Numerous controversies have long surrounded commercial real estate sale transactions and hence their qualification for the purposes of VAT. For where the assets sold consist of a totality of tangible and intangible assets, thus making up an enterprise or its organised part, rather than merely being a real estate, the transaction is not taxable with VAT.
Recent amendments to the tax legislation will also affect the obligations of withholding tax remitters. The new regulations, coming into force in 2019, will considerably extend the scope of obligations imposed on remitters, which in turn will result in an increased tax risk for domestic businesses.
The current relief-at-source mechanism entailing preferential taxation with withholding tax of revenues already at the time of payment by the tax remitter will be replaced on 1 January 2019 with an obligation for the tax remitter to collect the tax, which will be coupled with a tax refund procedure.