Whilst the revised National Planning Policy Framework (NPPF) contains a number of potentially game changing new policy proposals, many of the changes aim to re-wind the clock to the pre-December 2023 version of the NPPF. This is to encourage short-term growth through restored stability in the planning system ...
Shipping and Bermuda’s Corporate Income Tax Act The initial taxing determination You have determined that you have a shipping entity within a “Bermuda Constituent Entity Group”, which itself is within an “In Scope MNE Group” for the purposes of the Tax Act. Furthermore, you have already made various adjustments to the taxable income in accordance with Part 6 of the Tax Act ...
Following the adoption of Greater Manchester's Places for Everyone strategy, Shoosmiths brought together real estate experts for a roundtable discussion on approaches to new development, redevelopment, renewable energy provision, and decarbonisation. Greater Manchester has raised the bar for new commercial and residential development in recent years, with cranes now a permanent fixture on a skyline famous for high-rises and construction projects ...
Transfer Pricing rules are fundamentally based on the Arm’s Length Principle, articulated in art. 9 of the OECD Model Tax Convention. This principle is pivotal for bilateral and multilateral tax treaties to avoid double taxation, reiterated in point 1.6 of the OECD’s “Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ...
The much-anticipated Court of Appeal judgment in C.G.Fry & Son Ltd v SSLUHC [2024] EWCA Civ 730 was handed down on Friday 28 June 2024. It dismissed the appeal on all three grounds. The case was centred on the widespread issue of developments being required to demonstrate that they are ‘nutrient neutral’, so as not to add nutrient load on designated habitats ...
The Supreme Court has overturned the Chevron Doctrine–a four decade-old ruling that enabled Federal agencies, including the Internal Revenue Service (“IRS”), to interpret ambiguous laws passed by Congress, and to have such interpretations enjoy a significant degree of deference ...
On June 17, 2024, the Chilean Comptroller General of the Republic ("Comptroller") approved DS No. 13 of 2022, of the Ministry of Energy ("Decree"), which (i) amends the regulation of gas installers; and (ii) approves the Safety Regulation of Hydrogen Installations (the "Regulation"). Following the approval by the Comptroller, the decree will enter into force once it has been published in the Official Gazette, notwithstanding the transitory provisions regulated therein ...
On May 30, 2024, the Comptroller General of the Republic (“Comptroller”) approved Supreme Decree No. 70 (“Decree”), which amends, mainly, (i) the Supreme Decree No. 62, of 2006, of the Ministry of Economy, Development and Reconstruction (“DS 62”), which approves the Regulation of Power Transfers between Generating Companies established in the General Law of Electric Services, and (ii) the Supreme Decree No ...
Our Energy practice group has been following the progress of the legislative project which aims to clarify the requirements and processes for offshore wind power in the Finnish exclusive economic zone ("EEZ"). On 23 May 2024, the Finnish Ministry of Economic Affairs and Employment ("Ministry") held a third stakeholder meeting to inform and discuss in detail the draft government proposal, which has just been submitted for consultation ...
With the first UAE corporate tax registration deadline looming (31 May 2024), companies and other businesses need to ensure that they have checked their deadline to register as a taxable person.The registration process under the Federal Law No. (47) 2022 (CT Law) is still new to the UAE and 2024 marks the first mandatory year for companies to register with the Federal Tax Authority (FTA) as a taxable person ...
Last month, Shoosmiths hosted a second event with leading industry body, Regen on REMA, The UK’s Review of Electricity Market Arrangements – Second Consultation, which closed [this week ]. The event featured insights from Dan Osgood, the director of energy markets and analysis at Department for Energy Security and Net Zero, as well as a number of expert panel discussions around the key parts of the consultation ...
Cabinet Office has developed and published a standard Carbon Reduction Contract Schedule which provides standard terms and conditions to support contract-specific decarbonisation objectives to be set and delivered and provides a framework to monitor and assess the Suppliers’ decarbonisation performance ...
Shoosmiths’ energy & infrastructure partner Chris Pritchett hosted a panel discussion at the Solar and Storage Live London last week, focussing on the often-overlooked elements of the low carbon transport transition, namely accessibility, regional parity, and the regulatory and industry code barriers to rolling out some of the solutions that this transition so desperately needs ...
SyCipLaw's Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the first quarter of 2024. The SyCipLaw T.I.P.S - International Edition covers the following tax issues: 1. Are informal settlement agreements between the Commissioner of Internal Revenue and the taxpayer valid and binding? 2. While a tax case is pending in court, may the CIR and the taxpayer enter into a compromise agreement and request for judicial approval thereof? 3 ...
On 12 April, the Cabinet Office published the second tranche of its official guidance documents on the Procurement Act. The guidance documents cover: The National Procurement Policy statement (‘NPPS’); Technical Specifications; Pipeline Notices; Planned Procurement Notices; and Preliminary Market Engagement. Each guidance document clearly sets out the key points and the policy intent in respect of these discrete parts of the Procurement Act ...
The EU published a report on 18 April 2024, ‘Much More than a Market’.1 The reasons behind the call for the report are the EU’s concerns that just over 30 years after its creation there are important aspects of the Single Market that are not complete, and that the world is very different to what it was 30 years ago ...
On March 28, 2024, the Department of Finance Canada announced a one-year extension to the 15% Mineral Exploration Tax Credit (?METC?) available to investors in flow-through shares. The extension means that the METC will be effective until March 31, 2025. This announcement came at a time when uncertainty loomed over the industry and some stakeholders feared that the government would not renew the METC. Over time, this tax credit has become a key component of flow-through share financings ...
SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for February.The February 2024 issue covers the following tax issues:1. What is Republic Act No. 11976 and why is it relevant to tax?2. Are cross-border services provided by non-resident foreign corporations now subject to income tax and VAT under Revenue Memorandum Circular No. 5-2024?Please read the full texthereor via thislink ...
British Virgin Islands Economic Substance - frequently asked questions Who has to comply with the Substance Legislation? All companies and limited partnerships that are registered or incorporated in the British Virgin Islands (“Entities”) must comply with the Substance Legislation. The Substance Legislation does not apply to trusts or general partnerships ...
There are three main challenges to increasing competition in the availability of enroute charging stations, especially at motorway service area (MSA) sites, and the common theme is cost. The main challenges are: High costs for connecting to the electricity network, which acts as a key barrier to charge point operators (CPOs) investing at MSA sites. Limited competition at MSA sites, which is linked to the high costs for connecting to the electricity network ...
On January 1, 2024, regulations implementing the Corporate Transparency Act (“CTA”) became effective, triggering new reporting obligations for many entities conducting business within the United States ...
Ahead of International Data Centre Day on 20 March 2024 we consider what we believe to be some of the most important trends that are likely to have an impact on the data centre industry over the next 12 months: 1 ...
Although it is not often well-understood in business and tax circles, the Indian Act (the ?Act?), coupled with federal and provincial tax laws, provides several tax planning opportunities for Indigenous taxpayers. These laws provide various tax exemptions for people who qualify as ?Indians? under the Act, as well as for ?bands? and other ?councils ...
SyCip Salazar Hernandez & Gatmaitan (SyCipLaw) senior partner Carina "Caren" Laforteza and special counsel Catherina "Kate" Fernandez discuss the taxation of AI in light of recent developments concerning the concept of situs of taxation as interpreted by the Bureau of Internal Revenue (BIR), the local tax authority in the Philippines ...
