EU: Anti-Tax Avoidance Directive II (“ATAD II”)

On February 21, 2017, the 28 European Union (EU) Finance Ministers in the ECOFIN Council meeting reached political agreement on the Council Directive amending Directive (EU) 2016/1164 regarding hybrid mismatches with third countries with a view to adopting it (subject to receiving European Parliament’s opinion and legal-linguistic revision).

ATAD II basically adds to the existing ATAD I (adopted in 2016 and effective as of 2019) rules on mismatches with third countries and basically extends the hybrid mismatch definition to also include mismatches resulting from arrangements involving PEs, hybrid transfers, imported mismatches, and reverse hybrid entities. In addition, ATAD II includes rules on tax residency mismatches.

ATAD II still needs to be submitted for formal adoption at a next ECOFIN Council meeting after the European Parliament has formally issued its opinion on the EC proposal, which is currently scheduled for 26 April 2017.

Once formally adopted, EU Member States will need to transpose the provisions by 31 December 2019 and apply them per 1 January 2020. By way of derogation, the specific reverse hybrid entity rule would need to be transposed by 31 December 2021 and applied per 1 January 2022, however payments to reverse hybrids would not be deductible anymore from 1 January 2020.

The further developments in the EU in this regard should be closely monitored as they may potentially have implications for Swiss Finance Branches and Principal Companies.

For more information please find below the newsletter from our EUDTG network.

Download EUDTG newsletter

 

VAT Compliance Tools

The world of VAT and customs reporting is changing rapidly.

As businesses, we’re living in a world, which is becoming increasingly globalised, with the adoption of more and more VAT and other indirect taxes. Tax authorities are requesting more detailed transactional information than ever before – and more quickly. At the same time new technologies are introducing unprecedented methods to track both indirect and direct taxes.

It has now become business critical to keep up to date with your VAT compliance responsibilities and to be ready for more thorough questioning from your tax authorities. The best way to achieve this, we believe, is to embrace the new technologies available.

Here are some quick demonstrations of our key compliance tools. Click on the pictures to launch the selective video. Presentations and additional informations can be found below the videos.

1 VAT reconciliation solutions
PwC has different solutions to help you with VAT/turnover reconciliation, from an automated excel-based solution building on standard ERP VAT reports to an SAP-integrated programme which allows automated reconciliation preparation directly in SAP. An automated solution helps you reduce the manual workflow involved in setting up a VAT/turnover reconciliation in line with Swiss VAT law, and allows you to focus more on the analysis of transactions.vat_reconciliation

Presentation: VAT reconciliation solutions – February 2017, PwC Zurich
– Flyer: Does your ERP System talk ITX?

2. Taxmarc for SAP
Taxmarc is an ‘add on’ to the SAP-system and gives an insight into all the data which is relevant for determining the VAT that is payable or receivable. The system facilitates VAT treatment for each individual transaction.
taxmarc

– Presentation: Taxmarc for SAP – February 2017, PwC Zurich

3. VAT compliance technology
Our STARS compliance and analytics solution enables the automation of indirect tax returns, as well as providing detailed analysis of underlying transactional data. It helps standardise processes, increase efficiency and reduce risk in VAT compliance.
vat_compliance_automation

Presentation: VAT compliance Automation – February 2017, PwC Zurich

4. Customised-Import
Making import data visible with a diagnostic tool: With Customised-Import we can analyse the import data of a company, looking at a variety of aspects of import handling, quantifying savings and risk potential, and making the data visible to different interest groups in an easy and intuitive way.
customised_import

Presentation: Customised-Import – February 2017, PwC Zurich
Flyer: Keep track of your import data

5. Data analytics in indirect tax
The introduction of data analytics for indirect tax by authorities in most EU countries is now an impending reality. To become more efficient and create greater value for the broader business, tax functions need to take a closer look at the data they collect, the technology and processes they use, and rethink their approach to tax data management. PwC data analytics provides a complete view of the VAT risks and the opportunities that arise from using data smartly.

Presentation: Data analytics – February 2017, PwC Zurich
– Learn more about our Webcast on Wednesday, March 8, 2017

6. VAT refunds re-imagined
Businesses operating across borders often incur significant amounts of local VAT on expenses. Global reclaim Assessor (GrA) is a solution that enables the processing of invoices for VAT refund claims in a cost-effective way, helping businesses to recover the VAT paid and to optimise cash flow.

EUDTG Newsletter November – December 2016

EU direct tax law is a fast developing area. This presents taxpayers, in particular groups and multinational corporations that have an EU or European Economic Area (EEA) presence, with various opportunities.

The following topics are covered in this issue of EU Tax News:

CJEU Cases

  • Belgium: AG’s Opinion on the Belgian fairness tax: X
  • Denmark: CJEU Judgment on the Danish thin capitalisation rules: Masco Denmark ApS
  • Portugal: CJEU Judgment on the taxation of profits distributed by entities in third countries: SECIL
  • United Kingdom: AG’s Opinion regarding UK trust exit taxation: Trustees of the P Panayi Accumulation & Maintenance Settlements v HMRC
  • United Kingdom: AG’s Opinion on UK FID regime: The Trustees of the BT Pension Scheme v HMRC

National Developments

  • Netherlands: Dutch AG’s Opinion regarding Dutch dividend withholding tax on foreign investment funds
  • Spain: National High Court of Justice upholds insurance company claims
  • United Kingdom: Court of Appeal judgment on remedies in the franked investment income (FII) group litigation

EU Developments

  • EU: ECOFIN Council of 8 November 2016 adopts criteria for screening of third country jurisdictions
  • EU: ECOFIN Council of 6 December 2016 – results
  • EU: European Commission’s public CBCR proposal’s legal basis challenged
  • EU: European Commission welcomes the entry into force of new transparency rules for tax rulings

Fiscal State aid

  • Hungary: European Commission publishes its final decision on the Hungarian advertisement tax
  • Ireland: Non-confidential version of the European Commission’s final State aid Decision on Apple
  • Spain: CJEU Judgments on the Spanish financial goodwill amortisation scheme: Autogrill v Commission and Banco Santander and Santusa v Commission

This EU Tax Newsletter is prepared by members of PwC’s international EU Direct Tax Group (EUDTG).

Read the full newsletter here.

Further information about our service offerings in EU taxes: www.pwc.com/eudtg

Europe knows all about your VAT transactions – Do You?

There are headlines most weeks, if not days, telling us all about the different European jurisdictions where submission of transactional VAT data is mandatory. What frustrates me is that these stories tend to recycle the number of EU states who have mandatory regimes, without explaining which countries they are talking about, or which regulatory submission.

“There are 6 EU SAF-T states, but 2 also have an e-audit regime” is one of the most frequently recurring. However, I have seen articles claiming 9 or 10 transactional eFiling territories. Having gone back to the individual EU/EEA countries concerned to look at the legislation, I suggest that there are actually at least 14 countries across Europe who are (or will be by 1 July) collecting and analyzing this data.

Traditional VAT/SAF-T

Austria, France, Lithuania, Luxembourg, Poland & Portugal all have existing SAF-T based eFiling regulations for VAT transactional data. With Norway joining them this year, we have 7 SAF-T territories in Europe / EEA.

SAF-T has historically been used to provide more detailed, transactional, data about VAT subsequent to the filing of quarterly or monthly summary form-level data.

Invoice Approval or Submission

A second group of countries require the submission of Invoice data, either in real-time or following on shortly after the event. Czech Republic & Slovak Republic have long-standing regulations here, and Italy, Hungary & Spain join them this year. Italy from 1 January, Hungary & Spain from 1 July. That gives us 5 more territories.

You can debate the point whether each submission standard in this category is SAF-T or not; I’m not that concerned about what you call it. I am grouping these on the basis that the regulation comes from Invoicing, rather than VAT.

TNA

The Benelux countries have, for a number of years, shared cross-border VAT information within a project called Transactional Network Analysis, to identify and prevent Carousel Fraud.

Public statements have suggested that up to 10 countries are a part of the TNA group, but only the Benelux 3 are clearly identified. Luxembourg is a part of our Traditional VAT/SAF-T group, but we can definitely add Belgium & Netherlands to our list of EU states collecting sufficient transactional data sufficient to perform analytics. The others may be part of our SAF-T or Invoice groups, but we cannot be certain.

Data Analytics

With these regulatory submissions, the authorities have detailed submissions about each individual transaction; that’s as much information as your own organisation holds on those transactions. They also have large, and growing, data analytics groups of their own.

If your organisation is not performing data analytics on your own VAT & Invoice data, it will not be long before the regulators are asking you questions that you do not want to hear; they can compare your data with all the other data they collect, and exchange, and know more about your companies data than you do!

Are your supplies of blood plasma VAT exempt?

FinanzForum_2015_v2Recent developments related to blood plasma supplies in the EU and a comparison to the Swiss VAT treatment

Does human blood plasma fall within the scope of the VAT exemption applicable to blood?

  • In the European Union (EU)

On 5 October 2016, the Court of Justice of the European Union (CJEU) issued its decision to a German case (C-412/12, TMD) 1, in regards to whether the supply of blood plasma used for manufacturing of medicinal products should be VAT exempt or not.

With its decision CJEU, confirmed that although not explicitly listed in the EU VAT Directive’s 2 article, which provides for the VAT exemption of supplies of blood and human organs 3, the supply of plasma derived from human blood falls under the exemption, but only when the plasma is actually intended for direct therapeutic use.

Additionally, CJEU ruled that where the human blood plasma is intended to be used for the manufacture of medicinal products (i.e. plasma intended for industrial use) it should be subject to VAT. In this latter case, the question remains “Which VAT rate applies – the standard rate or the reduced rate?” The answer to this question depends on the national VAT rules of the country where the blood plasma sale, intra-community acquisition or import takes place.

  • In Switzerland

Swiss VAT law provides for a VAT exemption of supplies of blood and human organs 4; however, only the supplies of whole blood by persons possessing the required license are eligible to the VAT exemption.

Therefore, the supply of blood plasma, which is a component of human blood, but does not qualify as whole blood itself, is subject to Swiss VAT. Such an interpretation has been confirmed by the Federal Tax Authority (FTA) in their written guidelines.

The FTA has also confirmed that if the human blood plasma can qualify as “medication” 5, then the reduced VAT rate of 2.5% applies.

zentralschweizer_spitalapero

Implications your business should consider

As the CJEU’s decision becomes directly applicable legislation in all EU member states, it is expected that the CJEU’s decision would trigger changes to the current tax authorities’ practices in some countries, particularly with respect to the VAT treatment of blood plasma for industrial use.  This new EU legislation would mainly affect the specialized laboratories selling blood plasma, the pharmaceutical companies using plasma for the manufacture of medicinal products, as well as the intermediaries involved in the supply chain.

In view of the above, if you are involved in transactions with blood plasma (as either a supplier or a purchaser) it is recommended that you continue to monitor for local country developments triggered by the TMD case (C-412/12), and assess the impact of the CJEU’s decision in the light of both the EU and local legislation applying to your current supply chain.

We have provided a list of impacts/actions to consider, depending on your role in the plasma transaction (supplier/customer/intermediary), in the detailed PDF below:

PlasmaNews_Thumbnail_28.11.16

 

Download the PDF here: Are your supplies of blood plasma VAT exempt?

 

 

If you would like to discuss the above in more detail and assess the implications for your business, please do not hesitate to contact us.

Patricia More
Partner, Indirect Tax
PwC Geneva
patriciat@ch.pwc.com
+41 58 792 95 07

Sandra Ragaz
Indirect Tax Leader for Pharma & Life Science in Switzerland
PwC Zurich
sandra.ragaz@ch.pwc.com
+41 58 792 44 69

Gergana Chalakova
Manager, Indirect Tax
PwC Geneva
gergana.chalakova@ch.pwc.com
+41 58 792 92 02

1 C-412/15 (TMD Gesellschaft für transfusionsmedizinische Dienste mbH v Finanzamt Kassel II – Hofgeismar)
2 Directive 2006/112/EC
3 The VAT exemption on blood is laid down in Article 132(1)(d) of Directive 2006/112/EC.
4 The VAT exemption on blood is laid down in Article 21(2)(5) of Swiss VAT Law of 12 June 2009.
5 Definition of “Medication” is provided with Article 49 of the Ordinance to the Swiss VAT Law

Customs and International Trade

As you may have noticed, some changes will become applicable to the Harmonised System (HS) and subsequently to the Swiss Nomenclature (customs tariff) as well as to the EU Combined Nomenclature (CN) as of 1 January 2017. This includes the classification of pharmaceutical products of chapter 30:

Swiss Nomenclature

Swiss Nomenclature

EU Combined Nomenclature (CN)

EU Combined Nomenclature

Although the import of these products in Switzerland and the EU is still duty free, we recommend to check the classification of your products and makes changes/ amendments where needed. Should you need our assistance with (re)classifying your products, we are of course happy to help you.

PwC Customs & International Trade 2016

 

Download here the publication in PDF version: Customs and International Trade 2016

 

 

 

Sandra RagazSandra Ragaz
Director, TLS
+41 58 792 44 69
sandra.ragaz@ch.pwc.com

ChrisChristina Haas Brunitina Haas Bruni
Senior Manager, TLS
+41 58 792 51 24
christina.haas.bruni@ch.pwc.com

EUDTG Newsletter September – October 2016

EU direct tax law is a fast developing area. This presents taxpayers, in particular groups and multinational corporations that have an EU or European Economic Area (EEA) presence, with various opportunities.

The following topics are covered in this issue of EU Tax News:

CJEU Cases

  • Belgium: CJEU Judgment on the compatibility of the Belgian Net Asset Tax on foreign investment funds with EU law: NN (L) International SA
  • Belgium: CJEU Judgment on the different tax treatment between and third country dividends: Riskin and Timmermans
  • Belgium: AG’s Opinion on the subject-to-tax requirement of the Parent-Subsidiary Directive: Wereldhave Belgium and Others
  • Germany: CJEU referral on the German anti-treaty/anti-directive shopping rule: Deister Holding

National Developments

  • Belgium: Introduction of Transfer Pricing documentation obligations in Belgium
  • Belgium: Tate & Lyle reduced withholding tax rate: subject-to-tax requirement introduced
  • Belgium: Cayman Tax applicable to privately managed investment companies
  • Belgium: Implementation of the Parent-Subsidiary Directive anti-hybrid measure and GAAR
  • Belgium: Introduction of exit taxation
  • Finland: Foreign pension insurance company entitled to tax deduction based on technical reserve provision
  • Finland: Central Tax Board decision on the tax treatment of dividends from third country subsidiaries
  • Finland: Central Tax Board decision on the tax treatment of dividends received by foreign investment fund
  • Finland: Supreme Administrative Court Judgment on the tax exemption of German Real Estate Fund on Finnish real estate income
  • Norway: ESA reasoned opinion on the Norwegian interest limitation rules
  • Poland: Proposed amendments to the tax exemption of investment funds
  • Spain: Positive Regional Tax Court decision on Fokus Bank claims of a Finnish public pension fund
  • Spain: General Tax Directorate decision on the application of the Spanish regional wealth, inheritance and gift tax laws
  • United Kingdom: Application of the FII GLO CJEU Judgment where no foreign tax charged on profits underlying dividends: High Court judgment

EU Developments

  • EU: European Commission proposes Corporate Tax Package
  • EU: ECOFIN Council adopts Council Conclusions on new transparency rules and next steps to tackle terrorism financing, money laundering, and tax avoidance
  • EU: European Commission announces start of work to create first common EU list of “non-cooperative tax jurisdictions”
  • EU: European Commission President Juncker’s 2016 State of the (European) Union

Fiscal State aid

  • Sweden: European Commission approves Swedish tonnage tax regime

This EU Tax Newsletter is prepared by members of PwC’s international EU Direct Tax Group (EUDTG).

Read the full newsletter here.

Further information about our service offerings in EU taxes: www.pwc.com/eudtg

Digitalization of the Tax Environment

Digitalization thumbnailIt is no surprise that the whole world is getting more and more digital, but it is important to acknowledge that so are also the tax authorities in requirements they now set forth towards taxpayers.

OECD’s model of SAF-T files (followed by Polish JPK or Lithuanian i.SAF), French FEC, Lux FAIA and many other forms of more or less standardized types of electronic files are currently being required all over Europe. In the other corner, a huge amount of businesses struggle to make their ERP capture all transactions in a VAT compliant manner.

Our PwC Geneva VAT team organised a very successful breakfast event last week to discuss these challenges. Participants also had the chance to discover “Taxmarc”, an integrated tool created by PwC Netherlands and primarily designed for SAP systems, that significantly increases the level of ERP’s VAT compliance capabilities (e.g. that is able to automate VAT determination for triangulations or drop shipments transactions – just to name a few features). The tax control framework built in Taxmarc is an impressive enhancement of the VAT features, compared to the standard SAP logic.

If you are interested in this topic, please feel free to dowload the presentations below or to contact us directly to discuss your challenges.

Digitalization thumbnailDigitalization of the Tax Environment

 

DataIgnition thumbnailData Ignition for Indirect Tax

Taxmarc thumbnailTaxmarc

 

Patricia More
Partner, Indirect Tax Services
PwC Switzerland
Tel. +41 58 792 95 07
Email:
patricia.more@ch.pwc.com

Bozena Turek
Manager, Indirect Tax Services
PwC Switzerland
Tel. +41 58 792 91 25
Email:
bozena.turek@ch.pwc.com

Gergana Chalakova
Assitant Manager, Indirect Tax Services
PwC Switzerland
Tel. +41 58 792 92 02
Email:
gergana.chalakova@ch.pwc.com

Renewed definition of supplies of goods in chain transactions which involve intermediaries

The Commission Services (a working council of the European Commission) has recently published a working paper in which they provide their reasoning as to what makes up a supply of goods as a result of a judgment of the Court of Justice of the European Union (‘CJ EU’). The items discussed in this working paper are relevant for chain transactions in which intermediaries are involved who trade goods they do not actually dispose of as an owner.

Graphic

The working paper is issued in response to the questions raised by Lithuania on how the Fast Bunkering Klaipėda case of the CJ EU should be explained and applied in practice. Delegates of the EU Member States (who together form the VAT Committee) are now requested to give their opinion on the issues raised by the Commission Services.

Issues raised

The Commission Services are of the view that the outcome of the CJ EU judgment Fast Bunkering Klaipėda court case could not be said to be particular to that specific case, but may also be relevant to other scenarios such as chain transactions.
As explained by the Commission Services, the CJ EU judgment has made clear that a supply of goods for VAT purposes is recognised in case someone is empowered actually to dispose of goods as if he/she were their owner. The (subsequent) transfer of legal ownership to anyone else (if applicable) would therefore, in principle, have to be disregarded. This was apparently the case for Fast Bunkering Klaipėda who supplied goods on a ‘free on board’ basis to an intermediary (who was acting in his own name) but directly loaded the fuel itself into the vessel’s fuel tank of the final recipient. In this situation the intermediary could not actually dispose of the goods as an owner, since at the moment he obtained legal title to the goods, the fuel oil was already loaded into the vessel and put at the disposal of the final recipient.
According to the CJ EU, in such case a direct supply of goods takes place from the first supplier to the final recipient (ignoring the involvement of the intermediary). In the working document the EC now raises the issue that the transaction performed by the intermediary should consequently be regarded as a supply of services, as he is not in the position to supply goods that are already supplied for VAT purposes to the final recipient.

It is noted by Commission Services that in as far as the intermediary acts on behalf of another party, the intermediary is still deemed to have purchased and onward supply the goods. Hence, where a commissionaire is involved, the above should not be applicable.

Impact on businesses

If the above position would be true, the impact on businesses would potentially be significant. In supply chains similar to the one of Fast Bunkering Klaipėda, the first supplier would from a VAT perspective no longer be supplying goods to his direct counterparty, but to the final recipient instead. At the same time, it should be determined to which party the intermediary is rendering its services. Obviously this would have an enormous impact on the invoice flows in the supply chain. Moreover, the intermediary would be forced to disclose his margin (i.e. the fee for his services), which might be an issue in practice.
In our view, the impact on businesses of the Fast Bunkering Klaipėda case and this working paper from Commission Services is limited to those supply chains whereby the transfer of legal ownership takes place at the same time as or after the disposal of the actual ownership takes place. In this respect, it could be questioned whether a transfer of goods to someone empowered actually to dispose of those goods as if he were their owner necessarily takes place at the same time that the goods are physically put at the disposal of a buyer or final recipient.
Particularly in commodity trade vessels might already have left the harbour, whereas the documents that represent ownership of the goods loaded in the vessels (e.g. bills of lading) are distributed throughout the supply chain thereafter. It could be that the Fast Bunkering Klaipėda case and this working paper from Commission Services therefore do not necessarily have an impact, as all parties in the supply chain normally receive (and onward distribute) the documents representing ownership of the goods loaded in the vessel (unless economic reality proves otherwise). This might be different for the situation whereby parties involved in the supply chain establish a so-called ‘string’, based on which a document by-pass takes place from the first supplier to the last recipient in the supply chain. In those circumstances the other parties involved do not receive the documents that represent ownership of the commodities and consequently are not empowered actually to dispose of those goods as if they were their owner. In such case, in principle the other parties necessarily render services to each other. However, we feel that there are situations in which the settlements by the other parties (of the differences between their sales prices and the ‘by pass’ price) could possibly qualify as cash settlements not subject to VAT. This is to be further established on a case by case basis.

Way forward

In order to assess the potential impact of the Fast Bunkering Klaipėda case and the working paper from the Commission Services, we recommend companies to investigate whether they are involved in supply chains whereby the transfer of legal ownership of the underlying goods takes place at the same time as or after the disposal of the actual ownership. If so, a more detailed analysis is required to identify possible issues and establish possible work-arounds. We are happy to assist you in this respect.
Further guidance is to be expected when the delegates of the EU Member States / VAT Committee have given their opinion on the issues raised.

Legal status

Although this working paper and the expected guidelines of the VAT Committee on the basis thereof are no legally binding decisions, they provide guidance on the application of the VAT Directive. It is our experience that EU Member States use such guidance as a starting point for taking their individual position. We will of course inform you accordingly once the view of the VAT Committee has been published.

Renewed definition of supplies of goods in chain transactions which involve intermediaries

Patricia More
Partner, Indirect Tax
+41 58 792 95 07
patricia.more@ch.pwc.com

Julia Sailer
Director, Indirect Tax
+41 58 792 44 57
julia.sailer@ch.pwc.com

EUDTG Newsletter July – August 2016

EU direct tax law is a fast developing area. This presents taxpayers, in particular groups and multinational corporations that have an EU or European Economic Area (EEA) presence, with various opportunities.

The following topics are covered in this issue of EU Tax News:

CJEU Cases

  • Denmark: CJEU referrals on the concept of beneficial ownership and abuse in the Parent-Subsidiary and Interest and Royalty Directives
  • Finland: CJEU referral on the compatibility of the tax treatment of transfers of assets with EU law: A Oy
  • Germany: CJEU referral on the German cross-border arm’s length legislation in light of the SGI case
  • Netherlands: CJEU referral on the compatibility of the Dutch fiscal unity regime with EU law

National Developments

  • Austria: Austrian Ministry of Finance Opinion on access to goodwill amortization for EU/EEA group members
    PwC EU Tax News 2
  • Germany: Final Fiscal Court judgment on the German gift and inheritance tax allowance: Hünnebeck
  • Hungary: Amendments to Hungarian corporate income tax legislation
  • Norway: EFTA Surveillance Authority letter of formal notice on Norwegian interest cap rules
  • United Kingdom: First Tier Tribunal finds that manufactured overseas dividend rules do not breach EU law

EU Developments

  • EU: ECOFIN Council adoption of ATAD on 12 July 2016
  • EU: European Commission proposes new transparency rules and next steps to tackle terrorism financing, money laundering, and tax avoidance
  • EU: European Parliament’s TAXE II report adopted
  • EU: European Parliament’s Panama Papers Inquiry Committee

Fiscal State aid

  • Belgium: European Commission decides Belgian Diamond Tax Regime does not constitute State aid
  • EU: US Treasury White Paper on European Commission’s State aid investigations into transfer pricing rulings
  • Gibraltar: European Commission publishes its Oct. 2014 Decision to extend Gibraltar State aid investigation to include rulings
  • Hungary: European Commission finds Hungarian food chain inspection fee and tobacco sales tax in breach of EU State aid rules
  • Ireland: European Commission finds Ireland has granted unlawful State aid to Apple
  • Luxembourg: European Commission opens formal State aid investigation into Luxembourg’s tax treatment of GDF Suez (now Engie)
  • Norway: EFTA Surveillance Authority approves accelerated tax depreciation rules for wind power plants
  • Poland: European Commission opens formal State aid investigation into Poland’s tax on the retail sector
  • Spain: European Commission’s final Decisions on State aid to certain Spanish professional football clubs

This EU Tax Newsletter is prepared by members of PwC’s international EU Direct Tax Group (EUDTG).

Read the full newsletter here.

Further information about our service offerings in EU taxes: www.pwc.com/eudtg