On 2 July 2021, the Government gazetted the Securities and Futures (Amendment) Bill 2021 and the Limited Partnership Fund and Business Registration Legislation (Amendment) Bill 2021 (Bills). These new laws aim to open up new channels enabling foreign investment funds to be re-domiciled and registered in Hong Kong as open-ended fund companies (OFCs) or limited partnership funds (LPFs) ...
Contents Please click on the links below to jump to the relevant section: Legislation Relevant entities Relevant activities Tax residence requirements Guidance General requirements Directed and managed Core-income generating activities (CIGA) Premises Employees and personnel Expenditure Enhanced requirements Reduced requirements Outsourcing Enforcement authorities Reporting formalities Demonstrating compliance Penalties Recent developments Legal framework Legisl
The High Court has considered emergency response measures affecting the aviation sector. In two recent cases, aircraft lessors tried to enforce their lessees’ payment obligations, but were met with arguments that the leases had been frustrated. A contract is frustrated when an event arises after its formation and renders performance impossible, illegal or radically different from that which the parties had contemplated ...
When an employment relationship comes to an end, it is not uncommon for the parties to enter into a termination agreement setting out the departing employee’s rights and obligations. A question naturally arises as to whether, and to what extent, these benefits are chargeable to salaries tax ...
Contents Abstract What is an asset protection trust? Conflict of laws What is the objective of firewall legislation? What is the objective of fraudulent transfer legislation in a trust context? Jurisdiction Does comity continue to undermine firewalls? Simplification of structure of Bermuda's firewall legislation Extension of Bermuda's firewall When is a foreign order 'inconsistent' with the firewall legislation? Conclusion ABSTRACT View More
On May 28, 2021, President Biden released some of the legislative items that would be added by his American Families Plan, which includes a provision that could impact tax information reporting by financial institutions. If enacted, this proposal could require substantial effort to implement and administer. President Biden’s American Families Plan includes a provision which would increase the information reporting compliance requirements for financial institutions ...
For the past 25 years, Peru has been undergoing comprehensive economic growth, followed by a modernization and development process, which includes the establishment of a reliable legal framework geared towards maintaining the stability required to promote private sector activity and investment. This continuous growth has been the best incentive to attract substantial foreign investment in various industries ...
Financial ServicesTransition from LIBORIn this article, Krystle Lui Shu Lin reports on the transition from LIBOR rates to risk-free rates ...
On July 1st 2021, the Russian President signed a draft law on amendments to the Russian Civil Code, establishing the possi-bility of creation of a new type of non-commercial organization - a personal foundation- from March 1st 2022.Purposes of using personal foundationsThe personal foundation will become a new asset planning instrument, after the detailed legislation comes into force ...
The economic substance requirements in the Cayman Islands, introduced by the International Tax Co-operation (Economic Substance) Act (as revised) (the “ES Act”) (Economic substance requirements in the Cayman Islands), have been extended to partnerships pursuant to the International Tax Co-operation (Economic Substance) (Amendment of Schedule) Regulations 2021, which came into force on 30 June 2021 ...
Thailand’s Personal Data Protection Act B.E.2562 (“PDPA”) governs the cross-border transfer of personal data. The PDPA sets out a condition, among other things, that personal data may be transferred to another country or to an international organization (the “Recipient”) provided that they have in place an adequate level of personal data protection according to the adequacy decision as decided on by the Personal Data Protection Committee ...
In the first article of this three-part series we looked at the future of personal transport. In this second piece, we turn to consider mass public transport and how it could play a significant part in the future of commuting. Birmingham is beginning to make substantial changes to its transport infrastructure, but are the changes big enough? The Metro Opened on 30 May 1999, the West Midlands Metro provided a link between Wolverhampton and Birmingham ...
Wednesday June 30 2021 is when the Stamp Duty ‘holiday’ in its current form at least will end. The Chancellor, Rishi Sunak, introduced the temporary Stamp Duty Land Tax (SDLT) in July 2020 to boost the housing market following the first national lockdown. The aim was to save buyers from paying stamp duty on any properties valued at up to £500,000 – a saving worth up to £15,000 ...
1. What are the new procedures for availing of tax treaty benefits? The Bureau of Internal Revenue (BIR) issued Revenue Memorandum Order (RMO) No. 14-2021, as amended by Revenue Memorandum Circular (RMC) No ...
Dinsmore partner Kelvin Lawrence was published in Bloomberg Tax with co-author Bruce P. Ely from Bradley Arant Boult Cummings LLP. Their article, "The MTC Undertakes an Ambitious Study of Partnership Taxation," discusses the Multistate Tax Commission (MTC) Uniformity Committee's work group they created to study issues related to multistate taxation of pass-through entities ...
According to an anonymous source, a ‘Centre for Economic Situation Administration’ (“CESA”) meeting chaired by Prime Minister Gen Prayut Chan-o-cha was held on Friday 4 June that approved (in-principle) a set of proposed stimulus measures aimed at encouraging wealthy expatriates to Thailand ...
Recent developments such as the invalidation of the EU-U.S. Privacy Shield framework under the Schrems 2.0 decision and Brexit will have a significant impact on how businesses transfer their data internationally. Recap: For more information see our previous webinars: on the Schrems 2.0 case: What is the Schrems 2.0 case about? on Brexit 2 ...
There are plenty of articles which set out the "hard facts" of Freeports - the locations, tax benefits etc. - but are we all missing the real point? One of the key objectives of the UK government was to "create hotbeds for innovation" ...
On March 11, 2021, Christie’s auction house made a landmark sale by auctioning off an entirely digital artwork by the artist Beeple, a $69 million transaction in Ether, a cryptocurrency.1 In doing so, the famous auction house put non-fungible tokens (“NFT”), the product of a decentralized blockchain, in the spotlight ...
The term «næringsdrivende» (business activity) in the Norwegian Foundation Act shall be understood as activity with taxable profit («erverv til formål») The Ministry of Trade, Industry and Fisheries’ work on amending the Norwegian Foundation Act has been going on for several years, cf. proposals for a new Foundation Act in the NOU 2016: 21. Further law amendment proposals have now been proposed in a public hearing ...
Birmingham - the nation’s second city and one that has changed greatly over the last twenty years. One thing that has not changed, however, is that Birmingham is a big polluter. Continuing growth, both in terms of the population and economy, has left the air quality in such a poor state that Birmingham City Council estimates up to 900 people per year die from diseases associated with air quality ...
On 2 June 2021, four months after the UK’s formal application, it was announced the UK can start the process of joining the 11-country Comprehensive and Progressive Agreement for Trans-Pacific Partnership (“CPTPP”) ...
Shoosmiths latest SAMBA aviation webinar on 20 May attracted around 50 delegates to listen to our panel guests share their views on how recent events, including COVID, Brexit and climate change, have shaped the aviation sector today and how they might influence its future. Hosted by Elliot Bishop (Head of Shoosmiths Luxury Asset Group) and Sarah Fairweather (Joint Head of Marine and Aviation) ...
Dear valued clients, colleagues and friends, In this article, our partner, Anand Raj, and associate, Jeevitha Thurai Rathnam, discuss the Malaysia Competition Commission’s market review exercise into the transportation sector (port logistics ecosystem and motor vehicle warranty claims) ...
The IVAucher programme was set up to stimulate private consumption in the sectors worst affected by the economic impact of the COVID-19 pandemic (catering, accommodation and culture). With regard to these sectors, “catering” is used in the broad sense to cover restaurants, cafés, bars and catering companies providing food and beverage services, and “accommodation” refers to hotels and other short-stay accommodation for holidays and business travel ...