Corporate income tax (CIT) incentives granted during the period 2009-2013 have increasingly been challenged by tax authorities and particularly by state auditors with an inclination towards reassessment of such incentives ...
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 ...
The August 2016 issue of the Asian Legal Business (ALB) Asia Edition includes a regional update by SyCipLaw partner Maria Teresa Mercado-Ferrer entitled “A Need to Clarify Powers of the Philippine Economic Zone Authority and Local Government Units Relative to Peza-Registered BPO Companies”. The regional update can be found on page 15.Read the full ALB August 2016 issue for free ...
The Israeli Tax Authority (the "ITA") has recently published a draft circular ("Draft Circular") on the tax treatment of holdback payments and reverse vesting mechanism in the context of merger and acquisition transactions. According to the Draft Circular, subject to certain conditions as will detail below, the sale of shares to which holdback payments and reverse vesting mechanisms apply would be subject to a capital gains tax rate of 25% (30% in case of controlling shareholders) ...
Over the past few months the issue of offshore jurisdictions and the role they play in the global economy has come under extreme scrutiny, especially from onshore governments seeking to increase tax revenues. The recent Panama Papers Leak has only served to fuel the flame and has resulted in more people who know very little or nothing at all about offshore jurisdictions calling for their demise ...
African Union: Import tax introduced At its 27th summit recently held in Rwanda, the African Union (“AU”) decided to implement an import tax of 0.2% to be charged on all imports of goods (excluding basic necessities) in each member state. It is expected that EUR1-billion will be collected through this tax, making the AU financially autonomous. Morocco, the only African country currently not a member of the AU, is in the process of being reintegrated into the AU ...
It is common practice for suppliers to deliver the goods that they supply at the premises of their customers on the customer’s request. The suppliers then either deliver the goods themselves or they contract the services of third parties to deliver the goods on their behalf, for which they charge a delivery fee ...
The Draft Taxation Laws Amendment Bill of 2016 was released for public comment on Friday 8 July (the “2016 TLAB”). It proposes certain amendments to the rules currently contained in the Income Tax Act No. 58 of 1962 (the “Act”) dealing with employee-based incentive plans ...
general principles Legal professional privilege applies to communications between a client and legal advisor, where the legal advisor is acting in a professional capacity and is consulted in confidence for the purpose of the client obtaining legal advice (other than advice facilitating crime or fraud), and where legal professional privilege is claimed by that client ...
The AMC completed revision of its procedural rules on merger notifications. The new Merger Regulation significantly reduces disclosure requirements and simplifies filing forms, especially for mergers with no or limited overlaps ...
Pierre Denis, Étienne Brassard, Benjamin David Gross and Sibylle Ferreira, whose practices focus on business law, financing and aeronautics, contributed to the development of a Q&A guide entitled Aviation finance in Canada: overview and published in the first edition of Practical Law’s Aviation Finance Global Guide ...
ANGOLA: Securities Code Regulations enacted The Securities Code Regulation (Regulation No. 6/16) (the "Regulation") was approved by the Council of Administration of the Capital Market Commission and gazetted on 7 June 2016. The Regulation contains the organisation rules and administrative requirements for open companies and other issuers of securities admitted to trading in regulated markets ...
Timeline 20 August 2013: The South African National Assembly passes the Protection of Personal Information Bill [B9D of 2009] (“the Bill”) to give effect to the constitutional right to privacy. 19 November 2013: The Bill is signed into law by President Jacob Zuma and gazetted as the Protection of Personal Information Act 4 of 2013 (“POPI”) ...
Over the past year, the broad-based black economic empowerment (“B-BBEE”) landscape in South Africa has been completely overhauled and has become more stringent ...
In October 2015, the Organisation for Economic Cooperation and Development (“OECD”) published its final reports on the Base Erosion and Profit Shifting (“BEPS”) project, including the final report on BEPS Action 13, Transfer Pricing and Country-by-Country Reporting(“Action 13 Report”) ...
The Taxation Laws Amendment Bill 2016 has been released for public comment. It introduces various interesting amendments to South Africa’s tax law, which include the following: Use of trusts In circumstances where an interest-free loan has been advanced to a trust by a connected person (which includes a beneficiary or a relative of a beneficiary), it is proposed that a market-related rate of interest (currently 8%) is deemed to be paid on that loan ...
One of the key elements addressed in the Draft Reviewed Broad Based Black-Economic Empowerment (“BBBEE”) Charter for the South African Mining and Minerals Industry, 2016 (the “draft reviewed Mining Charter”) is the issue of ownership. The Department of Mineral Resources (“DMR”) seeks to achieve the ownership requirement through broad-based employee share option plans (“ESOPs”), which are likely to have an impact on both mining companies and their employees from a tax perspective ...
The decision by the International Trademark Association (“INTA”) to host a major meeting in Cape Town – apparently the first INTA conference to take place on African soil – is highly significant. It certainly says a great deal about the continent's growing economic importance. The conference takes place on 1 – 2 September 2016 and it’s entitled “Building Africa with Brands” ...
On July 27, 2016, the Securities and Insurance Superintendence (“SVS”) issued the general rule 410 (“NCG 410”), which supplements the list of entities that qualify as “institutional investors” according to article 4(e) of the Securities Market Law N°18,045 (“LMV”) ...
TAXPAYER REGIME A REGIME B METHOD FOR EXERCISING THE OPTION Public Corporations, Closed Corporations and “Sociedad en Comandita por Acciones”. N/A Mandatory regime. N/A Individual Companies and Individual Limited Liability Companies. Applicable provided the owner of the company is: (i)an individual domiciled or resident in Chile; and/or (ii)an individual or entity domiciled or resident abroad (together as “Final Taxpayers) ...
Implementation of Prakas on minimum registered capital of banking and financial institutions,Circular № B7-016-117 C.L, dated 16 June 2016This Circular, issued on 16 June 2016, aims at implementing Prakas №B7-016-117 on Minimum Registered Capital of Banking and Financial Institutions (“BFIs”), dated 22 March 2016 (“Prakas №B7-016-117”), in relation to procedures for increasing the minimum registered capital requirements of BFIs ...
As per Notification No. 039 issued by the Ministry of Economy and Finance (MEF) on 21 July 2016, a working group consisting of representatives from both the General Department of Taxation (GDT) and the Phnom Penh Municipality will begin to collect data from all enterprises in Phnom Penh from August 2016 onwards. Representatives of the working group will physically visit all enterprises in Phnom Penh for the purpose of: 1. Gathering the enterprise’s statistics; 2 ...
