In the age of the digitization and global interlinking nearly every enterprise becomes conscious or unconsciously with the international tax right confronted.

Experience and routine is necessary beside a maximum in sound legal knowledge in the national law as well as in the legal system of the foreign state for the solution of international tax circumstances. The TLI Steuerberatungsgesellschaft is specified on the solution of the most complicated international of tax circumstances. The tax advisers TLI distinguish themselves by the additional qualification „specialized advisor for international tax law“ which can be attained only by filing an additional one by the state supervised check as well as the proof about the treatment of a variety of practical cases in the international tax law.

Trust with the consultation in the area of the international tax law, e.g., with the acquisition of participation or real estate abroad, with foreign company sites, with the regulation of settlement prices or by delegation of employees abroad in the professional advisers for international tax right of the TLI Steuerberatungsgesellschaft Dobner GmbH & Co. KG.

The tax advisers of TLI are always informed about changes in the foreign tax legal systems and also detain you with short land reports.

a. Italy: Introduction of a web tax

By the 1 January 2020 Italy has introduced so-called “Web Tax”. This web Tax corresponds to the French model which intends a taxation of 3 % on home ones digitally achieved turnovers. The new web Tax should be valid as long as, up to international level a uniform arrangement for the taxation of digital turnovers is made.

Not every enterprise with turnovers digitally achieved in Italy is concerned by the new web tax. However, foreign companies that do not have a permanent establishment in Italy may also be subject to the new tax. If the conditions for taxation are met, the foreign company must register or appoint a fiscal representative in Italy.

Taxable are digital services such as the transmission of data generated by using a digital platform, the provision of multilateral digital platforms and the placement of advertising on a digital platform.

In particular, physical deliveries of goods within the framework of digital mediation are excluded from the Italian web Ttx.

The place of supply of the service is relevant for the application of the new web tax. However, the criteria for determining the place of performance of the service are likely to be subject to dispute.

The experts and specialist advisors for international tax law at TLI Steuerberater are at your disposal with their wealth of experience in international taxation. TLI tax consulant advises on the domestic activities of foreign companies, the foreign activities of German companies, and the immigration and emigration of natural persons.

b. India: News from company taxation

In order to stimulate economic growth in India, the government has decided to significantly reduce the corporate tax burden. In addition, there will be further tax relief for companies.

The standard tax rate for companies in India has so far been 30 %. The new regulation reduces the tax rate to 22 %. Under certain conditions, the tax rate can be reduced to 15 % for start-ups.

This new regulation could also provide a huge incentive for foreign companies to invest. However, a reduction in the tax rate must always be seen in the international tax context and in compliance with the double taxation agreements.

Like the United States of America, India also has a minimum tax, the so-called “alternative minimum tax”. The tax rate for this minimum tax has also been reduced. Additional levies have also been reduced.

TLI tax advisors‘ experts and expert advisors on international tax law will assist you with their wealth of experience in international taxation. TLI Steuerberater advises on domestic activities of foreign companies, foreign activities of German companies, as well as on the immigration and departure of natural persons.

c. Spain: Notification obligations for foreign relations

With effect from 1 January 2018, Germany had tightened its national rules on the reporting obligation for foreign matters. Particularly affected was the obligation to notify so-called third-country issues. The background to this intensification was the public discussion about the so-called Panama Papers, which uncovered a number of so-called letterbox companies in tax havens.

The Spanish Government has recently followed suit and has also tightened its national rules on the obligation to notify foreign affairs. In particular, the creation of companies, the exercise of functions of management, a shareholder or a trustee as well as special services will be subject to notification in the future.

The Spanish treasury imposes heavy fines for not reporting these facts.

TLI tax advisors and expert advisors on international tax law will assist you with their wealth of experience in international taxation. TLI Steuerberater advises on domestic activities of foreign companies, foreign activities of German companies, as well as on the immigration and departure of natural persons.

If you have any questions about national or international tax issues, please contact us directly at any time.