Financial Services VAT Alert. Tracking EU VAT Developments

Transcription

1 Financial Services VAT Alert Tracking EU VAT Developments April 2012 Edition 2012/4

2 Editorial Dear readers, Hereby we present the April edition of the FS VAT Alert. In this edition you will find the most important VAT developments that have occurred over the past month. Especially interesting in our view, is the dismissal of the Commission Proposal for an EU Directive on Financial Transactions Tax. Enjoy reading! Contents EUROPEAN UNION 1. ECJ rules pre-registration input VAT recoverable 2. Commission Proposal for EU Directive on Financial Transactions Tax dismissed CZECH REPUBLIC 3. Draft legislation on 2013 invoicing changes GERMANY 4. German treatment of the cost sharing exemption GREECE 5. New procedure for processing VAT refunds ITALY 6. Proposed tax and VAT reform project LUXEMBOURG 7. VAT audits in the financial sector NETHERLANDS 8. Latest Dutch austerity measures agreed: VAT increase from 19% to 21% per October Transfer of insurance portfolio qualifies as a transfer of a going concern 10. Provision of 'leads' VAT exempt 11. Point of view of the Dutch Tax Authorities regarding VAT consequences of prohibiting fees for insurance mediation POLAND 12. Risk assessment and monitoring services are VAT exempt services 13. Financial intermediary services are VAT exempt services 14. Bank is entitled to include the result on derivatives transactions in its pro rata calculation in every calculation period 15. Activities performed by companies, being a part of the Cash Pooling structure, cannot be treated as services within the meaning of the Polish VAT Act 16. Amounts transferred to the lesser after the termination of the lease contract are the usual payments for leased object delivery SWITZERLAND 17. Federal Tax Administration published interpretation of the notion of intermediary UNITED KINGDOM 18. HMRC issues draft guidance on implementing the cost sharing exemption 2 of 13

3 EUROPEAN UNION 1. ECJ rules pre-registration input VAT recoverable The ECJ has held that input VAT incurred before formal registration of a partnership, and before the partnership became VAT registered, can be recovered if such VAT relates to the taxable activities of the partnership but was invoiced before the partnership existed. Background This case concerns the recovery of input VAT by partners investing in a property partnership, in circumstances where the VAT on two invoices was invoiced to them as individuals rather than to the partnership. Judgment The ECJ considered that by applying the principle of neutrality, the VAT cost of a first investment incurred for the purpose of commencing a business must be regarded as a cost of that economic activity. Therefore the input VAT incurred in the course of establishing that economic activity should be allowed. The ECJ held that even if the invoice issued by a taxable person does not meet some of the formal requirements but if the substantive requirements are satisfied, the deduction of the input VAT should be allowed. It followed the Commission's opinion that the partnership should be permitted deduction provided that, viewed objectively; the costs were incurred with the intention that they would be used by the partnership in making taxable supplies frans.oomen@nl.pwc.com 2. Commission Proposal for EU Directive on Financial Transactions Tax dismissed During the ECOFIN, the Commission proposal for a European Directive on Financial Transactions Tax (FTT) was dismissed. There is now agreed that a special working group led by Germany will look into this study. There appears to be no consensus among the EU Member States on the proposed approach. In particular, the United Kingdom, Sweden, and also the Netherlands, were against the proposals of the Commission from the beginning. There is now an alternative presented by Germany that aims to create a broader base for the FTT in Europe. This is done in a German non-paper in which a European-wide stamp duty on share issuances is proposed. Further enhancing in the longer term is laid down in an additional proposal which also includes a stamp duty on for example, bonds and derivatives. The proposal is partly based on the existing English version and in February adopted French FTT bill (enters in to force in France by August 2012). It has been proposed to report to ECOFIN in June Also see our VAT study in this context which indirectly may have affected the decision of the Commission: frans.oomen@nl.pwc.com 3 of 13

4 CZECH REPUBLIC 3. Draft legislation on 2013 invoicing changes An amendment to the VAT Act addressing the changes being introduced by the new EU Invoicing Directive (effective 1 January 2013) has been released for consultation. The most significant changes to be introduced by the VAT Act amendment from 2013 relevant for the FS Industry, are the changes relating to the exemption of insurance activities. The amendment replaces the terms "insurance or reinsurance activities" with the more accurate terms "provision of insurance" and "provision of reinsurance" limiting the scope of exemptions strictly to provision of these services. In case of related activities, including insurance and reinsurance intermediation, the exemption will apply only to services provided by insurance intermediaries. Activities concerning the insurance claims settlement will be excluded from the exemption. Pension insurance schemes and its intermediation will be moved to the new Section 54 and shall remain VAT exempt. Martin Divis martin.divis@cz.pwc.com GERMANY 4. German treatment of the cost sharing exemption Federal Audit Court complains about preliminary practice of tax authorities to accept VAT exemptions for sharing costs of services for loan administration for regional savings banks. Although meanwhile formally requested by the EU Commission Legislation in Germany has still not succeeded in amending its VAT legislation to extend the scope of the cost sharing exemption (please compare FS VAT Alert April 2011). Respective amendment bills had already been issued and remitted to the German Parliament but did not pass. With respect to one of these amendment bills in 2008 the German Ministry of Finance already granted quite a generous administrative rule accepting cost sharing exemption for administration of loans following a respective request of regional saving banks beforehand in sight of the expected amendment. Now the Federal Audit Court focuses on this official ruling and complains a loss of tax revenue which in its opinion is not justified by formal act of parliament. In the view of the Audit Court granting the VAT exemption qualifies as an unjustified tax subvention. The Federal Ministry of Finance is now officially requested to stop this practice. We should point to the fact that the Federal Audit Court is responsible to review whether costs spent by official authorities and government are reasonable but has, however, no competence to justify whether the qualification of such tax treatment like in the case at hand is in line with the tax law. In so far it is notable that the Audit Court did obviously also not recognize whether the taxpayer should already be entitled to apply such VAT exemption based on binding EU Law. Elmar Jaster elmar.jaster@de.pwc.com GREECE 5. New procedure for processing VAT refunds Businesses which incur VAT in Greece should be aware of changes to the procedures for processing applications for refunds of VAT from Greece which were announced recently. 4 of 13

5 The most significant changes to be introduced by the VAT Act amendment from 2013 are as follows: Applications are submitted electronically through Taxisnet; Such applications will be processed based on chronological order; For amounts in excess of 100,000 Euro a provision audit must take place in any case, whilst for smaller amounts audits may be ordered based on a risk-based approach; It is stipulated that the audit must be concluded within 2 months, unless it is considered that a regular audit must follow; The order for payment must be issued within one month from conclusion of the audit; For amounts in excess of 300,000 Euro where Ministerial approval is granted in accordance with art. 32 of L. 3220/2004, it is stipulated that payment must be made within 4 months from the registration of the order in the respective refund books held by the tax office; After the lapse of the payment deadline stipulated in the Decision, the liability is considered due and payable. Note: this may be of practical importance with respect to set-off claims; However, the Decision in question does not appear to resolve several issues that relate to delays experienced in VAT refunds, since: It does not provide for any consequences in case the audit is not concluded within the provided timeline; Many of the provisions of the Decisions are made subject to fiscal restrictions ; No clear process is provided for pending claims. PwC remains at your disposal for any support regarding the pertinent issues. Mary Psylla mary.psylla@gr.pwc.com ITALY 6. Proposed tax and VAT reform project Under a new draft Decree, the Italian Government will be appointed to prepare a package of tax reforms including a review of the penalties regime and a revised VAT grouping procedure to bring the Italian grouping rules in line with the VAT Directive. According to a Decree which has yet to be approved, the Italian Government will be appointed to prepare a package of tax reforms in Italy. Based on the information available so far, the tax reform would involve, among other things, the implementation of the VAT grouping procedure as described in the recast VAT Directive. Currently, under the 'Italian VAT grouping' procedure, the VAT settlement of group companies can be done together, but they maintain their full independence as taxable person (e.g., they have to submit their own returns) and inter-company transactions follow the ordinary VAT rules. On the basis of the recast VAT Directive, group companies would be regarded as a single taxable person for VAT purposes. This would have a relevant impact especially for those companies with limited input VAT deductibility - such as financial entities. Alessia Angela Zanatto alessia.angela.zanatto@it.pwc.com 5 of 13

6 DID YOU KNOW? ITALY Filing deadline for financial institutions 'e-money' declaration postponed to 15 October 2012 The deadline for the communication of the transactions relevant for VAT purposes of an amount equal to or greater than 3,600 euro to be submitted by financial institutions established in Italy or with a fixed establishment in Italy has been postponed from 30 April 2012 to 15 October Alessia Angela Zanatto alessia.angela.zanatto@it.pwc.com LUXEMBOURG 7. VAT audits in the financial sector On 1 January 2011, the Luxembourg VAT administration was reorganised in specialised VAT offices. For more than one year now, VAT tax office number 3 has become competent for the financial sector. Since then, taxpayers have been experiencing an increasingly number of VAT audits. Most of these audits are not on-site. This is our point of view, based on our experience, on how tax payers can prepare for VAT audits. The VAT authorities request detailed information on operations, income and expenses and perform remote controls. In the financial sector, the most frequent items checked are: Correct application of VAT exemptions and existence of supporting documentation; Correct reporting of reverse charged VAT; Method used to determine the proportion of recoverable VAT; Link between expenses and specific activities when full deduction is applied. Being able to quickly and efficiently react to audits requires that appropriate documentation and explanation on the VAT treatment of transactions exists and is kept at the taxpayers' premises. A good tool for managing VAT audits consists in having a well organised accounting system using resourceful software with VAT coding allowing to easily identify the nature of transactions (VAT exempt, subject to reverse charged Luxembourg VAT, etc.). Too often, investment funds, asset managers, insurance undertakings and holding companies struggle to find the information that will serve as evidence. Returns and accounts are still difficult to reconcile; information is spread among various departments; persons in charge of VAT management are not regularly trained; VAT manuals when they exist are not updated. VAT audits therefore remain a challenge and may lead to material reassessment and provisions. PwC assists clients in coping with questions from the authorities and ensures that the VAT control process is dealt with smoothly. PwC's assistance in setting up VAT coding and ensuring that all appropriate documentation is available for potential controls proves very efficient for reducing risks of controls and saving time and effort in controls. Frédéric Wersand frederic.wersand@lu.pwc.com 6 of 13

7 NETHERLANDS 8. Latest Dutch austerity measures agreed: VAT increase from 19% to 21% per October 2012 Yesterday, a majority in Dutch parliament agreed with a package of proposed austerity measures. Part of these measures is the increase of the standard VAT rate from 19% to 21%. This proposed increase should take effect from 1 October Under the same agreement, performing arts, which were subject to the standard VAT rate since July 2011, are transferred back to the 6% reduced VAT rate. For businesses, this means that they should prepare for these changes. The VAT rate increase may affect the pricing of products, but will also lead to a higher cost for businesses that cannot fully reclaim input VAT. The proposed changes will also have to be included in the businesses bookkeeping systems. We expect that transitional measures will be introduced, which will probably be comparable to the transitional measures introduced with regard to previous changes of the VAT rates. Under these transitional measures, the tax point is based on the time of the actual supply. As a result, possible VAT advantages created by payments made before the VAT increase for supplies made after the VAT increase are undone. These earlier transitional measures also address, for example, real estate projects that have commenced before the VAT increase and that are completed after the VAT increase. We would advise businesses to discuss the impact of this VAT increase with their PwC VAT adviser. Jeroen Bijl jeroen.bijl@nl.pwc.com 9. Transfer of insurance portfolio qualifies as a transfer of a going concern The Court of Appeal ruled with reference to the ECJ judgment Christel Schriever that the fact that the legal title of an insurance portfolio has not been transferred, is not a decisive factor in determining whether the transfer of a going concern treatment for VAT is applicable. Background In 1987 an association entered into a joint venture with company X. The association contributed their insurance portfolio, while maintaining the title, into the joint venture, and X contributed its knowledge, labor and diligence. Based on the joint venture agreement the association annually receives 40% of the mediation commission that X receives from insurance companies. As through the years the association did not pay VAT on the received commissions from X, the Dutch Tax Authorities imposed a reassessment. Judgment The association claims that the annual commission which it receives from X, results from the transfer of the insurance portfolio back in 1987 (even though the legal title of the portfolio remains with the association) and is therefore outside the scope of VAT based on the transfer of a going concern treatment. The Court of Appeal ruled in favor of the association, stating that the fact that the legal title of the insurance portfolio has not been transferred, is not a decisive factor in determining whether the transfer of a going concern treatment is applicable. Therefore, the annual commission which the association receives from X is exempt from VAT frans.oomen@nl.pwc.com 7 of 13

8 10. Provision of 'leads' VAT exempt The Court of Appeal ruled that the provision of 'leads' by an intermediary, to providers of financial products, is VAT exempt. Background In this case, a company operated a website where potential consumers could compare financial products. The data of the potential consumers were made available, against payment, to selected credit providers. After payment these credit providers were able to contact these potential consumers. Judgment The Court of Appeal ruled that the most decisive factor for application of the exemption for services consisting of negotiation of credit is that the negotiation activity must be aimed at enabling two parties, the potential consumer and the credit provider, to reach an agreement. The negotiation service may be limited to pointing out the opportunity to conclude an agreement with the credit provider. On these grounds the mediation activities of the company were considered exempt by the Court, as they fell within the scope of the relevant exemption. The judgment confirms that until now the interpretation of this exemption by the Dutch tax authorities has been too restricted. We doubt that the exemption would be applicable in cases where a company sells client information or merely includes a simple link to a financial services provider's website on its own website for consideration. In those cases, it can be questioned whether the company is actually doing all that is necessary in order for two parties to enter into a contract frans.oomen@nl.pwc.com 11. Point of view of the Dutch Tax Authorities regarding VAT consequences of prohibiting fees for insurance mediation Currently insurance agents in the Netherlands are rewarded for their work through commission fees payable by financials, at the conclusion of insurance and financial products. Based on current proposals, on 1 January 2013 commission fees prohibition on complex financial products will apply. In most situations, as per 2013, a fee will be paid by the customer to the intermediary. The Dutch Tax Authorities have taken the view that the VAT exemption for negotiation for financial services remains applicable even if the remuneration for the mediation service is paid by the customer directly to the intermediary. In addition, the Dutch Tax Authorities has formulated practical ground rules on the application of the VAT exemption due to changes of reward modules. In outline, the Dutch Tax Authorities formulated the following ground rules: In situations where a financial intermediary is consulted by a customer just for independent advice, so without having the intention to conclude a financial product through that intermediary (e.g. in the case of a mere second opinion), the VAT exemption does not apply; Where the advice of a financial intermediary also relates to an existing or to yet to conclude financial product, this advice is VAT exempt. Even if no sales agreement is concluded; 8 of 13

9 A written assignment/agreement (or an appearance thereof) counts as evidence for proving the purpose of the service of the financial intermediary. If it shows that the consumer has no intention of concluding a financial product through that intermediary, the VAT exemption does not apply. If at any time any changes to relevant legislation and/or regulations are implemented, these ground rules may also change frans.oomen@nl.pwc.com POLAND 12. Risk assessment and monitoring services are VAT exempt services The Court ruled that risk assessment and monitoring services are VAT exempt services. Background A Bank renders risk assessment and monitoring services for the benefit of financial institution operating within our Client s capital group. The Bank asked the Ministry of Finance whether such services should be exempt from VAT under Polish VAT Law. In the tax ruling issued for the Bank the Ministry has stated that such services should be taxed with standard VAT rate as they are not essential for completing an exempt transaction (granting a credit). The Bank has decided to prepare a complaint to the Administrative Court in Wroclaw. Marcin Chomiuk marcin.chomiuk@pl.pwc.com 13. Financial intermediary services are VAT exempt services The Court ruled that financial intermediary services are VAT exempt services. Background A Bank carries out services which consist of intermediation in sale of financial products (granting a credit) by a financial institution from Bank s capital group. The aim of these services is to do all that is necessary in order for two parties to enter into a credit agreement. The scope of these services includes also some administrative activities. The Bank asked the Ministry of Finance whether all activities carried out by the Bank constitute a composite supply of services which is VAT exempt. The Ministry has stated that only part of these activities should be VAT exempt. The Bank has lodged a complaint to the Administrative Court in Wroclaw. Judgment Recently, the judgment has been issued, in which the Court has stated that all activities carried out by the Bank constitute a composite supply of services which is VAT exempt (only verbal reasons for the judgment are known at the moment). Marcin Chomiuk marcin.chomiuk@pl.pwc.com Judgment Consequently, it has been stated by the Court that services rendered by the Bank should be VAT exempt (only verbal reasons for the judgment are known at the moment). 9 of 13

10 14. Bank is entitled to include the result on derivatives transactions in its pro rata calculation in every calculation period Recently a 3 year tax dispute regarding pro rata calculation has finally ended. A Bank applied for a binding ruling to confirm that with respect to derivatives operations as a taxable base should be considered result on all transactions of the same kind in reconciliation period. Such approach has been challenged by the Polish tax authorities and a negative ruling has been issued. The Bank took steps to change the negative ruling. During the dispute 2 of 3 rulings have been lifted by the Administrative Court. Third ruling received by the Bank is positive. On the basis of the ruling the Bank is entitled to include the result on derivatives transactions in the pro rata calculation calculated in the following way: R = (a + b + c) - (d + f + g) a, b, c stands for inflow payments (e.g. premiums received, amounts of the contracts reconciliation received) and d, f, g stands for outflow payments (e.g. premiums paid, amounts of the contracts reconciliation paid). The importance of this ruling is that the result is to be calculated for every reconciliation period (month or quarter) separately for different types/categories of derivatives. Marcin Chomiuk Marcin.chomiuk@pl.pwc.com 15. Activities performed by companies, being a part of the Cash Pooling structure, cannot be treated as services within the meaning of the Polish VAT Act A Bank renders Cash Pooling services aimed at improving financial liquidity and reducing external financing costs for capital group member companies. The Bank asked the Ministry of Finance whether activities he performs in order to supply Cash Pooling service constitute one composite financial service which is exempt from VAT under Polish VAT provisions. In the tax ruling issued for the Bank the Ministry confirmed the aforementioned view. Consequently, according to the Ministry, the members of Cash Pooling structure do not provide services in favor of the Bank (since it is the Bank who renders the complex Cash Pooling service). However, the Ministry stated that the ruling does not determine the relations between companies involved in the Cash Pooling structure. Marcin Chomiuk marcin.chomiuk@pl.pwc.com 16. Amounts transferred to the lessor after the termination of the lease contract are the usual payments for leased object delivery The Polish Supreme Administrative Court ruled that amounts transferred to the lessor after the termination of the lease contract, are the usual payments for the leased object delivery. Delivery of goods is subject to VAT at the moment of release of the leased object. 10 of 13

11 When the lease contract is terminated due to a loss, destruction or irrepairable damage to the leased object, lease is committed to settle the remaining owed payments. The payable amount is reduced by damages received from an insurer. Although the contract is terminated the amounts transferred to the lessor are the usual payment which is a part of financial lease contract. The Polish Supreme Administrative Court has stated that lessor is committed to charge relevant VAT amounts from all payments. Marcin Chomiuk marcin.chomiuk@pl.pwc.com SWITZERLAND 17. Federal Tax Administration published interpretation of the notion of intermediary The Federal Tax Administration s ( FTA ) VAT division has published VAT info for Finance, which is important for the entire Swiss financial sector. This publication deals with the qualification of services in the financial sector. The publications describes the following changes for the financial sector: Treatment of services combinations (70% rule); Adjustments for services to oneself, in particular in case of services to staff members; New interpretation of the notion of intermediary. The most significant change compared to the practice prevailing under the former VAT law resides in the interpretation of the notion of intermediary. In principle, an intermediary s fee should relate to the turnover that was brought in. So a loan intermediary would not have to pay taxes on the commission he receives from a Swiss bank for the clients he brings in. From the FTA s point of view, however, financial attributions to the intermediary that underlie the payment duty should be taxed, as in such cases the businesses brought in are in the intermediary s own interest. The FTA has not established any clear definition of what the activity of an intermediary entails, which means that the new administrative practice leaves some room for interpretation in each case. The new definition of the notion of intermediary, however, does not bring any change in the taxation of distribution and portfolio maintenance compensation in connection with collective investments. This continues to be exempt from VAT, without any right to deduct input VAT. We recommend that banks examine if VAT is mentioned erroneously on invoices and credit notes in spite of being intermediary services excluded from VAT. In such cases there is a need to act. The new FTA practice could also have consequences on the calculation of a bank s deductible input tax, regardless of whether it is determined by means of the lump sum for banks or by directly attributing the input tax to the relevant turnover. Tobias Meier Kern tobias.meier.kern@ch.pwc.com UNITED KINGDOM 18. HMRC issues draft guidance on implementing the cost sharing exemption HMRC has issued 'VAT: Cost Sharing Exemption Guidance - Draft' for comment by stakeholders, i.e. those organisations which responded to the consultation exercise which took place in HMRC requires further responses by 18 May of 13

12 Some of the more significant features of the draft guidance are as follows: A cost sharing group (CSG) can include non-uk members, and a UK organisation can be a member of a non- UK CSG; A CSG must have a legal form capable of being VAT registered and, subject to the normal rules, it can be a member of a VAT group, but a VAT group cannot be a CSG member; A CSG can be a group of equal members, but it can also be controlled by one member, e.g. if one member holds more than 50% of its shares (in which case it would be eligible for VAT grouping); A CSG can have a mixture of exempt 'at cost' supplies to its members and taxable 'for profit' supplies to non-members; A charity or unincorporated association could be a CSG; If it recruits members by recommendation, invitation or word of mouth and does not compete for business in the open market with 'for profit' businesses, a CSG will not distort competition; The CSG, not its members, is responsible for its own VAT affairs but, as it relies on what its members do to obtain exemption, it should be able to demonstrate that the members qualify to receive exempt services; To become a member, an organisation must have, or expect to have at least 5% exempt or non-business activity; and must fulfil that intention within 12 months to stay a member; 'Directly necessary' supplies are those which are 'directly attributable' to exempt and/or non-business activities, so if a member has no taxable activity, or only negligible (15% or less) taxable activity, all supplies by the CSG will be exempt; HMRC may permit the 15% test to apply to a sector or part of a member organisation; 'Exact reimbursement' means there must be no profit element at all, and there must be a clear audit trail to prove it; and A CSG can raise funds to enable it to operate, and it may run periodically in surplus or deficit, but exemption will only apply if accounting shows that, over a reasonable period, exact reimbursement is achieved. HMRC refers to infraction proceedings by the European Commission against Member States which are considered to have applied the exemption beyond what is permitted in the Principal VAT Directive, and sensibly warns that the scope of the UK exemption might have to be reconsidered if the outcome is adverse for those Member States. It is likely that further guidance will be needed as CSGs and the scope of the exemption develop. It appears that CSGs and their members will have to work closely together to ensure that the correct liabilities are applied. In particular, it appears that members could, based on the current proposed guidance, be entitled to enjoy exempt supplies on some occasions but, if their circumstances change, they could lose that entitlement, and possibly regain it, but it is the CSG which will be responsible for applying the correct VAT liability. Jamie Randell jamie.t.randell@uk.pwc.com 12 of 13

13 Contact For more information, please do not hesitate to contact your local PwC Indirect Tax expert or one of the experts mentioned below: Austria Christoph Wagner tel: christoph.wagner@at.pwc.com Belgium Koenraad de Bie tel: koenraad.de.bie@pwc.be Bulgaria Nevena Haygarova tel: nevena.haygarova@bg.pwc.com Cyprus Chrysilios Pelekanos tel: chrysilios.pelekanos@cy.pwc.com Czech Republic Martin Diviš tel: martin.divis@cz.pwc.com Denmark Jan Huusmann Christensen tel: jan.huusmann.christensen@dk.pwc.com Estonia Tanja Kriisa tel: tanja.kriisa@ee.pwc.com Finland Juha Laitinen tel: juha.laitinen@fi.pwc.com France Stéphane Henrion tel: stephane.henrion@fr.pwc.com Germany Felix Becker tel: felix.becker@de.pwc.com Greece Mary Psylla tel: mary.psylla@gr.pwc.com Hungary Tamas Locsei tel: tamas.locsei@hu.pwc.com Ireland John Fay tel: john.fay@ie.pwc.com Italy Alessia Angela Zanatto tel: alessia.angela.zanatto@it.pwc.com Latvia Ilze Rauza tel: ilze.rauza@lv.pwc.com Lithuania / Belarus Kristina Krisciunaite tel: kristina.krisciunaite@lt.pwc.com Luxembourg Marie-Isabelle Richardin tel: marie-isabelle.richardin@lu.pwc.com Malta David A. Ferry tel: david.ferry@mt.pwc.com The Netherlands tel: frans.oomen@nl.pwc.com Norway Yngvar Engelstad Solheim tel: ynvar.solheim@no.pwc.com Poland Marcin Chomiuk tel: marcin.chomiuk@pl.pwc.com Portugal Mario Braz tel: mario.braz@pt.pwc.com Romania Diana Coroaba tel: diana.coroaba@ro.pwc.com Slovakia Valeria Kadasova tel: valeria.kadasova@sk.pwc.com Slovenia Marijana Ristevski tel: marijana.ristevski@si.pwc.com Spain Miguel Blasco tel: miguel.blasco@es.landwellglobal.com Sweden Lars Henckel tel: lars.henckel@se.pwc.com Switzerland Tobias Meier Kern tel: tobias.meier.kern@ch.pwc.com United Kingdom Jamie Randell tel: jamie.t.randell@uk.pwc.com United States Evelyn G Lam tel: evelyn.g.lam@us.pwc.com Disclaimer. Clients receiving this Alert should take no action without first contacting their usual PwC Indirect Taxes Advisor. This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PwC, its members, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it. PwC firms provide industry-focused assurance, tax and advisory services to enhance value for their clients. More than 161,000 people in 154 countries in firms across the PwC network share their thinking, experience and solutions to develop fresh perspectives and practical advice. PwC is the brand under which member firms of PricewaterhouseCoopers International Limited (PwCIL) operate and provide services. Together these firms form the PwC network. Each firm in the network is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services to clients. PwCIL is not responsible or liable for acts or omissions of any of its member firms nor can it control the exercise of their professional judgment or bind them in any way. 13 of PricewaterhouseCoopers Belastingadviseurs N.V.(KvK ). All rights reserved.