Effective January 1, 2017, new rules will govern the taxation of mutual fund corporations structured as ?switch funds?. Investors switching between funds will no longer be able to do so without incurring taxable capital gains. This article summarizes the impact of such changes. Description of "switch funds" under the current regime In Canada, most mutual funds are structured as trusts and some are structured as corporations (referred to as ?corporate class funds?) ...
Introduction In the context of trusts situated in foreign participating jurisdictions, the Common Reporting Standards (“CRS”) require the trustees to identify the settlor, beneficiaries and other natural persons exercising ultimate effective control (including through a chain of ownership) and report the necessary financial information in respect of those persons to the relevant foreign revenue authority ...
The 2017 Law on Financial Management has yet to be formally enacted in Cambodia however its content has already been disseminated among most tax professionals and the press so with that in mind we have put together what we believe are the salient points of the draft Law on Financial Management (“the Draft Law”) for your reference. The Draft Law has been rubber stamped by the Council of Ministers and when enacted the changes should take effect from 1 January 2017 ...
Trade mark law may be contained in statutes, but judges are the ones who interpret the statutes. Judges are also the ones who eventually decide whether one trade mark is confusingly similar to another. It is these factors that make the “Question the Trade Mark Judges” event that recently took place at University College London so fascinating for anyone interested in trade marks ...
In the case of Claremont Library Development Company (Pty) Ltd v The Commissioner for the South African Revenue Service, the Tax Court recently considered the question of whether crediting a loan account constitutes “payment” of full consideration for purposes of the Value-Added Tax Act, No 89 of 1991 (the “VAT Act”) ...
Section 103(2) of the Income Tax Act, 58 of 1962 empowers the Commissioner (the “Commissioner”) for the South African Revenue Service (“SARS”) to disallow the setting off of an assessed loss or balance of an assessed loss against the company’s income if the relevant requirements are met ...
Maxim Alekseyev, ALRUD Senior Partner, and Kira Egorova, ALRUD Of Counsel, prepared an article for Trusts&Estates journal “Family Offices in Russia”. Trust&Estates is one of the most reputable journals for wealth management professionals serving the needs of high-net-worth clients and their families ...
The Serbian Minister of Finance issued the Rulebook on the Manner and Procedure of Delivering and the Content of the Tax Administration's Notification on Commencement or Finalization of Tax Audit ("Rulebook"). Under the Rulebook, the Tax Administration ("TA") will start to deliver notifications on initiated tax audits of the legal entities and entrepreneurs to the Business Registers Agency ("BRA"). Notifications will be delivered once a day ...
Over the summer, several European blue chips, certain Fortune 500s and major Asian corporates accelerated their entry strategy for Iran. Some are investing in Iran pursuant to the Foreign Investment Promotion and Protection Act 2002 (“FIPPA”), which, amongst other things, provides a sovereign guarantee from the Iranian government ...
IN THIS ARTICLE, CHRISTOPHER TAY HANMIN BRIEFLY REVIEWS SOME OF THE OFFENCES UNDER THEGOODS AND SERVICES TAX ACT 2014("GST ACT").IntroductionOne of the most significant tax Acts to be introduced in the past 30 years is the GST Act which was gazetted on 19 June 2014 and has set 1 April 2015 as the effective date for the imposition of the Goods and Services Tax ("GST") ...
By way of -providing guidelines for implementing the Tax Law No.106/2016/QH13 (Law 106) effective from 1 July 2016, the government has issued Decree 100/2016/ND-CP (Decree 100) on 1 July 2016 and the Ministry of Finance has issued Official Letter 10315/BTC-TCT dated 25 July 2016 (OL 10315) and Circular 130/2016/TT-BTC dated 12 August 2016 (Circular 130) ...
Africa Tax in Brief Ethiopia: Treaty and amending protocol with the Netherlands enter into force The Ethiopia-Netherlands Income Tax Treaty, 2012 and the exchange of notes, signed on 10 August 2012, entered into force on 1 September 2016, and the amending protocol to the treaty, signed on 18 August 2014, will enter into force on 30 September 2016. The exchange of notes generally applies from 1 September 2016 ...
contingency fees VAT inclusive or exclusive The High Court, Gauteng Local Division, considered in a recent case (case No 2012/21359, 31 August 2016) whether an agreement in terms of which a legal practitioner charged contingency fees to a client under the Contingency Fees Act, No 66 of 1997 (the “CFA”), is valid ...
Global Transfer Pricing Risk Management The realities of the business environment in which multinational groups operate today consist of a shrinking domestic market and an ongoing pressure to reduce costs. In addition, multinational groups are also faced with the different expectations of different stakeholders and the increased disclosure requirements of financial data ...
The Davis Tax Committee Issues Its Second Report on Estate Duty The Davis Tax Committee (“DTC”) released its much-anticipated second (and final) interim report (the “Report”) on estate duty on 24 August 2016. The Report has been published with amendments taking into account the public’s comments that were submitted in respect of the first interim report ...
The South African Taxation of Trusts Recent Developments The Davis Tax Committee’s (“DTC”) first interim report was released in July 2015 (the “First Report”) and made various significant recommendations to the Minister of Finance regarding (among other topics) the taxation of trusts in South Africa ...
An interesting trend can be noticed recently as the Serbian Tax Administration and Tax Police have raised their level of activity in conducting routine tax inspections in companies across the country ...
The Second Eastern Economic Forum was held on 2nd and 3rd December in Vladivostok. The participants presented various investment projects ready for implementation. On 3rd September Maxim Alekseev, ALRUD Law Firm Senior Partner, participated in Russia-ASEAN session. Its primary topic was discussion of the declaration on main areas of cooperation between Russia and ASEAN adopted on Russia-ASEAN summit held in Sochi on 19-20 May, 2016 ...
On 24 August 2016, the Davis Tax Committee (“DTC”) released its long-awaited report on estate duty, which was submitted to the South African Minister of Finance (“the Minister”) for consideration on 28 April 2016. The report takes into account public commentary and submissions received following the release of the committee’s first interim report ...
TAXATION TAX ON IMMOVABLE PROPERTY PAYMENT FOR 2016 Notifications No. 12723 dated 5 August 2016 & No. 13466 dated 16 August 2016 Per Notification No. 12723, the General Department of Taxation (“GDT”) informs owners of immovable property (“Property”) which is subject to the Immovable Property Tax (“IPT”) to pay the IPT to the tax authorities by 30 September 2016. Late payment of IPT is subject to penalty ...
Corruption is a scourge which transcends frontiers. In response to this situation, Canada has chosen to pass the Corruption of Foreign Public Officials Act (hereinafter referred to as the "CFPOA") in 1998, then reinforced the regime thereof more recently. The difficulty with this Act lies in the fact that the offences must have been committed abroad. International cooperation thus remains essential to its application. The difficulties related to the transnational nature of corruption are real ...
