Germany's Federal Constitutional Court rules change-in-ownership rules partially unconstitutional
In a taxpayer-favorable decision issued on 29 March 2017 and published on 12 May 2017, Germany’s Federal Constitutional Court held that the change-in-ownership rules relating to loss carryforwards partially infringe the German constitution, and must be amended with retroactive effect.
SAT Issued New Rules to Improve Administration of Special Tax Investigation and Adjustment and Mutual Agreement Procedures
On 17 March 2017, the State Administration of Taxation (SAT) issued new regulations to improve administration of Special Tax Investigation and Adjustment and Mutual Agreement Procedures (i.e. Bulletin 6, or Bulletin).
Tax Treaty Update – Russia, Denmark and Spain
According to a press release of the Japanese Ministry of Finance (MOF), the Governments of Japan and the Russian Federation, as well as Japan and the Kingdoms of both Denmark and Spain, have initiated negotiations to amend their current bilateral tax treaties.
Tax incentives for the relocation and expansion of headquarter functions from major cities to local areas
This newsletter outlines the procedures to apply for these benefits and summarizes the calculation of such benefits related to tax relief for capital investments and job creation, both of which have a significant impact on corporate tax.