Section 64E(1) of the South African Income Tax Act, 1962 (the “Act”) provides that dividends tax must be levied at a rate of 20% of the amount of any dividend paid by any company, other than a headquarter company. In terms of section 64EA(a) of the Act, the beneficial owner of a cash dividend is liable for dividends tax in respect of that dividend. However, in terms of section 64F(1), a cash dividend is exempt from dividends tax in various instances ...
Earlier this year, right in a last minute attempt to win undecided voters for one of the political parties, the leaving members of parliament enacted a new tax law. While fundamental changes to the Austrian Tenancy Law had been vividly discussed between the socialist and the conservative parties in recent years, the new law on the abolition of stamp duty falls completely short of what could have been achieved ...
If your estate plan was put in place more than 3 years ago, the plan is likely designed to save estate taxes at the sacrifice of income tax benefits. Estate tax is no longer a concern for married couples owning less than $11 million of assets. We recommend reviewing your estate plan to confirm that it has the flexibility to adapt to tax law changes and to secure income tax benefits ...
Earlier this year, and the last time before next year’s parliamentary elections, the current Luxembourg Finance Minister presented the budget law for 2018 to the Parliament (Chambre des Députés) ...
As seen in NonProfit Pro With the recent state of natural disasters devastating communities both in the U.S. and abroad, many people turn to charities to see what they can do to help those affected by these tragic events. Over the past two decades, charitable giving has grown considerably in the U.S. The number of public charities is up almost 60 percent, from about 643,000 in 2000 to more than 1 million today, according to the National Center for Charitable Statistics ...
The United Arab Emirates (UAE) Federal Tax Authority (FTA) has commenced accepting registrations for Value Added Tax (VAT) through its online portal ...
ILPA’s Paper Earlier this year the International Limited Partner's Association (ILPA) published its paper "Subscription Lines of Credit and Alignment of Interests: Considerations and Best Practices for Limited and General Partners." Since then there''s been a lack of on the record industry commentary from general partners (GPs) on this paper, but it has not gone unnoticed and has triggered much discussion behind closed doors ...
Central America is at an inflection point regarding acceptable compliance and conformity. Among all the anxiety and instability that change will bring, it is welcoming to see that separate disciplines are pushing towards similar objectives in Corporate Governance. A quick discussion on Director´s Responsibility provides a glimpse on how new Governance issues will reshape slanted interpretations of the law ...
With virtual currencies such as Bitcoin becoming ever more popular and accessible, it is important that South African taxpayers carefully consider the tax and exchange control uncertainties that accompany the incorporation of these relatively new systems into businesses and/or investment portfolios. We highlight below some of the tax and exchange control consequences arising from transactions involving Bitcoin ...
Are bidders required to partner with a Taiwan company to participate in the bidding process? Foreign companies may participate in the bidding process on their own, so long as they meet the bidding qualifications. Most public engineering projects permit either bidding by a single company or by a joint bid. So long as a company is able to meet the qualifications for the procurement project, it may submit a bid on its own ...
The UAE has issued substantive law on Value Added Tax (VAT) and Excise Tax. Federal decree law No.8 of 2017 deals with VAT. The imposition of VAT will commence in the UAE from 1 January 2018 at a rate of 5%. The VAT law provides a framework for implementation of VAT in the UAE ...
The Israeli Tax Authority ("ITA"), published a list of instances whereby transfer of funds, through banking corporations, to foreign residents will be exempt from tax withholding ...
Under RERA, the promoter of a real estate project is obliged to obtain the requisite insurance policies required to secure the development of project and insurances as may be notified by the government. The lack of transparency and uniformity in the Indian real estate market has done little to entice insurance companies from tapping into lucrative land deals and developing insurance products for the real estate sector ...
Following the Luxembourg case C-274/15, the series of cases relating to the scope of the cost-sharing VAT exemption also referred to as “Independent Group of Persons” (“IGP”) continues with the release today of three judgements by the Court of Justice of the EU (“CJUE”): Aviva (C-605/15), DNB Banka (C-326/15) and European Commission v Federal Republic of Germany (C-616/15) ...
The final Default Regulations, issued in terms of section 36 of the Pension Funds Act, were recently issued by the South African Minister of Finance. They aim to provide retirement funds with greater discretion and flexibility in relation to their default investment portfolios and annuity strategies. To comply with the regulations, many funds will need to amend their rules and investment policy statement ...
In terms of the South African Income Tax Act, 1962 (the “Act”), distributions received by or accrued to a shareholder of a company may constitute either a dividend or a return of capital – each of which would give rise to different tax implications for the shareholder or company concerned ...
In the 2017 South African Budget speech, the Minister of Finance raised government’s concern that the current Controlled Foreign Company (“CFC”) rules do not capture foreign companies held by interposed trusts or foundations, and it was announced that countermeasures for the treatment of foreign companies held by trusts or foundations will be considered ...
After getting the knowledge of GPA Model and PPP Model, the bidders need to know how to make preparation during the pre-bid stage. Following are the responses to some most frequently asked questions regarding bidding qualifications, based on which the foreign bidders can make its preparation plan ...
On August 28, 2017, the California Supreme Court issued a 5-2 split decision in California Cannabis Coalition v. City of Upland, S234148. The Court held that a revenue measure proposed by citizen initiative is not “imposed by local government," and does not trigger the procedural limitations of Article XIII C of the California Constitution,[1] as a result ...
Position of Russian Federal Tax Authorities in respect of currency control regulation August 29, 2017 Dear Ladies and Gentlemen, This is to inform you that Federal Tax Authority of the Russian Federation published the Letter no. 3-H-3-17/5523@ dated July 16, 2017, in respect of the position regarding legitimacy of transactions of Russian residents on their foreign bank accounts which were not declared to the local tax authorities (the “Letter”) ...
On 27 August 2017, the United Arab Emirates (the "UAE") published the text of its domestic Value Added Tax (the "VAT") Law, shortly after releasing the text of its Excise Tax Law last week, and the Federal Tax Procedures Law earlier this month. It will be followed by implementing regulations, which will provide more detail on application of the VAT Law.The UAE Government is still planning to introduce VAT on 1 January 2018 ...
SyCipLaw Partners Imelda A. Manguiat and Carina C. Laforteza, Senior Associate Bhong Paulo A. Macasaet, and Associate Maricar G. Ramos contributed the Philippine chapter of Getting the Deal Through: Aviation Finance & Leasing 2017. The chapter addressed pivotal questions about air law and aviation financing and leasing. The scope and rules and regulations of owning, leasing, securing, financing and operating an aircraft were also discussed ...
The window period for South African residents to regularise their unauthorised foreign assets under the Special Voluntary Disclosure Programme (“SVDP”) closes on 31 August 2017. The current SVDP is the latest in a series of such opportunities offered by the Financial Surveillance Department of the South African Reserve Bank (“SARB”), beginning with the 2003 exchange control amnesty ...
