The Slovenian tax package adopted in October 2019 includes amendments to the Personal Income Tax Act (ZDoh-2V), the Corporate Income Tax Act (ZDDPO-2R), the Act on Tax on Profit from the Disposal of Financial Derivatives (ZDDOIFI-A) and the Tax Procedure Act (ZDavP-2M). The amended and new provisions will apply from 1 January 2020, with the exception of the provisions on the depreciation of assets from operating leases, which have been in force since 1 January 2019.

Taxation of companies according to new Slovenian tax package

Although Slovenia had proposed to increase the general corporate tax rate (DDPO) from 19% to 20% in February, according to the adopted Slovenian tax package this tax rate will remain at 19%, as in 2019, and will not change in 2020.

While the rate remains unchanged, all companies in Slovenia will have to pay corporate income tax from 2020. If a legal entity generates taxable income, any tax exemptions and tax losses from previous tax periods can be used up to a maximum of 63% of the taxable base. This means that companies generating profits for tax purposes and who previously reduced their tax base to zero due to high research and development (R&D) investments, investments in fixed and intangible assets, for employing certain categories of worker (disabled people), as well as for investing in voluntary supplementary pension insurance and for donations, will from now on always have to pay corporate income tax.

The tax allowances for R&D and equipment, as well as in fixed and tangible assets may be carried forward for a limited period of five tax years, while other allowances reduce the tax base only in the year they originated, which further limits the actual application of tax allowances. The same provisions also apply to sole entrepreneurs who determine income tax on the basis of actual expenses. 

Example:
A company generates a profit before corporate tax of EUR 1,000,000 and has invested EUR 1,500,000 in R&D in 2020. In 2020 the company can only consider a tax exemption for the R&D investment amounting to EUR 630,000, and then the difference over the next five years. 

Corporate income tax base: EUR 1 Mio x (1 – 0.63) = EUR 370,000
Corporate income tax calculation: EUR 370,000 x 19% = EUR 70,300 

Irrespective of the high level of investment or previous tax losses, the company will have to pay corporate income tax of EUR 70,300, which represents 7.03% of the profit. 

The changes to depreciation of assets in operating leases are the most important amendments that apply retroactively, i.e. from 1 January 2019. This means that by incorporating the operating lease into fixed and intangible assets in accordance with international and also Slovenian accounting standards, the legislator set the depreciation at the highest annual rate possible, which corresponds to the actual depreciation period of the asset, i.e. the asset’s useful life in operating leases. This provision already applies to the preparation of the corporate income tax self-assessment for 2019 and the determination of income tax for sole entrepreneurs for 2019.

Taxation of capital owners 

In 2019, taxpayers still have to pay 25% of the final tax on investment income (interest, dividends, capital gains and gains on the sale of derivative financial instruments). From 2020, capital gains will be taxed at the rate of 27.5%.

For capital gains realised in 2019, we present the comparable tax rates that will apply from 2020:

To close the legal discrepancy and avoid abuse, income of a shareholder from the sale of shares to the company (purchase of own shares) or company shares from non-regulated market are taxed as a dividend at the total amount paid.For income from real estate leasing, taxpayers can take into account standardised costs of 15% (only 10% in 2019), but the income tax rate for income from real estate leasing increases to 27.5% as well (in 2019 the tax rate is 25%). 

The transferor may inform the taxpayer in writing about the acquisition value of the shares or units sold prior to the tax settlement. 

Taxation of employees

From 4 May 2019 the annual holiday payment is completely exempt from social security contributions as well as income tax. This means that the employer’s costs are equal to the employee’s net payment, which corresponds to the average gross salary in Slovenia, amounting to EUR 1,726 in August 2019. 

Example:
A company pays out the holiday payment at a gross amount of EUR 1,700. It actually has personnel costs of EUR 1,700 and the employee receives a net amount of EUR 1,700 to his or her bank account. 

The Slovenian tax package for 2020 is also intended to change the income tax categories in terms of reducing income from employment of the middle tax brackets.

From 2020 the following income tax categories apply:

Also, the common tax allowance will increase and from 2020 should be the following:

This means that the common tax allowance for all taxpayers will rise at least from the current EUR 3,302 to EUR 3,500.

To apply and recognise a special allowance for supported family members (adult and unemployed children, parents or adoptive parents), the significant change is that such a person must have the same permanent residence as the taxpayer who declares that family member as a supported family member. This does not apply to children under 18 years.

To promote the purchase and use of electric vehicles, the Slovenian tax package reduces the benefit in kind when purchasing company vehicles used by employees for private purposes. The monthly benefit in kind for the private use of a small electric vehicle will only amount to 0.3% of the purchase price of the vehicle, if the purchase cost of the vehicle including VAT does not exceed EUR 60,000. The benefit in kind for private use of company vehicles for conventional petrol and diesel vehicles, as well as for larger electric vehicles (only for a surplus over EUR 60,000), remains at 1.5% of the initial cost in the first year.

According to the new Slovenian tax package the taxation of part of the salary for business success (so-called 14^th salary or Christmas bonus) currently remains unchanged for the coming years. The 14^th salary can be paid without income tax, and only bears the obligatory social security contribution deduction of 38.2%. In 2019, the tax-exempt part of the Christmas bonus can be paid out up to approximately EUR 1,700.

If you would like to find out more detailed information about the adopted Slovenian tax package, please visit the website of WTS Slovenia and contact the local experts of WTS Global for Slovenia.

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Similarly to last year, Tamás Gyányi, tax partner of WTS Klient Hungary, is among the world’s leading indirect tax experts in this year’s special edition too. The 2019 list highlights another 22 experts from WTS Global’s tax advisers as well.

You can find more information on how the Indirect Tax Leaders 2019 list was compiled here, and you can download the full edition in PDF format from the following link:

ITR Indirect Tax Leaders 2019 (PDF)

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Over the course of two days, in-house transfer pricing professionals, leading advisers and senior policymakers will be brought together to debate the most significant topics and trends currently impacting the industry.

The Forum aims to facilitate free and transparent debate on salient issues such as the OECD’s taxation of the digital economy, developments in risk and compliance management and the rise in TP disputes. As such, taxpayers are invited to openly share experiences of how to deal with a rapidly evolving global transfer pricing environment.

Please find further information on the Forum on the website of International Tax Review.

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Similarly to 2017 and 2018 WTS Global again won the “European Indirect Tax Firm of the Year” award at the European Tax Awards this year, which means the jury found WTS Global to be the best indirect tax adviser firm in Europe in 2019. Jürgen Scholz, leader of the WTS Global Indirect Tax team, managing partner of WTS Germany and one of the most acknowledged VAT specialists in the country, was also nominated for the European Tax Practice Leader of the Year 2019 award.

Four WTS Global partner companies received awards too. WTS Germany won the German Transfer Pricing Firm of the Year title for the second time, and similarly to last year, ICON, the Austrian partner and KM Partners / WTS Consulting in Ukraine were also ranked among the leading tax adviser companies. Sorainen, WTS Global’s exclusive partner in Belarus, Lithuania, Latvia and Estonia, received the title of best tax adviser firm in the Baltic region. One case of the Group’s Italian partner Studio Biscozzi Nobili was highlighted by the jury in the European Impact Cases category.

The European Tax Awards have taken place every year since 2005, organised by the International Tax Review in order to recognise the leading international tax firms of Europe. The nominees are assessed according to their size, innovation and complexity based on which they are ranked depending on the country and line of business. This year the award ceremony was held in London on 16 May.

Click here to read about the description of the competition and its winners on the official website of European Tax Awards.

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 The International Tax Review (ITR), Europe’s top magazine on taxation, is organising the competition for European tax companies for the 15^th time. This year, tax firms from 26 countries registered for the European Tax Awards 2019 competition, and even applicants for the ITR World Tax ranking will be included in the evaluation process.

Finalists of the European Tax Awards 2019

WTS Klient Hungary has been shortlisted in two categories for the European Tax Awards 2019 giving it a good chance at receiving the Hungary Tax Firm of the Year and the Hungary Transfer Pricing Firm of the Year titles.

WTS Global won the Indirect Tax Firm of the Year award in 2018 as well as in 2017, and has reached the finals of this category this year too, giving it a great chance of winning the European Indirect Tax Firm of the Year for the third time in a row. Besides the indirect tax category, WTS Global is also shortlisted for the European Transfer Pricing Firm of the Year award at the European Tax Awards 2019. Jürgen Scholz, managing partner of WTS Germany and the most acknowledged VAT specialist in the country, was nominated for the European Tax Practice Leader of the Year 2019 award. At the European Tax Awards 2019 competition, 10 WTS Global group members reached this year’s finals in 18 categories.

Award ceremony in London

The award ceremony has been organised by the renowned trade journal, the International Tax Review, every year since 2005 to honour the leading European tax firms. The candidates are evaluated by the jury according to three main criteria – size, innovation and complexity – and they are ranked by country and fields of activity.

The winners of the European Tax Awards 2019 will be announced on Thursday 16 May 2019 at a gala awards ceremony held at the Savoy Hotel in London.

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VAT simplification measures or simplified procedures (reverse charge mechanism) are applicable in Romania for specific transactions between two Romanian VAT payers. The main condition for applying the reverse charge mechanism in Romania is that both the seller and the buyer are registered for VAT purposes in Romania and that the supply takes place within the country.

Goods and services subject to reverse charge mechanism in Romania

The reverse charge mechanism in Romania is mandatory for applicable transactions as the country has one of the highest VAT gaps in Europe (35.88% in 2016) as regards uncollected VAT. In this respect, the seller issues the invoice without VAT and the buyer records the VAT both as input and output VAT, offsetting one another.

Provided that both the seller and the buyer are Romanian VAT payers, the main local goods and services subject to this reverse charge mechanism in Romania are as follows:

• Sale of ferrous and non-ferrous waste
• Sale of wood
• Sale of cereals
• Sale of electrical energy
• Sale of construction, partial construction, land (subject to the VAT regime by option or by law)
• Sale of mobile phones
• Sale of devices with integrated circuits
• Sale of PCs, tablets or laptops

Since it was possible to invoice most of the above transactions without VAT until 31 December 2018, Romania requested an extension of this mechanism to combat VAT fraud in these specific areas.

EU Directive on reverse charge mechanism

In this respect, EU Directive 2018/1695 was published in the Official Journal of the European Union on 12 November 2018, allowing Member States to regard the buyer as the person liable for VAT for specific local transactions until 30 June 2022. This is the envisaged date that the new EU VAT Directive will enter into force.

Having considered the above EU Directive and the current approach of the Romanian Ministry of Finance, the Romanian authorities modified the Romanian Fiscal Code. As we wrote in an earlier article, Government Emergency Ordinance no. 114/2018 enables the continued application of the reverse charge mechanism in Romania after 1 January 2019.

If you would like to know more about the application of the reverse charge mechanism in Romania or any other taxation issues of the country, please visit the website of Ensight, WTS Global’s exclusive representative in Romania.

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On 26 February 2019, the Slovene Ministry of Finance presented a tax package for the period 2019 to 2022, which has not yet been adopted. As stated by the country’s finance minister, the main goal of the tax reform in Slovenia is “to increase the net income of employees to make the Slovenian labour market more competitive internationally”. The provisions for the relief of taxation on employment income follow the latest suggestions of the OECD, and are warmly welcome, but the changes in taxation on capital income and capital gains should be considered carefully before implementation.

Tax reform in Slovenia for companies: increase in CIT rate

The current corporate income tax (CIT) rate in 2019 is 19%, which will increase in the coming years as follows:

• in 2020 the CIT rate will be 20%,
• in 2021 the CIT rate will be 21%,
• from 2022 onwards the CIT rate will be 22%.

Taxation of individuals: heavier tax on capital income and capital gains

So far, the taxation on interest, dividends, rental income and capital gains has been 25% and final. At present, the following tax rates apply to capital gains realised in 2019:

• ownership of capital < 5 years => tax rate of 25%,
• ownership of capital from 5 to 10 years => tax rate of 15%,
• ownership of capital from 10 to 15 years => tax rate of 10%,
• ownership of capital from 15 to 20 years => tax rate of 5%,
• ownership of capital > 20 years => tax free.

With the 2019-2022 tax reform, the taxation of interest, dividends and rental income will increase from the current 25% to 30%.

Taxation of capital gains from the disposal of shareholdings, real estate and other property will be taxed as follows from 2020 onwards:

• ownership of capital up to 10 years => tax rate of 30%,
• ownership of capital > 10 years => tax rate of 15%.

It is clear from the tax reform in Slovenia that capital gains will not be tax free anymore from 2020 onwards. The government’s proposal does not provide for a transition period for old rights acquired under the existing Income Tax Act.

Taxation of employees: holiday remuneration

The payment of holiday remuneration is currently subject to an advance payment of personal income tax up to 70% of the average gross salary in Slovenia at the time of payment, which is EUR 1,247.49 in March 2019.

After the tax reform in Slovenia, the holiday remuneration should be free of tax and free of any social contributions. Simply put, this means the employer’s cost would equal the net payment to the worker at the maximum amount of an average gross salary in Slovenia, which for March 2019 is EUR 1,782.

It is expected that holiday remuneration already paid in 2019, for which the advance payment of income tax has been charged and withheld, will be refunded to the employee in the course of the 2019 annual income tax assessment.

Example:
Following the tax reform proposal, a company who pays out holiday remuneration amounting to a gross EUR 1,500 should incur a labour cost of EUR 1,500, and the employees should receive a net amount of EUR 1,500 of holiday remuneration to their bank account.

More favourable income tax brackets and tax-free amount

The income tax brackets are designed to relieve employment income from heavy taxation, as evaluated by the OECD.

The following income tax brackets are proposed:

The general relief for taxable persons / residents is determined based on the total annual income of the individual and is expected to be the following:

This means a general tax deduction from the current EUR 3,302 would increase to EUR 3,500 for all taxpayers.

Bonus salary

Currently, a social contribution of 38.2% is levied without limitation on one-time bonus salaries, or on “part of remuneration for successful business” in translation from the Slovenian, but there is no advance tax payment for 100% of the average gross salary in Slovenia. The bonus salary may be paid out once a year only, and to all employees who fulfil the requirements, as specified in the decision of the Management Board.

The tax reform in Slovenia suggests that from 2020 onwards a bonus salary, which is exempt from personal income tax, will be based on the following:

• in 2020 it will increase to 150% of the average gross salary in Slovenia or about EUR 2,550,
• in 2021 it will increase to 175% of the average gross salary in Slovenia or about EUR 2,975,
• and from 2022 it will increase to 200% of the average gross salary in Slovenia, currently around EUR 3,400.

It is also important to note that the bonus salary is not taken into account in the calculation of annual income tax.

Example of calculation for payment in 2022:
Gross bonus salary: EUR 3,400
Employer’s cost: EUR 3,947.40
Net payment to employee: EUR 2,648.60 

It is expected that the proposals will be adopted in the current form, but there might be some transitional provisions which would prevent sudden decisions of capital owners / residents in Slovenia to flee from the Slovene capital market.

If you would like to find out more detailed information about the current tax reform in Slovenia, please visit the website of WTS Slovenia and contact the local experts of WTS Global for Slovenia.

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Cancellation of 20% deviation from the arm’s length price

One of the key changes regarding the latest TP trends in Belarus is that now any deviation from the arm’s length price (profitability range) in controlled transactions may trigger additional corporate income tax liabilities. Previously 20% deviation from the arm’s length price (profitability range) was allowed.

Advance pricing agreements

Taxpayers with controlled transactions exceeding a value of BYN 2 million excluding indirect taxes (currently approx. EUR 800,000) and high taxpayers are entitled to enter into advance pricing agreements with the tax authorities.

The list of related persons is extended

A person that directly or indirectly influences the business conditions or economic results of another person is recognized as a related person. Tax Code 2019 introduces the new term “beneficiary of the company” which is defined, for tax purposes, as an individual who directly or indirectly takes key managerial decisions and decisions affecting the business activities of the company. Such beneficiaries and the company are related persons.

The latest TP trends regarding the trade in shares of companies

The current opinion of the Belarusian tax authorities regarding TP control of transactions involving shares between related persons is that the sale of shares can be interpreted as transactions involving property rights which are subject to TP control. Still there is a lot uncertainty because the Tax Code does not specify how to determine the arm’s length price of shares. Currently there is no rule that taxpayers should stick to the value of net assets per share or similar.

Practice of the supervisory authorities

President Lukashenko publicly announced a campaign against corruption and manipulations in structures involving intermediaries. Financial investigators of the State Control Committee now pay close attention to structures involving related intermediary companies during their audits, especially those registered outside Belarus. We expect that the supervisory authorities will focus even more on deals involving intermediary companies in 2019.

If you would like to know more about the new Tax Code and the latest TP trends in Belarus, please visit the homepage of Sorainen, the Belarusian partner firm of WTS Global.

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Innovation contribution – a look back

It verges on the impossible, but since the currently applicable law effective from 1 January 2015 was implemented, one major element of the regulation, the one defining which business entities are liable to pay the innovation contribution, has remained essentially unchanged until the end of 2018. It was always a key issue whether the small and micro enterprise status giving exemption should be defined based on the company’s own indicators, or using consolidated financial data with any related companies as well.

At the end of 2014 the regulation prescribed that all the provisions of Act XXXIV of 2004 on Small and Medium-sized Enterprises and the Promotion of SME Development (hereinafter referred to as: SME Act) must be taken into account when qualifying a small and micro enterprise. Hence, it needed to be checked whether the company had any related or partner companies, and whether, pursuant to the “two-year rule”, its headcount, net sales revenue or total assets exceeded the threshold prescribed by law in two consecutive years.

Thereafter, from 2015 until the end of 2018, enterprises had to be classified based on their own indicators. The returning regulation effective again from 2019 brings back the pre-2015 provisions.

The 2019 regulation

What does all this mean in practice? From this year on, when defining whether a Hungarian company is obliged to pay the innovation contribution, you again need to take into account the relevant financial indicators of any related or partner companies as well, and when assessing whether a contribution needs to be paid, the data in their financial statements becomes relevant too. The “two-year rule” is still applicable: a business “exceeding” (or falling below) the threshold loses its previous rating if it exceeds or falls below the given threshold in two consecutive years.

Let’s take an example. Let us suppose that our company is a small enterprise and has not been obliged to pay innovation contribution since at least 2017, and (based on its own figures in its latest financial statements from 2016) it is classified as a micro enterprise in 2018. Its business activity picked up substantially according to the figures in its 2017 financial statements, so much so that when it reassessed in 2019 based on its 2017 financial statements, it qualifies as a large company. However, it does not matter if we qualified the company as large this year because the data reported in its last financial statements exceeded the threshold; since it happened for the first time, the rating of the company for 2019 is unchanged, so it is still exempt from paying the innovation contribution.

Brief look at aspects to be examined

It is important to specify whether the companies within your group are classified as related or partner companies based on the statutory definitions. If yes, the consolidated figures need to be taken into account when assessing fulfilment of the threshold for the innovation contribution obligation in 2019 – just like before 2015. The good news though is that the base and rate of the innovation contribution remain the same: the contribution must still be calculated and paid on the local business tax base at a rate of 0.3%.

If you would like more detailed information on how the 2019 innovation contribution amendments affect your company, please get in touch with the tax experts at WTS Klient Hungary.

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Value added tax

• The sale of certain residential properties will still incur 5% VAT provided the sale is to be concluded in the period from 1 January 2020 to 31 December 2023, and, if the construction is subject to a building permit, the final permit was valid on 1 November 2018, or the construction activity subject to simple notification pursuant to the Act on the Formation and Protection of the Built Environment was reported by no later than 1 November 2018.

• The threshold for choosing VAT-exempt status will be raised from HUF 8 million (roughly EUR 25,000) to HUF 12 million (roughly EUR 32,000).

• For cases where leased passenger cars are used for both business and private purposes, the law dictates a 50% deduction rate for the input VAT on the lease in order to reduce administration burdens. If a taxpayer does not want to apply the 50% deduction rate, the deduction rate can be altered based on duly substantiated documentation, in line with the extent the car is used or utilised for the business activity eligible for the tax deduction.

• The rules on the transfer of vouchers differentiate between single-purpose and multi-purpose vouchers in terms of tax payment liability. The aim is to levy the tax upon the issuance of the voucher wherever possible.

• With regard to the exercise of tax deduction rights it is important to note that taxpayers are entitled to include the amount of deductible input tax (previously not refunded) – incurred before the registration of the taxpayer in the national registry – in the tax assessment period that includes the registration date.

• The standardisation of the 5% tax rate for milk types will include ESL and UHT milk types under the scope of the reduced 5% VAT rate too.

• Cereals and steel products will remain subject to the reverse charge mechanism from 31 December 2018 as well.

Corporate tax

• Corporate tax groups allowed. One requirement for establishing a corporate tax group is to have a related company relationship between the taxpayers based on at least 75% of the voting rights. Corporate tax groups fulfil their tax liabilities through a designated member of the group registered at the Hungarian tax and customs authority as the group representative, under a specific group ID, and the group members exercise their taxpayer rights in the same way. Requests for the registration of corporate tax groups can be submitted from the first day of the penultimate month of the fiscal year until the 20^th day of that month. Taxpayers lose this right after the deadline expires. Requests may first be submitted between 1 and 15 January 2019. No application for an extension shall be accepted upon failure to meet this deadline. If the request is approved, the corporate tax group will be established as of 1 January 2019.

• The maximum amount of a development reserve is to be raised from HUF 500 million (roughly EUR 1.5 million) to HUF 10 billion (roughly EUR 30 million).

• Provisions on thin capitalisation are replaced by the new rule on limiting interest deductions. Under the rule, the tax base is increased by the portion of net financing costs that exceeds 30% or HUF 939,810,000 (EUR 3 million) of fiscal-year earnings before interest, taxes, depreciation and amortisation (EBITDA), whichever is higher. At the same time, the amount of the tax-base increase is reduced, up to no more than the amount of the increase, by any unused interest deduction that accrued in previous fiscal years. Contracts for financial costs concluded before 17 June 2016 may not be subject to the new rule (case-by-case examinations necessary). 

• Costs allocated to the operation of day-care centres at workplaces shall be deemed eligible costs when assessing tax bases.

• The definition of controlled foreign company and the related tax base adjustment items are to undergo significant changes. 

Personal income tax

• The fringe benefit system is to be radically transformed, the tax-exempt status or reduced tax rate of the benefits granted most often will be abolished.

• Which benefits will remain under favourable conditions?
  • SZÉP card (fringe benefit: tax burden of 34.5%)
  • private use of company phone
  • meals on official business trips or other services (not income)
  • products or services provided for entertainment purposes or as business gifts (other benefit: tax burden of 40.71%)
  • from 2019, small-value gifts may be provided once a year as opposed to the earlier rule of three occasions per year (other benefit: tax burden of 40.71%) 

• Tickets to sports events / certain cultural events can be provided tax-free (ceiling for tax-exemption = amount of the minimum wage).

• The fee of (individual or group) risk insurance concluded and paid by payers (employers) after 31 December 2018 is taxable (with due consideration of the reasoning of the Bill and of the 1-year transitional provision applicable for risk insurance taken out before 1 January 2019).

• The amount of the family (tax base) allowance will increase from the current HUF 116,670 (roughly EUR 360) to HUF 133,330 (roughly EUR 410) per dependant and allowance month.

• The NAV can prepare draft tax returns for the self-employed The deadline for submitting the tax return is 20 May following the fiscal year (also for the 2018 fiscal year).

• In the case of housing loans the reduction in the interest rate does not have to be considered income (provided any loan granted in the four years before the disbursement does not exceed HUF 10 million (roughly EUR 30,000), but the condition of legitimate housing needs does not have to be met).

Social contribution tax 

• The rate of the social contribution tax remains at 19.5%.

• The health care contribution will be abolished and integrated into the social contribution tax. The social contribution tax will be set out in a separate law (Act LII of 2018 on Social Contribution Tax).

• The previous rule on the calculation of the upper threshold is changing. Employees who earn 2 times the minimum wage on a monthly basis do not have to pay social contribution tax on dividends or income from exchange gains. (The health care contribution is currently capped at HUF 450,000 – roughly EUR 1,400.)

Act on Rules of Taxation 

• There will be an increase in late payment interest from double the base interest rate of the central bank (1.8%) to the base interest rate of the central bank plus five percentage points (5.9%).

• The maximum default penalty payable upon violating the rules for topping up tax advances will be halved.

• The NAV will conduct a mandatory tax inspection at business entities whose net sales revenue totals HUF 60 billion (roughly EUR 185 million) in two consecutive years but still do not generate a profit. (This shall not apply for the first four financial years of companies established without a legal predecessor.)

Innovation contribution

• Determination of those obliged to pay innovation contributions will change from 1 January 2019; several companies previously exempted from paying contributions may now be obliged to pay innovation contribution.

If you would like more detailed information on how the 2019 tax law amendments will affect your company, please get in touch with the tax experts at WTS Klient Hungary.

You can download our summary in PDF format here:
WTS Klient Newsflash 23.11.2018 – 2019 tax law amendments

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