Michaela Merz


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Paraguay: New taxes on digital imports as from 1 of January 2020


Under a tax reform that took effect from 1 January 2020, digital services supplied by non-residents to local consumers became liable to 10% VAT and 4.5% Income Tax for Non-Residents (INR). Under the new rules, banks, financial institutions, exchange houses, cooperatives, payment processors or similar entities, and telephone companies or other entities that mediate for the provision of digital services, must act as a withholding agent in respect of collecting the tax due. However, Regulatory Decree No. 3181 establishes a transitional provision under which mandatory withholding for digital services will become effective as of 1 July 2020.

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TP – The OECD released a final paper on Financial Transactions Transfer Pricing


The OECD published a new chapter of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Authorities (“the OECD Guidelines”). The new chapter provides guidance on the transfer pricing for loans, guarantees, cash pools, hedging and captive insurance transactions.

The new chapter is the first OECD guidance on transfer pricing for financial transactions issued in final form and will be the main reference point for pricing and auditing related party financial transactions in most countries going forwards.

Loan, guarantee and cash pool policies that Swiss groups apply across their international operations should be reviewed and updated to ensure compliance with the new guidance.

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UK/Switzerland – BREXIT update


The UK’s departure from the EU – BREXIT – took effect on 31 January 2020 under the terms of the Withdrawal Agreement agreed with the EU in October 2019. As a consequence, the UK has left the political institutions of the EU and entered a transition period. During this transition period (until 31 December 2020), EU regulations will in principle continue to apply in the UK. In the course of the next months the UK government and the EU will negotiate a comprehensive trade deal.

The BREXIT may have an impact on the treaty clearance for payments between Switzerland and the UK and puts treaty claims at risk based on the Swiss-US DTT:

Payments from the UK to Switzerland / from Switzerland to UK: replace 823C with 823B

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Switzerland: VAT return digitalization


Swiss VAT – “MWST-Abrechnung easy”

Today, the FTA reached another milestone in its digitization strategy: More than half of the taxable persons settle VAT online.

Within the last year, the proportion of persons settling online has risen from 36% to over 50%. This means that currently more than 194,000 companies are settling VAT electronically, and the trend is rising.

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EU : EORI Number and Brexit


UK left EU on January 31, 2020. Transition period run until December 31, 2020.

In the Netherlands the Dutch customs authorities have already granted Dutch EORI numbers to companies which have a UK EORI number as well. Therefore number of companies have two active EORI numbers in place.

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India: Union Budget – Rebuilding momentun 2020-21


The Indian sentiments on growth mirroring the global pessimism and manifested through distress in the financial sector, lower GST collections and strain on the fiscal deficit was the backdrop in which the Finance Minister tabled the budget proposals for FY 2020-21.

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Hungary – changes in the field of digital reporting as from 1 of April 2020


The Hungarian online reporting is effective for invoices with the VAT content above HUF 100,000 issued after July, 1 2018. This online invoice reporting obligation will be subject to significant changes over the coming years.

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