Braxton Real Estate Funds legal services
Our legal team is available to answer your questions about Property Funds legal issues, including:
Key Trends and Evolution in the Real Estate Investment Fund Market
How is the REIF Market Affected by New Regulatory Environment on a Cross-border Basis?
SEC Registration and Compliance – Scope – Key Feature - How to Handle and Speed-up the Process to Ensure On-time Compliance?
European Real Estate Market in Perspective and in Comparison with Luxembourg
Real Estate as an Asset Class in Portfolio Composition – Assessing the Outlook for the Property Fund Market
Recap on Custody Requirements for Real Estate Fund Assets including Financial Instruments & Real Assets under AIFMD & Dodd Frank/SEC Registration
How to formalize Risk Management Procedures to Meet AIFMD Requirements?
How to Identify, Monitor and Control Risks that trigger Liquidity & Financing Problems?
How the New German Open-ended Real Estate Fund Legislation is Seeking to Restore Investor’s Confidence?
Valuation Process, Valuer Selection, Monitoring & Liability Issues for REIFs
How to Document Delegated Activities and Duties? Process – Monitoring - Reporting
Luxembourg Real Estate Servicing Platform & Fund Administration Panel Session:
How to Reassess the Operating Model & Additional Service Offering to Comply with AIFMD?
Solvency II – Impact of the Directive on Real Estate Property Funds and Allocation to Real Estate Assets
European Real Estate Market in Perspective and in Comparison with Luxembourg
The Braxton Team
Thursday, February 24, 2011
Monday, February 14, 2011
European Union Direct Taxes
Permanent Establishment is a vital concept in international taxation. While for direct taxes, it is mainly defined by the OECD Model Convention, the European VAT Directive and its implementing Regulation provide an EU-wide approach for VAT.
Difficulties arise as terminology and definitions in indirect and direct tax diverge. Moreover, countries have implemented and interpreted the EU and OECD rules in a different way, impacting on issues like cross-border reorganisations, transfer pricing, taxation of dividends and interest and royalties, tax residence, temporary and permanent transfer of assets, place of supply and VAT liability.
In both direct and indirect tax, the concept of Permanent Establishment has undergone very recent changes: The 2010 changes to the OECD Model Convention and Commentary, and in particular the new Art. 7, will be adopted in national law, as speakers from the Netherlands and Germany will report. The effect of the new definition on treaties with other countries will also be considered.
Some of this topic is addressed in the new book "European Union Direct Taxes", by the International Tax Professor Salvador Trinxet Llorca.
In indirect tax, the current more important issue is the practical consequences of the adoption of the Regulation implementing the EU VAT Directive in January 2011.
Difficulties arise as terminology and definitions in indirect and direct tax diverge. Moreover, countries have implemented and interpreted the EU and OECD rules in a different way, impacting on issues like cross-border reorganisations, transfer pricing, taxation of dividends and interest and royalties, tax residence, temporary and permanent transfer of assets, place of supply and VAT liability.
In both direct and indirect tax, the concept of Permanent Establishment has undergone very recent changes: The 2010 changes to the OECD Model Convention and Commentary, and in particular the new Art. 7, will be adopted in national law, as speakers from the Netherlands and Germany will report. The effect of the new definition on treaties with other countries will also be considered.
Some of this topic is addressed in the new book "European Union Direct Taxes", by the International Tax Professor Salvador Trinxet Llorca.
In indirect tax, the current more important issue is the practical consequences of the adoption of the Regulation implementing the EU VAT Directive in January 2011.
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