According to latest news reports, Plinovodi – the company managing Slovenian gas pipelines, will be brought under majority state control, while the energy company, Petrol, is due to secure a majority stake in the gas wholesaler Geoplin under a contract signed this month. It should be noted that the Slovenian Sovereign Holding (SSH) and Petrol are currently the largest Geoplin shareholders. Geoplin, in turn, is the sole shareholder of Plinovodi ...
In our blog post from July 25, 2016 we highlighted the provincial government’s introduction (effective August 2, 2016) of the new 15% property transfer tax (the “Foreign Entity Tax“) on foreign buyers of residential property in the Greater Vancouver Regional District (“Metro Vancouver“). The Foreign Entity Tax has been introduced by way of an amendment to the Property Transfer Tax Act (British Columbia) (the “Act“) ...
The July 2016 issue of the International Financial Law Review (IFLR) included an international briefing article entitled “Renewable energy projects”. The article was contributed by SyCipLaw partner Rafael L. Encarnacion. The article discussed the challenges that the national legal regime poses to foreign investors seeking a higher equity stake for renewable energy projects, and the difficulty of procurement with either-end users or distribution utilities ...
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 ...
Generally when a successful business is acquired, whether by an asset acquisition or an equity acquisition, the assets will includeboth tangible and intangible property. When an entity conducting a business is liquidated, the tangible and intangible assets of the entity are distributed to the owners. Often, one very valuable intangible that does not appear on the balance sheet is goodwill ...
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) ...
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 ...
On July the 27th 2016, Law No. 20.936 that establishes New Power Transmission Systems and creates an Independent Coordinating Body for the National Power System (the “Transmission Law” or “New Law”) was published. Its stated objectives are to ensure that transmission does not become an obstacle to power generation, increase competition in the electrical market and boost the development of non-conventional renewable energies ...
The Act of 22 July 2016 Amending the Energy Law and Certain Other Acts was published on 2 August 2016. The act is intended to eliminate the black market in fuels, strengthen competition on the market, and improve Poland’s energy security. The amendments introduced by the act primarily concern the market for natural gas and liquid fuels ...
After more than a four months and a Phase II (in-depth) investigation, the Competition Commission gave conditional approval, to Sunoko's acquisition of the Star Šecer company and its subsidiary Te-To - the owner of the sugar factory in Senta. No divestments have been required from Sunoko. The ruling presents the finale of one of the most complicated merger cases in Serbia thus far and Karanovic & Nikolic is proud to have been advising MK Group throughout the process ...
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 ...
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 ...
The Mexican government announced the second bid of Round 2 on August 23, 2016. This will be the seventh upstream bid round in Mexico since passage of the energy reform in mid-2014. The new bid round (named Round 2.2), comprises 12 onshore blocks for exploration in the Burgos and Southeastern Basins, covering collectively 5,006 km2 , with prospective resources of approximately 643.2 million barrels of crude equivalent and an original volume of approximately 93 ...
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 ...
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 ...
Ever since Serbia’s Stabilisation andAssociation Agreement with the EU (‘SAA’) entered into force in September 2013, Serbian media have paidsignificant attention to the country’s obligations concerning the acquisitionof agricultural land by foreigners. The fear of one part of the public appearsto be that, due to the application of the SAA, large portions of Serbianagricultural land will be sold out to foreigners ...
