Changes are proposed to Hong Kong’s profits tax exemption for privately offered funds which will:
- unify the profits tax exemptions for privately offered funds (onshore or offshore, regardless of their structure, location of central management and control, their size, or the purpose they serve) into one comprehensive regime; and
- significantly widen the application scope of the profits tax exemption.
See here for more information.
More commercial property transactions are likely to be subject to VAT (rather than Civil Law Activities Tax) as a result of new guidelines issued by the Polish authorities.
In December 2009, Germany introduced an exemption from Real Estate Transfer Tax (RETT) for group restructurings.The exemption was challenged in the case of an upstream merger as infringing the State aid rules.
The CJEU found that although there was technically state aid, it could be justified "by the nature or general scheme of the German tax system and the intention of the German provision to prevent double taxation" (it being assumed that RETT had already been paid by the group).