasing. However, let us look at this instrument from the perspective of a taxable entity. 

22. 11. 2021

In Brief from International Taxation [October 2021]

Germany will allow partnerships to tax income as corporations through corporate tax. The Finnish Supreme Administrative Court has issued a ruling regulating the rules restricting the tax deductibility of interest expenses. The European Union has included Hong Kong in the list of non-cooperative tax jurisdictions in Annex II, together with a commitment to adjust the tax exemption regime for foreign income. This and more can be found in current news from the field of international taxation. 

21. 10. 2021

OECD: Implementation plan of a two-pillar solution

The OECD kept its promise and issued a Statement on 8 October 2021 involving a draft implementation plan of the two-pillar solution to address the tax challenges arising from the digitalisation and globalisation of the economy. An information brochure including answers to frequently asked questions was issued along with the Statement. The global convention was subsequently endorsed by the G20 representatives during their summit. 

20. 10. 2021