Tax implications of Brexit - Update

After three and a half years of tough negotiations hat das United Kingdom Nun 31 January 2020 die Leave the European Union. Even if in the United Kingdom no stone remains upon another, at least tax-related Essentially for now all's the same. The EU has agreed a transitional arrangement with the British, whereby the United Kingdom bis to 31.12.2020 How one EU Member State is dealt with. After that, the UK will likely become Third country and leaves the European Union's single market and customs union. Tax implications thus only enter from 1 January 2021 The most important changes are briefly summarised below:

Income tax-wise falls es im Falle eines Departure to the United Kingdom Immediate taxation (of the silent reserves). Accordingly, an application for instalment payments can no longer be made in the operational area. This applies to all operational cases of departure pursuant to Section 6 item 6 EStG, which upon expiry of the transition period take place. Furthermore, for companies, the provisions of the directive will lapse from 1 January 2021. Parent-subsidiary directive, the Interest and Licensing Fee Policy and the Fusion Directive. Here it jumps new Double taxation agreement with the United Kingdom stepping in, which already since 1 January 2020 applicable. Accordingly, in the case of Dividends one Withholding tax exemption A stake of at least 10%iger is envisaged. At present, there are no plans (as yet) to levy withholding tax on interest and licence fees in the UK. However, this could be changed by the UK legislature.

VAT remain in the transition period also further Intra-Community supplies of goods and receive benefits. Special provisions In the area of VAT and customs law, there will be zero-rated supplies for export and import that commence before the end of the transition period but end after its expiry. Furthermore, it should be noted that VAT refund applications by (the) latest 31 March 2021 must be asked.

In the transition period, a Free trade agreement to be negotiated with the EU based on the Canadian model. Further developments remain to be seen.

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