Tax

As local and international tax regulations become more prescriptive, dealing with them in a cross-border context presents you with a significant challenge. Our 350 tax lawyers are supported by strong technical tax intelligence teams that identify developments in tax law and policy affecting your business. This multi-disciplinary approach helps you develop robust structures that maximise tax effectiveness in alignment with your commercial strategy.

Whether you are a financial institution, multinational, fund, investor or high net worth individual, we understand your business and the tax pressures you face. Our teams work together across Europe and beyond in the key areas affecting your business including VAT, international taxation, transfer pricing, e-commerce, M&A and investment funds, tax planning and financing.

Our experts can help you manage tax control cases and deal with tax authorities as well as manage tax litigation cases. The right tax advice can make a material difference to transaction costs and, in some cases, avert serious consequences.


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20/05/2022
DEBRA – The new EU tax ini­ti­at­ive aim­ing at pro­mot­ing a fair and sus­tain­able...
With­in the EU a wide­spread asym­metry ex­ists between debt and equity fin­an­cing. Usu­ally, in­terest is tax de­duct­ible from the cor­por­ate in­come tax base while di­vidends do not be­ne­fit from such ad­vant­age...
28/03/2022
Ger­many: Cross-bor­der em­ploy­ee as­sign­ments - li­ab­il­ity for wage tax?
The de­cis­ive factor for wage tax li­ab­il­ity in the in­ter­na­tion­al as­sign­ment of em­ploy­ees is not who pays the wage. For the em­ploy­ee, the ques­tion is: in which coun­try must the in­di­vidu­al pay tax on his...
14/02/2022
Con­sequences of the Court of Justice of the European Uni­on rul­ing on the...
The Court of Justice of the European Uni­on (here­in­after, “CJEU”) has de­clared the gen­er­al rules on pen­al­ties for tax of­fences re­lated to the in­form­at­ive de­clar­a­tion of over­seas as­sets and rights ...
03/02/2022
Tax treaty between France and Colom­bia: Fi­nally entered in­to force!
France has an ex­tens­ive net­work of tax treat­ies in Lat­in Amer­ica. However, Colom­bia was still a coun­try with which France had no tax treaty entered in­to force, des­pite a tax treaty be­ing signed back in...
10/01/2022
CMS Next
What’s next? In a world of ever-ac­cel­er­at­ing change, stay­ing ahead of the curve and know­ing what’s next for your busi­ness or sec­tor is es­sen­tial.At CMS, we see ourselves not only as your leg­al ad­visers but also as your busi­ness part­ners. We work to­geth­er with you to not only re­solve cur­rent is­sues but to an­ti­cip­ate fu­ture chal­lenges and in­nov­ate to meet them.With our latest pub­lic­a­tion, CMS Next, our ex­perts will reg­u­larly of­fer you in­sights in­to and fresh per­spect­ives on a range of is­sues that busi­nesses have to deal with – from ESG agen­das to re­struc­tur­ing after the pan­dem­ic or fa­cing the di­git­al trans­form­a­tion. We will also share with you more about the work that we are do­ing for our cli­ents, help­ing them in­nov­ate, grow and mit­ig­ate risk.To be able to provide you with the best sup­port, we im­merse ourselves in your world to un­der­stand your leg­al needs and chal­lenges. However, it is equally im­port­ant that you know who we are and how we can work with you. So, we in­vite you to meet our ex­perts and catch a glimpse of what is hap­pen­ing in­side CMS.En­joy read­ing this pub­lic­a­tion, which we will up­date reg­u­larly with new con­tent.CMS Ex­ec­ut­ive Team
23/12/2021
Min­im­um tax­a­tion of groups and shell en­tit­ies: two new draft dir­ect­ives...
On Decem­ber 22, 2021, the European Com­mis­sion pub­lished two draft dir­ect­ives: the first one is the European ad­apt­a­tion of the mod­el rules pub­lished two days earli­er by the OECD in or­der to guar­an­tee a...
09/12/2021
Re­duced VAT rates: agree­ment reached by EU Fin­ance min­is­ters to up­date...
The Coun­cil of the European Uni­on reached a polit­ic­al agree­ment on 7th Decem­ber 2021 for the ad­op­tion of a dir­ect­ive aim­ing at mod­ern­ising and har­mon­ising the rules for the ap­plic­a­tion of re­duced VAT...
30/09/2021
CMS Ex­pat Desk Con­tact Card
When tal­ent needs to move, we’re be­hind youLiv­ing in a highly con­nec­ted world al­lows com­pan­ies to hire and mo­bil­ise skilled and tal­en­ted people al­most any­where – and loc­ate busi­ness op­er­a­tions wherever they need to be.But when con­sid­er­ing mov­ing of­fices or em­ploy­ees, there are a range of factors to con­sider. These can in­clude the polit­ic­al and eco­nom­ic con­sequences of COV­ID-19 or Brexit, the cor­por­ate and per­son­al tax im­plic­a­tions of re­lo­ca­tion – even the im­pact of sanc­tions im­posed on cer­tain coun­tries.Around the world our CMS Ex­pat Desk teams are ready to help you man­age the em­ploy­ment, tax, visa (im­mig­ra­tion) and so­cial se­cur­ity as­pects of re­lo­ca­tion.Draw­ing to­geth­er spe­cial­ists from the CMS Em­ploy­ment & Pen­sions Group and the CMS Tax Group, our teams are net­worked across loc­a­tions in Europe, Asia, Africa and Lat­in Amer­ica to of­fer you multi-jur­is­dic­tion­al sup­port – wheth­er you’re mov­ing one em­ploy­ee or a whole of­fice.Our em­phas­is is on un­der­stand­ing you and the spe­cif­ic needs of your busi­ness. By shar­ing our know­ledge, net­works and provid­ing prac­tic­al day-to-day sup­port, we aim to help make any re­lo­ca­tion pro­cess smooth, swift and fully-con­sidered – with min­im­al dis­rup­tion to your core busi­ness.Ex­plore more about our ex­per­i­ence and ser­vices be­low. To con­tact your loc­al CMS Ex­pat Desk team, please check out the group con­tact card.Ayşegül Avci and Niels Koene, Co-Heads of the CMS Ex­pat Desk
10/09/2021
CSR and taxes: tax­a­tion is not only about money
At first glance, tax­a­tion and cor­por­ate so­cial re­spons­ib­il­ity (CSR) ap­pear to be dis­tant fields, an­ti­nom­ic even. Yet they have come to­geth­er over the past two years to form two sides of the same coin...
30/12/2020
Stock sav­ings plan and Brexit: Brit­ish stock and some oth­er fin­an­cial in­stru­ments...
As a res­ult of Brexit, both stock or UCITS by a Brit­ish is­suer are dis­qual­i­fied and some EU-based UCITS funds’ un­der­ly­ing Brit­ish fin­an­cial in­stru­ments may also be so. Such a dis­qual­i­fic­a­tion may lead...
12/11/2020
Law and reg­u­la­tion of Cov­id-19 tax re­lief in Bos­nia & Herzegov­ina
Value Ad­ded Tax Coun­cil of Min­is­ters have ad­op­ted a De­cision on in­dir­ect tax ex­emp­tions and tax re­fund of already paid in­dir­ect taxes on equip­ment and re­sources donated by do­mest­ic and in­ter­na­tion­al...
Comparable
07/10/2020
Ex­CEEd­ing Bor­ders
Col­li­ers In­ter­na­tion­al­Luke Dawson - Man­aging Dir­ect­or & Head of Cap­it­al Mar­kets, CEEThe In­dus­tri­al&Lo­gist­ics (I&L) prop­erty sec­tor has ris­en out of the shad­ows over the last few years to be­come one of the most dy­nam­ic and stra­tegic­ally im­port­ant sec­tors in our eco­nom­ies and the com­mer­cial real es­tate sec­tor, on a glob­al basis. The I&L sec­tor is by no means a new kid on the block and for people out­side of this in­dustry, it may well largely go un­noticed as products and ser­vices are seem­ingly ma­gic­ally pro­duced and ap­pear in shops and on our door­steps. Be­hind the scenes, there is of course a gi­gant­ic sec­tor made up of man­u­fac­tur­ers, sup­pli­ers, re­tail­ers, 3PLs, dis­trib­ut­ors, stor­age and sup­ply chain com­pan­ies to name just a few, and they lit­er­ally touch any busi­ness or in­dustry sec­tor that you can pos­sibly ima­gine. In ad­di­tion to that, there are sev­er­al highly ex­per­i­enced, glob­al, re­gion­al and loc­al in­vestors and de­velopers that provide the li­on’s share of the prop­er­ties to make all this pos­sible.In this re­port, we look at how the I&L sec­tor has de­veloped in the geo­graph­ic­ally and macro-eco­nom­ic­ally stra­tegic re­gion of Cent­ral&East­ern Europe (CEE). We will also touch on some of the trends fa­cing the sec­tor, both from a prop­erty point of view, as well as from oc­cu­pi­er and con­sumer led stand­points. To­geth­er with our part­ners, we also provide valu­able in­sight in­to im­port­ant loc­a­tion se­lec­tion de­cision-mak­ing cri­ter­ia around la­bour mar­kets, tax and in­cent­ives offered to in­vestors con­sid­er­ing this re­gion.This re­port cov­ers a range of top­ics across 17 coun­tries in the wider CEE re­gion and as a res­ult, we have close to 100 pages of in­sights to share with you. There­fore, we would not ex­pect you to con­sume this all in one sit­ting and we hope this will be a use­ful tool longer term as you re­view the op­por­tun­it­ies in this great re­gion. Last, but not least, you can­not ig­nore the ele­phant in the room that is COV­ID-19. This pan­dem­ic that we are still very much in, has only con­firmed the stra­tegic im­port­ance and need for this sec­tor in un­cer­tain times, but has also high­lighted some areas for re­flec­tion. We hope you find this re­port use­ful and, wheth­er you are an in­vestor, de­veloper, oc­cu­pi­er or oth­er in­ter­ested party in the I&L sec­tor, we look for­ward to dis­cuss­ing your out­look and plans with you fur­ther.CMS and So­rain­en­Lu­kas Hej­duk - Part­ner, Head of CEE Real Es­tateOver re­cent dec­ades, coun­tries in the wider Cent­ral and East­ern Europe re­gion have at­trac­ted sig­ni­fic­ant levels of for­eign in­vest­ments. The well-edu­cated la­bour forces and lower la­bour costs than in West­ern Europe, rap­idly de­vel­op­ing in­fra­struc­ture with good trans­port links to the rest of Europe, tax ex­emp­tions and pref­er­ences for in­vestors, are only some of the reas­ons why nu­mer­ous com­pan­ies have de­cided to open man­u­fac­tur­ing fa­cil­it­ies and dis­tri­bu­tion centres in CEE.CMS and So­rain­en have provided their col­lect­ive know­ledge and ex­per­i­ence which is in­ten­ded to help po­ten­tial In­dus­tri­al&Lo­gist­ics in­vestors un­der­stand what in­cent­ives are avail­able when seek­ing to start op­er­a­tions in one or more of the 17 CEE coun­tries covered in this re­port. As there are vari­ous levels of sup­port across CEE, the fol­low­ing guide is presen­ted in a coun­try-by-coun­try format. It is not meant to be com­pre­hens­ive and gives more of a gen­er­al, in­dic­at­ive pic­ture. As laws and reg­u­la­tions can change quickly, it is vi­tal to seek pro­fes­sion­al ad­vice at an early stage if you de­cide to green light an in­vest­ment.Rand­stad­Paweł Ko­peć - Head of En­ter­prise Solu­tions CenterThe CEE re­gion has al­ways been among the first des­tin­a­tions in the minds of for­eign in­vestors, from the pro­duc­tion and lo­gist­ics sec­tors, when look­ing for sav­ings on per­son­nel costs and avail­ab­il­ity of the work­force. Over the years, la­bour mar­ket con­di­tions across the CEE coun­tries has changed rap­idly and, in some coun­tries, un­em­ploy­ment rates have fallen be­low levels that any­one could have pre­dicted a few years back, reach­ing nat­ur­al un­em­ploy­ment rates.Des­pite some of these factors, the CEE re­gion re­mains very at­tract­ive and has a lot to of­fer. Not only there are dif­fer­ences in la­bour avail­ab­il­ity and costs between the vari­ous coun­tries, there are also sig­ni­fic­ant dif­fer­ences between spe­cif­ic counties and cit­ies in the giv­en coun­try. New in­vestors will of course tend to feel more se­cure loc­at­ing their busi­nesses in areas already ex­plored by oth­er com­pan­ies, but those who take the risk and be­come pi­on­eers in less in­dus­tri­al­ized areas, may well be re­war­ded with loy­al per­son­nel and less work­force short­ages. In this re­port, we share our views on the vari­ous la­bour mar­ket con­di­tions and trends across the re­gion.25%me­di­um25%me­di­um25%me­di­um25%me­di­um