Strap: In a recent case of Samsung Heavy Industries, the Indian Supreme Court held that the Project Office of the company cannot be termed as PE under the provisions of India-Korea Tax Treaty as it is solely carrying out activities of an auxiliary nature ...
The 2020 election in California as pertains to national politics was never in doubt, but despite being a deeply blue state, Californians continued to show their divide on taxing businesses and making major changes to the statewide tax code. Several ballot initiatives, both at the state and municipal level, would have radically altered how businesses and executives are taxed ...
In the recent decision in Agracity Ltd. v. The Queen1, the Tax Court of Canada (the “Court”) endorsed the Canadian tax consequences of business transactions between a Canadian corporation (“Agracity”) and its Barbados affiliate (“NewAgco-Barbados”) within a group of companies operating in the agrochemical industry (the “Group”) ...
The supply of undeveloped (bare) land is exempt from value added tax (VAT) pursuant to Article 46 (3) of UAE Law No 8 of 2017. Bare land (as opposed to covered land) is defined as ‘land that is not covered by completed, partially completed buildings or civil engineering works’ pursuant to Article 44 of Cabinet Decision 52 of 2017 ...
The SyCipLaw T.I.P.S. for October cover the following tax issues: 1. When the taxpayer cannot be located, what are the options available to a Revenue Officer in serving an electronic Letter of Authority? 2. Is the sale, barter, exchange or other disposition through Initial Public Offering of shares of stock in closely held corporations subject to tax? 3 ...
Income tax The Income Tax (Prescribed Fees under Schedule 5 to the Act) Rules 2020 have been gazetted on 22 September 2020 and have come into operation on 25 September 2020. The following public rulings and guidelines have recently been published on the Inland Revenue Board of Malaysia’s official website:i. Appeal Against an Assessment and Application for Relief (Public Ruling No. 7/2020) issued on 7 October 2020 to replace Public Ruling No. 12/2017 dated 29 December 2017;ii ...
Introduction The balance of trade between India and China continues to be heavily tilted in favour of China. Trade remedies such as anti-dumping and countervailing duties have been used frequently by India to curtail import of Chinese goods. To overcome such barriers, India has long suspected that China has been routing its goods through the ASEAN countries by misusing the Free Trade Agreements (‘FTA’) ...
27.10.2020 –Emergency Ordinance no ...
On 24 August 2020, the UAE issued Cabinet Resolution 58 of 2020 on Regulating the Procedures of the Real Beneficiary (the Resolution). The Resolution, amongst other things, aims to establish a legal framework for identifying and recording details of real beneficiaries of entities licensed to conduct business in the UAE. The Resolution is an additional step towards the UAE’s efforts in combating money laundering, the financing of terrorism and illegal organisations ...
E-commerce: New VAT rules Law 47/2020 was published on 24 August to implement articles 2 and 3 of Council Directive (EU) 2017/2455 of 5 December 2017, and Council Directive (EU) 2019/1995 of 21 November 2019, modifying the operation of the Value Added Tax (“VAT”) system in intra-EU and international e-commerce. This legislation enters into force on 1 January 2021 ...
Defining your strategy and analysing the market are crucial when making the decision to invest in China, but the tax efficiency of the business has its own specific issues and investors should not neglect them either. The Chinese tax system has particular characteristics that you must get to know before investing. In this informative note, we will address some basic aspects of value added tax and the invoicing system ...
The Arendt Weekly Update is a newsletter designed to give you the insight you need without overloading your mailbox. It lists the latest news, topical webinars, training courses and more. NEWSFLASHES Budget 2021: various tax measures to address the impact of the COVID-19 pandemic and support a sustainable recovery On 14 October 2020, the Luxembourg government filed the budget bill 7666 with the Luxembourg parliament ...
The Arendt Weekly Update is a newsletter designed to give you the insight you need without overloading your mailbox. It lists the latest news, topical webinars, training courses and more ...
A case note by Abhilaash Subramaniam Introduction In the recent case of SWW v Ketua Pengarah Hasil Dalam Negeri, the High Court of Malaya granted the taxpayer leave to apply for judicial review, a stay of proceedings pending the disposal of the taxpayer’s application for judicial review and subsequently allowed the taxpayer’s judicial review application on the merits, ordering a prohibition on all collection and enforcement action relating to disputed taxes and assessments
Income Tax The Income tax The Income Tax (Special Treatment for Interest on Loan) Regulations 2020 have been gazetted on 25 August 2020 and shall have effect for the year of assessment 2020 and subsequent years of assessment ...
In a major win for sellers of services and intangibles, the Ohio Supreme Court ruled on Sept. 29, 2020, that a taxpayer is entitled to Ohio Commercial Activity Tax (CAT) refunds stemming from its sale of contracts to an out-of-state buyer ...
A recent Ministerial Order1 from the Minister of National Revenue has formally extended certain deadlines under the Income Tax Act (“ITA”) and the Excise Tax Act (“ETA”). The Order is retroactive to March 13, 2020. The extension is 6 months or until December 31, 2020, whichever is earlier. This Ministerial Order will have various implications for taxpayers and registrants, in particular in terms of limitation periods ...
SyCipLaw TIP 1: Based on reports, the BIR is considering applying a minimum threshold on who will be required to submit BIR Form No. 1709. The threshold may be based on the assets or revenue of the entity or the size of the transaction, or both. However, until the BIR issues the relevant circular, a taxpayer entering into transactions with related parties must ensure that it complies with the requirements under RR No ...
How is taxable income determined in your state? To what extent is the state income tax base aligned with the federal income tax base? Alabama levies a corporate income tax on business entities classified as taxable or “C” corporations that have nexus with the state and are not classified as “financial institutions” or insurance companies subject to a separate premium license tax; and it levies a FIET on business entities classified as financial institutions havin
We would like to take this opportunity to remind our readers that the immovable property tax (“TOIP“) and Unused Land Tax deadline for 2020 is next Wednesday the 30th of September 2020. The 2020 TOIP and Unused Land Tax payment can be made at any tax branch or any branch of Canadia, Acleda, Vattanac or Cambodia Public Bank. Those already registered for TOIP and Unused Land Tax need to provide their 2019 tax payment receipt or Property Tax Registration Identification Card ...
In recent months, a number of changes to the Russian tax legislation, implying long-term effects for both Russian taxpayers and foreign investors, are taking place. Amendments to the Double Tax Treaties ('DTTs') are among of the most important ones. Below, we provide our consolidated analysis of the forthcoming changes and recommendations on steps to prepare for them ...
The Tax Court of Canada (the “Court”) recently upheld the deductibility of carrying charges incurred in connection with an issuance of shares. In so doing, the court upheld the tax benefits arising from a common financing practice. In addition, the Court reiterated the principle in tax matters according to which, save in exceptional cases, the legal relationships established by one or more taxpayers must be respected ...
Complementary Law No. 175/2020, enacted in September 23, 2020, determined that the Service Tax (ISS) must be shared between the municipalities where the service providers and the clients are located. Complementary Law No. 175/2020, enacted in September 23, 2020, determined that the Service Tax (ISS) must be shared between the municipalities where the service providers and the clients are located ...
On Saturday, September 12, 2020, the Internal Revenue Service (“IRS”) updated a marijuana industry frequently asked questions (“FAQ”) page that provides relief to state-legal cannabis businesses. The FAQ announces that state-legal cannabis businesses can reduce their gross receipts by using an alternative accounting method under Section 471 of the Internal Revenue Code (the “Code”) ...
