Contents* Quebec Modernizes its Corporate Law * Choosing a Name you Intend to Keep * Deemed Year-End on Loss of CCPC Status: One Possible Solution * Renewal Option or Privilege QUEBEC MODERNIZES ITS CORPORATE LAWValérie [email protected] Bill 63 – The Business Corporations Act was tabled before the National Assembly on October 7, 2009 and assented to on December 4, 2009 ...
Dear Sirs, We would like to present you a brief overview of tax legislation updates concerning transfer pricing and VAT on services upon importation of goods into the territory of the Russian Federation. Draft law On Transfer Pricing We would like to pay your attention to the fact that draft law “On transfer pricing” was accepted by the State Duma in the 1st reading ...
Historically, a significant number of states had a general policy of respecting the form of a transaction chosen by a taxpayer and applied their sales tax laws based on that form of transaction ...
The Australian Taxation Office's unsuccessful attempt to freeze the bank accounts of the private equity firm Texas Pacific Group has highlighted the ATO's new focus on private equity activities in Australia. The attempted freeze followed the stock market float of the Myer Group, as the ATO sought a reported tax bill of $A452 million from TPG ...
The Foreign Investment Review Board (Board), being the Australian government body that examines proposals for foreign investment in Australia, recently announced that the monetary thresholds set for the purposes of compulsory notification to the Board of a proposed acquisition will be revised to: AUD231 million, for private business investment (up from AUD219 million); and AUD1004 million, for US investors under the Australia-US Free Trade Agreement (up from AUD953 million) ...
The Russian Federation, the Kazakhstan Republic and the Belarus Republic (hereinafter also referred to as the “Member States”) have formed Customs Union in accordance with the Treaty on Creation of Unified Customs Territory and Formation of Customs Union (Dushanbe, October 6, 2007) ...
Following the recent actions taken by the Australian Taxation Office to freeze the bank accounts of the private equity firm TPG, the Commissioner of Taxation has released two draft Taxation Determinations (TDs): TD 2009/D17 Treaty Shopping - Can Part IVA of the Income Tax Assessment Act 1936 apply to arrangements designed to alter the intended effect of Australia's International Tax Agreements network?; and TD 200
In light of the ineffectiveness of tax litigation and the increased mistrust of taxpayers in relation to tax decisions, with the decision-makers very often hiding behind mere decisions of form, it is imperative that we weigh up alternative methods for resolving tax disputes, such as mediation, conciliation, and tax arbitration itself, in order to deal with disputes accumulated and arising out of relations between the State and the taxpayer, thus reversing the fe
Following the public discussions which took place after the approval of the Decree-Law no. 317/2009 of 30 October (Decree-Law 317/2009)[1], Decree-Law no. 3/2010 of 5 January (Decree-Law 3/2010) was published in the Official Gazette, imposing a prohibition on credit institutions to charge on automated teller machines[2] (ATM) transactions, as well as, a prohibition on beneficiaries to charge payment transactions in automatic payment terminals and devices[3] ...
Interest rates have remained at an all time low of 0.5% for 10 months in a row and the Bank of England is continuing with its quantitative easing programme. It has been upped to a £200bn asset purchase programme to increase the money in the UK’s financial system and boost bank lending. Meanwhile, total government debt is projected to rise to £1.4 trillion, nearly doubling to 80% of GDP ...
We would like to present you an overview of the most valuable changes in Tax legislation effective since January 1, 2010. Also we would like to point out the recently adopted Decision of the Presidium of the Supreme Arbitrazh Court of the Russian Federation significant from the tax standpoint ...
The transfer tax situation for 2010 could hardly be more confusing. A last-ditch effort in the Senate to extend the 2009 rates and exemptions was blocked by Senators who support repeal or higher exemptions and lower rates. Supporters of continuing the 2009 rules ($1 million gift tax exemption, $3 ...
The Government of the Republic of Indonesia has entered into over 60 agreements on avoidance of double taxation with other countries. These agreements normally state the scope and the parties who are entitled to avoidance of double taxation benefit. In practice, some parties may abuse the avoidance of double taxation by structuring a transaction in a certain way ...
As an initiative to develop Islamic finance and Islamic fund management in Hong Kong, the SFC signed a Declaration on Mutual Cooperation on Development of Islamic Capital Market and Islamic Collective Investment Schemes (Declaration) with the Securities Commission of Malaysia (MSC) on 9 November 2009, which provides a framework for the mutual recognition of Islamic funds (excluding hedge funds, wholesale funds and real estate investment trusts as defined in the
Chapter 10.2 of the SFC's Code on Unit Trusts and Mutual Funds (Code) requires that pricing errors for SFC authorised funds should be corrected as soon as possible and all necessary action should be taken to avoid errors occurring in the future. If the pricing error results in an incorrect price of 0 ...
As a consequence of the recent wave of successful SFC insider dealing criminal prosecutions, responsible officers (ROs) are asking what they need to do to protect their companies and themselves. ROs are obliged to take all reasonable measures to ensure that proper safeguards exist to prevent the licensed corporation and its employees from insider dealing ...
Following the public consultation early this year on proposals for a legislative framework to upgrade the current anti-money laundering (AML) regime in the financial sector, Hong Kong's Financial Services and Treasury Bureau (FSTB) has launched a second-round consultation ...
Under the Tobacco acT (r.s.Q., c. t-0.01), employers mUst prohibit their employees from smoKing inside their establishments. howeVer, the act is mute on no smoKing oUtside, on the company’s land ...
THE CONFIDENTIALITY AGREEMENT, CAN YOU LIVE WITHOUT IT?Patrice André [email protected] are advising a client who is selling his business. The parties have already signed a letter of intent that provides for a due diligence review to be conducted in respect of your client’s business ...
We would like to draw your attention to the upcoming valuable updates in Tax legislation. Below we have placed a short overview of the hottest issues already occurred in Russian tax environment and some to be introduced in the nearest future. Respectively, these incentives are proposed either to overcome consequences of the financial crisis, or to realize the next step of the long-term policy of stabilization and modernization of the Russian tax system ...
At the same time, the effective rate of tax on dividends for high earners will rise from 25% to 36%. No changes are currently proposed to the rate of capital gains tax which means it will remain at 18%. However, both main parties have now admitted that further tax increases are likely. With the gap between income tax and capital gains being a massive 32%, it seems unlikely that the current generous rate of capital gains tax will remain in place ...
When a company goes into administration, a statutory moratorium takes effect to help the administrators achieve the objectives of the administration. Amongst other things this means that no legal process can be started or continued against the company without the consent of the administrators or the court ...
Self-regulation of retail banking came to an end on 1 November 2009 with the establishment by the Financial Services Authority (FSA) of a new banking conduct regime. This new regime largely replaces the voluntary Banking Codes and comprises: 1 ...
Several countries have already introduced the concept of “temporary non-residents” into their tax orders, thus enabling them to lay down special rules regarding the taxation of income received by those who are habitually resident in these countries, but take up residence in another country for a certain period – which as a rule does not exceed 5 years and is very often a result of secondment - and subsequently return to their former country of residence ...
