Tackling base erosion and profit shifting remains a priority for the National Treasury and the South African Revenue Service (“SARS”). It was recently reported that in the 2021 fiscal year, SARS dealt with 345 cases of transfer pricing, base erosion and profit shifting to the value of almost ZAR12-billion. Yet, only three South African courts have dealt with transfer pricing ...
Under Notice 2022-33, the Internal Revenue Service (IRS) has extended the deadline for adopting amendments to qualified retirement plans and individual retirement accounts (IRAs) to reflect certain changes made by the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), the Bipartisan American Miners Act of 2019 (Miners Act), and the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) ...
November 1, 2022 By: Jeffrey M. Dennis The amended California Consumer Privacy Act (CCPA), sometimes referred to as the California Privacy Rights Act (CPRA) or Proposition 24, takes effect on January 1, 2023 – and introduces new consumer rights, while significantly increasing compliance pressures on companies who do business in California. With less than 60 days before the amended CCPA launches, the time for compliance is NOW ...
Dr Michael Psaila and Dr Frank B. Testa, are attending the International Bar Association (IBA) Annual Conference being held at the Miami Beach Convention Centre from 30 October to 4 November. Please reach out to them if you would like to meet up ...
You may have seen news items discussing a South African copyright case that deals with blind people’s rights to access books. It’s perhaps not that easy to follow, so we’ll try to make it as simple as possible. South African copyright law has been slow to evolve The South African Copyright Act dates back to 1978 ...
THE LINDT BUNNY The company Lindt & Sprungli is the maker of the famous Lindt chocolate bunny. The product comprises chocolate in the shape of a squatting bunny, wrapped in gold foil with a red ribbon and a small bell. The chocolate bunny is a very big seller around Easter time, with sales in the tens of millions ...
In this article, we’ll discuss three copyright-related stories that have made headlines and contain some interesting lessons. ED SHEERAN (YES, AGAIN) We recently discussed the well-publicised case where Ed Sheeran successfully fought off a UK High Court copyright claim relating to his song Shape of You. When the verdict was announced, Sheeran said that he hoped that there would be no more “baseless” copyright claims ...
In November 2022, South Africa is expected to present a report to the Financial Action Task Force (“FATF”) on the steps it has taken to address the shortcomings identified in the Mutual Evaluation Report concluded last year ...
Instruction No. 26118 GDT on the Use of Official Exchange Rate for Self-Assessment Taxpayers dated 28 October 2022 (“Instruction 26118”) has abrogated Instruction No. 10362 GDT, dated May 17, 2022 (“Instruction 10362”) ...
With this continued interest, a number of Singapore are managers using Jersey as the jurisdiction in which to domicile their funds. This choice is driven by several factors. Singapore tax treatment of digital assets. Digital assets do not fall within the definition of a “designated investment” for the purposes of Singapore tax legislation. This means that a Singapore domiciled fund will be subject to tax in the country, and such tax leakage is hugely unattractive to investors ...
October is Breast Cancer Awareness Month, an annual campaign to raise awareness about the impact of breast cancer and to raise funds for research into its cause, prevention, diagnosis, treatment and cure. The firm held an event last week at its offices with staff in order to raise awareness about breast cancer and to raise funds for the cause. The firm is once again making a contribution to the Action for Breast Cancer Foundation ...
Kongwat Akaramanee, senior associate of Kudun and Partners together with associate; Attapon Tanasanti were invited to speak at the 5th AFBR Club seminar on the topic “How do family businesses relate to sustainability?” organized by the Association of Family Business Entrepreneurs (AFBE). In an exclusive setting consisting of no more than 20 participants, the team shared insights on the important factors in making a will for a family ...
The concept of “natural capital” seeks to recognise the role of nature as an asset which is key to the sustained functioning of human social and economic activity. Examples of natural capital include clean air, water supply, plant life, animals, soil and minerals ...
On October 21, 2022, Kudun and Partners’s China Practice team participated in the 30th Anniversary Business Networking and Exhibition organized by the Thai-Hong Kong Trade Association (“THKTA”) = at the Peninsula Bangkok ...
On 13 October 2022, Shoosmiths hosted a webinar on the UK Covid-19 Inquiry (the ‘Inquiry’). The webinar took a closer look at the structure and progress of the Inquiry, alongside the commercial and legal considerations that any potential witness or party should be aware of, including the role of a Core Participant (‘CP’). The webinar was hosted by Paul Eccles (Partner) and included talks by Alex Friston (Associate) and Charles Arrand (Partner) ...
The Royal Government of Cambodia will continue its relief measures to mitigate the economic impact of Covid-19 and support the recovery of the country’s tourism sector, according to an official announcement on 25 October 2022 ...
Thanyaluck Thongrompo, partner of Kudun and Partners, was invited to be a speaker at the Faculty of Law, Maejo University on the topic “International Trade: Regulatory Issues on Import and Export” where she shared her knowledge and experience in handling import and export matters in Thailand. This webinar is a part of the law students’ academic program that focuses on Law of Cross-Border Trade Economics ...
The Government of Malta reaffirmed its commitment to establishing Malta as a go-to jurisdiction for start-ups in its Budget for 2023. During the budget speech that was delivered on 24th October 2022, the Minister for Finance and Employment, Hon. Clyde Caruana announced that a one-stop shop for start-ups is set to be launched within the “Start in Malta” programme currently run by the Malta Enterprise ...
What is the ROE? The ROE is a UK wide register created through the Economic Crime (Transparency and Enforcement) Act 2022, administered by the Registrar of Companies for England and Wales. A key aim of the legislation is to obtain and record details of property located anywhere in the UK held by overseas entities as well as to ascertain details of the beneficial owner(s) of such overseas entities ...
Due to the impact of the COVID-19 pandemic, many employers have seen an increased demand for international remote working arrangements. We have briefly touched upon the OECD guidelines relevant to these arrangements in a prior article ...
Alleged base erosion and profit shifting activities of multinational enterprises (“MNEs”) have been a hot issue globally and therefore the chances of an MNE being confronted with a transfer pricing audit have increased substantially over the last few years ...
On 6 October 2022, as part of the ongoing work of the OECD/G20 Inclusive Framework (“IF”) on Base Erosion and Profit Shifting (“BEPS”) to implement the Two-Pillar solution to address the tax challenges arising from the digitalisation of the economy, the OECD released its progress report for comment. Background The report was prepared for the purposes of obtaining further input from stakeholders on the administration and tax certainty aspects of Amount A ...
Under the Renewable Energy Act (Republic Act No. 9513) (the “RE Act”), it is a policy of the state to increase the utilization of renewable energy (“RE”) by institutionalizing the development of national and local capabilities in the use of RE systems ...
Recently, President Biden announced an executive order to pardon all federal marijuana possession charges. The President also urged governors to do the same at the state level saying, “Just as no one should be in a federal prison solely due to the possession of marijuana, no one should be in a local jail or state prison for that reason, either.” While President Biden’s pardons signal a step toward overhauling U.S ...
