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 ...
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 ...
The October 2016 issue of the Asian Legal Business (ALB) includes a regional update article entitled “New Implementing Rules for Philippine Data Privacy Act”, contributed by SyCipLaw partner Rose Marie M. King-Dominguez. The article enumerated and discussed the implementing rules and regulations of the Philippine Data Privacy Act of 2012. It is located on page 11. Read the full ALB October 2016 issue on the ALB website ...
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 ...
The July/August issue of the International Financial Law Review (IFLR) included an international briefing article entitled “Promoting Foreign Investment”. The article was contributed by SyCipLaw partner Carina C. Laforteza and associate Lito Paolo T. Martin II. The article discussed the enactment of Republic Act No. 10881, which was set to make the Philippine sa more attractive destination for foreign investors in the financing industry ...
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) ...
The Philippine Competition Commission (PCC) has issued its first merger clearance under the implementing rules and regulations of the Philippine Competition Act. The clearance was for the proposed acquisition by Sanofi of the CHC business of Boehringer Ingelham. SyCipLaw acted as Philippine antitrust counsel to Sanofi. Download the Client Alert for more information on the first merger clearance of PCC under the Philippine Competition Act ...
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 ...
The September 2016 issue of the Asian Legal Business (ALB) Edition included a regional update article entitled “Anti-Corruption Laws in the Philippines”, contributed by SyCipLaw partner Ronald Mark C. Lleno, and Associate Rhey David S. Daway. The article discussed examples of prohibited corrupt practices under Philippine law. It is located on page 16. Access the full ALB September 2016 issue online ...
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 ...
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 ...
From August 30th of 2016, the Hague Convention Abolishing the Requirement of Legalization for Foreign Public Documents, commonly known as the “Apostille Convention”, and which changes the legalization process of foreign public documents, will enter into force in Chile. This treaty was signed on October 5th, 1961, and on December 2015 Chile completed the procedures to ratify it. In order to enforce this convention in Chile, Law No ...
According to recent media reports, Minister of Trade, Tourism and Telecommunications in Serbia's newly formed government, Rasim Ljajic, stated that a free trade agreement between Serbia and the countries of the Eurasian Economic Union (EEU) should be signed come November, while outlining that at this stage, the matter is out of Serbia's hands and fully dependent on the EEU ...
On taxation of electronic services from 2017 Dear Ladies and Gentlemen, The law “On Amendments to Parts I and II of the Tax Code of the Russian Federation” comes into force on January 01, 2017. Pursuant to the adopted changes, starting from 2017 foreign companies which do not have permanentestablishment in Russia and provide electornic services to individuals inRussia will be required to register with the Russian tax authorities and pay VAT in Russia. 1 ...
An interesting piece of news in the sphere of tax law has recently been provided by the Court of Justice of the European Union (CJEU) decision that found Portuguese withholding tax rules to be breaching EU law.The case concerns a loan given to Auto Estradas do Litoral SA ("Brisal"), a Portuguese company by the Irish bank – KBC Finance Limited ...
