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The Philippines is currently a party to 43 double taxation agreements (DTAs), all of which contain a mutual agreement procedure (MAP) provision. The Department of Finance recently issued Revenue Regulations (RR) No. 10-2022, which took effect on 23 July 2022. RR No. 10-2022 prescribes the guidelines for filing a MAP request for assistance in resolving DTA disputes ...

DFDL | November 2022

Instruction No. 27185 GDT (“Instruction 27185”) on the Display of Tax Registration Documents at Business Premises was issued by the General Department of Taxation on the 14th of November 2022 ...

Schwabe, Williamson & Wyatt | November 2022

In March 2022, the Oregon legislature passed House Bill (HB) 4002, which imposes new overtime pay requirements for agricultural workers beginning on January 1, 2023. The bill also establishes a refundable tax credit for eligible employers to help offset all or part of the additional wage expenses attributed to overtime pay ...

Hanson Bridgett LLP | November 2022

On October 21, 2022, the IRS announced in Notice 2022-55 cost-of-living adjustments to the tax-qualified retirement plan dollar limits for 2023. Most of the applicable dollar limits currently effective for 2022 will increase substantially compared with prior years. Below is a summary of the limits that are generally relevant for most retirement plans. Effective January 1, 2023: The elective deferral limit for 401(k), 403(b), and eligible 457(b) plans is increased from $20,500 to $22,500 ...

Under Notice 2022-33, the Internal Revenue Service (IRS) has extended the deadline for adopting amendments to qualified retirement plans and individual retirement accounts (IRAs) to reflect certain changes made by the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), the Bipartisan American Miners Act of 2019 (Miners Act), and the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) ...

ENSafrica | November 2022

Tackling base erosion and profit shifting remains a priority for the National Treasury and the South African Revenue Service (“SARS”). It was recently reported that in the 2021 fiscal year, SARS dealt with 345 cases of transfer pricing, base erosion and profit shifting to the value of almost ZAR12-billion. Yet, only three South African courts have dealt with transfer pricing ...

ENSafrica | November 2022

In November  2022, South Africa is expected to present a report to the Financial Action Task Force (“FATF”) on the steps it has taken to address the shortcomings identified in the Mutual Evaluation Report concluded last year ...

DFDL | October 2022

Instruction No. 26118 GDT on the Use of Official Exchange Rate for Self-Assessment Taxpayers dated 28 October 2022 (“Instruction 26118”) has abrogated Instruction No. 10362 GDT, dated May 17, 2022 (“Instruction 10362”) ...

Carey Olsen | October 2022

With this continued interest, a number of Singapore are managers using Jersey as the jurisdiction in which to domicile their funds. This choice is driven by several factors. Singapore tax treatment of digital assets. Digital assets do not fall within the definition of a “designated investment” for the purposes of Singapore tax legislation. This means that a Singapore domiciled fund will be subject to tax in the country, and such tax leakage is hugely unattractive to investors ...

DFDL | October 2022

The Royal Government of Cambodia will continue its relief measures to mitigate the economic impact of Covid-19 and support the recovery of the country’s tourism sector, according to an official announcement on 25 October 2022 ...

ENSafrica | October 2022

Alleged base erosion and profit shifting activities of multinational enterprises (“MNEs”) have been a hot issue globally and therefore the chances of an MNE being confronted with a transfer pricing audit have increased substantially over the last few years ...

ENSafrica | October 2022

  Due to the impact of the COVID-19 pandemic, many employers have seen an increased demand for international remote working arrangements. We have briefly touched upon the OECD guidelines relevant to these arrangements in a prior article ...

ENSafrica | October 2022

On 6 October 2022, as part of the ongoing work of the OECD/G20 Inclusive Framework (“IF”) on Base Erosion and Profit Shifting (“BEPS”) to implement the Two-Pillar solution to address the tax challenges arising from the digitalisation of the economy, the OECD released its progress report for comment. Background The report was prepared for the purposes of obtaining further input from stakeholders on the administration and tax certainty aspects of Amount A ...

ENSafrica | October 2022

It has been a little over a year since the Financial Action Task Force (“FATF”), an international initiative established to combat money laundering published its Mutual Evaluation Report (“MER”) on South Africa in which it identified major “weak spots” in our compliance processes. The FATF gave the country a deadline of February 2023 to remedy all the deficiencies or face possible grey listing ...

After more than 10 years, the Department of Finance has finally issued Revenue Regulations (RR) 7-2022, which provides "the policies and guidelines for the availment of tax incentives under the Renewable Energy Act of 2008" ...

Carey Olsen | October 2022

Annex II is a list of cooperative jurisdictions maintained by the EU that reflects ongoing cooperation between the EU and its international partners and the commitments of these countries to reform their legislation to adhere to agreed tax good governance standards. Its purpose is to recognise ongoing constructive work in the field of taxation, and to encourage the positive approach taken by cooperative jurisdictions to implement tax good governance principles ...

Simonsen Vogt Wiig AS | September 2022

Resource rent tax on aquaculture The government proposes to introduce a resource rent tax on aquaculture from 1st of January 2023. The proposal will be circulated for consultation today with a deadline of 3rd of January 2023. The proposal includes a resource rent tax with an effective rate of 40% applicable to the production of salmon, trout, and rainbow trout. The proposal includes a tax-free allowance of between 4,000 and 5,000 tonnes ...

DFDL | September 2022

We would like to take this opportunity to remind our readers that the immovable property tax (“TOIP”) and Unused Land Tax deadlines for 2022 of 30 September 2022 are fast approaching.  The 2022 TOIP and Unused Land Tax payment can be submitted at any tax branch or any branches of the following banks: Canadia, ACLEDA, Vattanac, Cambodia Public Bank or ABA Bank ...

Shearn Delamore & Co. | September 2022

<p>Dear valued clients, colleagues and friends,</p><p>&nbsp;</p><p>We are pleased to bring you the latest legal updates for September 2022.</p><p>&nbsp;</p><h2><strong>Financial Services</strong></h2><p><a href="http://www.shearndelamore.com/alerts/2022/Legal_Updates_Sept_1_2022.pdf">Expansion of SRI Sukuk and Bond Grant Scheme</a></p><p><a href="http://www ...

Kudun and Partners | September 2022

As data centers play a crucial role in the growing digital world, many businesses undoubtedly need reliable data hosting services to facilitate better data management ...

Buchalter | September 2022

September 1, 2022 By: Nora Sheriff, Gwenneth O’Hara, and Lillian Rafii On August 19, 2022, the California investor-owned utilities filed a joint motion for official notice at the California Public Utilities Commission (CPUC), saying that the recently adopted Inflation Reduction Act of 2022 (HR 5376) is “directly relevant” to the CPUC’s open net energy metering (NEM) proceeding. The CPUC is currently contemplating a revision to its NEM tariff (referred to as NEM 2 ...

Shearn Delamore & Co. | September 2022

Dear valued clients, colleagues and friends, On 23 August 2022, the Malaysia Competition Commission (“MyCC”) launched a public consultation on the proposed renewal of a Block Exemption Order (“BEO”) in respect of liner shipping services covered under a VSA. The renewal application was made pursuant to Section 8 of the Competition Act as the earlier BEO granted expired on 6 July 2022.  The press release by MyCC (“Press Release”) is accessible here ...

Goods and Services Tax AlertSummons not to be issued to Managing Director, CEO, CFOs of companies routinely By the recent Guidelines for issuance of summons under Section 70 of the CGST Act – Instruction 03/2022- 23 [GST-Investigation], indiscriminate issuance of summons has been discouraged, and officers have been advised to issue summons judiciously ...

Hanson Bridgett LLP | August 2022

On August 24, 2022, the IRS issued Notice 2022-36, 2021-15 I.R.B. 986, (the "Notice"), which grants significant penalty relief for taxpayers who failed to file certain tax or information returns for tax years 2019 and 2020. However taxpayers must file their missing returns on or before September 30, 2022, in order to obtain the penalty relief. This Notice presents a rare opportunity to taxpayers who have not filed the requisite returns to avoid onerous penalties ...

The Philippines is party to double taxation agreements (DTAs) with 43 countries. These DTAs contain exchange of information (EOI) provisions, which oblige contracting parties to exchange details that are needed to carry out the provisions of the DTAs or the domestic laws that concern the taxes applicable to the DTAs. To this end, the Bureau of Internal Revenue (BIR) consistently develops its EOI programme and has, in the past decade, circulated administrative issuances to facilitate EOI ...

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