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) ...
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 ...
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 ...
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 ...
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 ...
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 ...
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) ...
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 ...
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 ...
TAXATION TAX ON IMMOVABLE PROPERTY PAYMENT FOR 2016 Notifications No. 12723 dated 5 August 2016 & No. 13466 dated 16 August 2016 Per Notification No. 12723, the General Department of Taxation (“GDT”) informs owners of immovable property (“Property”) which is subject to the Immovable Property Tax (“IPT”) to pay the IPT to the tax authorities by 30 September 2016. Late payment of IPT is subject to penalty ...
Corruption is a scourge which transcends frontiers. In response to this situation, Canada has chosen to pass the Corruption of Foreign Public Officials Act (hereinafter referred to as the "CFPOA") in 1998, then reinforced the regime thereof more recently. The difficulty with this Act lies in the fact that the offences must have been committed abroad. International cooperation thus remains essential to its application. The difficulties related to the transnational nature of corruption are real ...
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 ...
The Second Eastern Economic Forum was held on 2nd and 3rd December in Vladivostok. The participants presented various investment projects ready for implementation. On 3rd September Maxim Alekseev, ALRUD Law Firm Senior Partner, participated in Russia-ASEAN session. Its primary topic was discussion of the declaration on main areas of cooperation between Russia and ASEAN adopted on Russia-ASEAN summit held in Sochi on 19-20 May, 2016 ...
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 ...
Africa Tax in Brief Ethiopia: Treaty and amending protocol with the Netherlands enter into force The Ethiopia-Netherlands Income Tax Treaty, 2012 and the exchange of notes, signed on 10 August 2012, entered into force on 1 September 2016, and the amending protocol to the treaty, signed on 18 August 2014, will enter into force on 30 September 2016. The exchange of notes generally applies from 1 September 2016 ...
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 ...
