As the end of another tax year approaches, now is a good time to consider your financial position and check whether you have taken full advantage of the tax reliefs and exemptions that are available. This note is intended to provide a brief guide to the opportunities that we believe may be worth considering. There are many tax-saving measures available and we detail below a number of steps that can be taken to improve your tax position, without significant effort ...
The Central Bank of Brazil initiated a public hearing on 6 February to facilitate foreign investment. The Internet-delivered hearing will end on 7 April. The idea is to include under a single normative act the scattered provisions relating to fixed and variable income investment, as well as to portfolio investment. The measure is one of initiatives taken by the Central Bank within its Otimiza-BC program of cost reduction ...
The recent amendments to the VAT legislation introduced by the Taxation Laws Amendment Act, No 31 of 2013, gives effect to government’s proposal that all foreign businesses supplying e-books, e-music and other digital goods and services in South Africa be required to register as South African value-added tax (“VAT”) vendors ...
In a decision that will please rights holders, the Court of Justice of the European Union (‘CJEU’) ruled last week that goods sold by a website based outside the EU are protected by EU intellectual property law if they are sold to a person in the EU. Mr Blomqvist lived in Denmark. He ordered a watch described as a Rolex from a Chinese website which was then sent to him from Hong Kong. The Danish customs authorities held the parcel on suspicion that it was a counterfeit ...
Strategic Investment Act: The new Act on Strategic Investment in Croatia has achieved its goal of reducing administrative procedures and ensuring the speedy realisation of strategic projects in Croatia. In order to declare a project “strategic,” it must meet several criteria. Foremost, the project must be in accordance with spatial planning regulations. Also, the total amount of capital expense must be HRK 150 million (approx. EUR 19.6 million) or more ...
For the Portuguese tax authorities to grant the status of the non-habitual tax resident, it is necessary to meet the following conditions: The applicant cannot have been taxed as tax resident in Portugal in any of the five preceding years; The applicant must be considered as a tax resident in Portugal and residence in Portugal for tax purposes may be acquired in any year, among other situations, when the taxable person ...
While helpful, California’s Board of Equalization has not exactly taken the most pro-renewable energy position in their new guidance on the effect of the installation of a solar power system on tax-exempt property. In what appears to be a fairly common acquisition structure, for example, a solar power company installs a solar power system that it retains ownership of, and the nonprofit provides the space for installation and then leases the system from the solar company ...
On December 20, 2013, the Quebec Department of Finance and the Economy issued Information Bulletin 2013-14 (the “Bulletin”), announcing inter alia changes to various tax measures specifically applicable to the natural resources industry ...
CONTENTS Requirements for ITC and ITR claims: A judgment of the Court of Québec sets the record straightRestrictive covenants transactional context vs ...
Negotiation of the proposed EU Data Protection Regulation has faltered. While there is still a possibility that the Regulation could be passed before the May 2014 European elections, that looks increasingly remote. The main stumbling block appears to be the difficult issue of the ‘one stop shop’, which has produced deadlock within the Council of Ministers. The ‘one stop shop’ proposal is inherently difficult, but until now has been referenced in somewhat superficial terms ...
As the end of 2013 draws near, taxpayers should consider the effect of the new 3.8% surtax on investment income. Beginning January 1, 2013, a 3.8% surtax is placed on certain investment income for individuals, trusts, and estates. The surtax is imposed in addition to all other taxes imposed by the Internal Revenue Code (including the alternative minimum tax). Prior to the end of 2013, individuals, trustees, and executors should consider ways to minimize the 3.8% surtax ...
The Romanian Government has approved the necessary legislative amendments to create a holding regime in Romania, the ordinance being published in the Official Gazette on Friday, November 15, effective as of January 1st, 2014. The ordinance includes profits tax exemptions for Romanian holding companies as regards revenues from dividends received, revenues from the sale of shares and revenues from the liquidation process ...
On October 15th 2013 the New Hotel and Restaurant (Taxation) Ordinance 2013 came into effect. This ordinance amends the former Hotel and Restaurant (Taxation) Ordinance which was into effect prior to October 15th.There are a wide range of new provisions which clients should be aware of ...
The Turks and Caicos Islands (TCI) has just enacted a revamped investor residency programme, entitling successful applicants to a permanent residence certificate (PRC). The Qualifying criteria are: Villas a. Investment of not less than $300,000 in actual construction of a new home, or in renovation of a distressed property as a home for the applicant and his or her dependants, on the islands of Grand Turk, Salt Cay, South Caicos, Middle Caicos or North Caicos; or b ...
On September 26, 2013 the Supreme Court released its decision in the Envision1 case. The case deals with the amalgamation of two credit unions, but has broader implications for the tax treatment of amalgamations in Canada, and will be of interest to Canadian corporations contemplating a merger in the future. In 2001, two BC credit unions amalgamated to form Envision. The transaction was undertaken for non-tax reasons, but structured to obtain a particular tax outcome ...
If you made gifts in calendar year 2012 that should be reported on a federal gift tax return (Form 709) and you extended the deadline to file your gift tax return, the deadline to submit a timely-filed return is October 15, 2013 ...
CONTENTS The Pros and Cons of Arbitration Clauses in Commercial Contracts Pirating and Using Software Without a Licence: The BSA The Software Alliance Case Interprovincial Taxation: The Importance of Severing Residential Ties on Departure Security Under Section 427 of the Bank Act: Do the Rights of a Bank Rank Ahead of Those of the Holder of a Retention Right? THE PROS AND CONS OF ARBITRATION CLAUSES IN COMMERCIAL CONTRACTS Catherine Méthot and André Paquette Arbitration clauses
The Nation published the result of a survey that basically asked two specific issues : (i) how easy (or clear) you think the tax system? and (ii) what is the main reason why some people evade taxes? Any analysis of the tax system should take into account an absolute truth: no one likes to pay taxes . As we have discussed on other occasions ... a person can understand why you pay taxes, but like ... or want to pay ... mmmm ... I do not think: that's another thing ...
The Philippine Bureau of Internal Revenue (BIR) has recently implemented Revenue Regulations No. 18-2012 (RR 18-2012) directing all persons, whether private or government, to secure from the BIR a new Authority to Print (ATP) and to print new receipts/invoices starting July 1, 2013 ...
Introduction:The Consumer Protection Act, Cap. 326D (‘the Act’) aims at protecting consumer rights by, among other things, prohibiting and penalizing the use of unfair contract terms by suppliers of services. The Act is administered and enforced by the Fair Trading Commission (‘the FTC’). This article summarises the effect of the Act on how service providers can legally contract with their customers. This article does not focus on suppliers of goods ...
We are pleased to advise that, with effect from 15 May 2013, some important changes were made to the Virgin Islands Special Trusts Act (VISTA), the Trustee Act and various other British Virgin Islands statutes relating to the trusts and estates. The main changes include the following: 1 Amendments to VISTA 1 ...
IntroductionOn 6 June 2013 the Council of Ministers approved the bill to finalise the transposition of Directive 2003/49/ EC of the Council of 3 June into the IRC (corporate income tax) Code. The Directive, which establishes a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States, is commonly known as the ‘Interest & Royalties Directive’ ...
Serbia Following the last amendments to the tax laws, the Ministry of Finance has since prepared several rulebooks to help implement the amended legal provisions. Amongst these, the Rulebook on Transfer Pricing is the most important. Other rulebooks of the Ministry prescribe new forms of tax returns for tax payable on capital gains and income from the lease of movable and immovable assets, and newly introduced withholding tax on income from the sale of scrap and waste ...
The renewed focus on the ’global tax share’ of OECD countries relative to the global profits of multinationals has reignited the debate about the adequacy and transparency of tax information in Australia. The following article considers the viability of recent proposals. In April 2013, Australia’s Assistant Treasurer released a discussion paper – Improving the transparency of Australia’s business tax system – that outlined three options for reform in this area ...
