On December 29, 2018, Government Emergency Ordinance No. 114/2018 on the establishment of measures in the field of public investments and of fiscal – budgetary measures, the amendment and completion of certain normative acts and the extension of certain deadlines (“GEO 114/2018”) was published in the Official Gazette ...
The Supervisory Agency for Investment in Energy and Mining ("OSINERGMIN") and the Ministry of Energy and Mines ("MINEM") have carried out a series of pre-publications of draft regulations in the electricity and hydrocarbons sector, including: Minimum Power: on July 31, 2020, through OSINERGMIN Resolution No ...
The South African Revenue Service (“SARS”) is, in accordance with section 3(2)(j) of the Tax Administration Act, 28 of 2011 (the “TAA”), responsible for giving effect to the Country-by-Country Reporting Standard for Multinational Enterprises (the “CbC Reporting Standard”) which was developed under the Organisation for Economic Co-operation and Development’s (“OECD’s“) base erosion and profit shifting (“BEPS”) Action Plan 13 – “Re-examine Transfer Pricing Documentation” ...
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
Last night, only days ahead of a general election the minority Government in Norway is likely not to win, a proposal for dramatic changes to the upstream petroleum tax regime. It was announced at 18.00 hours Oslo time in a hastily called press conference by the Minister of Finance Mr Sanner (Conservative) and the Minister of Petroleum and Energy Ms Bru (Conservative) ...
Collaboration took centre stage at the recent Transport and Energy (TE) Forum event, which brought together industry leaders both in the public and private sectors to explore the crucial need for increased cooperation across the landscape. The forum, marked by the tagline 'Further & Faster,' acknowledged the strides the UK has made in achieving new charge point milestones but underscored the imperative for continued progress ...
With the steep collapse of oil and gas prices in the last eighteen months, dozens of exploration and production companies have declared bankruptcy and many more companies are expected to file for bankruptcy protection unless prices rebound dramatically ...
Dozens of North American oil and gas producers have commenced Chapter 11 bankruptcy cases this year, including most recently, Escalara Resources Co., RAAM Global Energy Company, Miller Energy Resources, Inc., and Parallel Energy LP ...
In August 2016, we reviewed publicly available data for a group of 58 E&P companies and predicted how they would fare under the leverage test that had, at the time, recently been introduced by the OCC.Based on that review, we predicted that, in 2016, over 91 percent of the companies reviewed would be non-passing credits under the OCC’s leverage test. The average leverage ratio of the E&P companies reviewed in 2016 was 6.0x ...
In September 2021, the House of Representatives approved on third reading House Bill (HB) 8942 – the Ease of Paying Taxes Act. The bill proposed to amend the National Internal Revenue Code as amended (the Tax Code) and introduce administrative reforms that will simplify tax compliance and strengthen taxpayers' rights ...
On 23 June 2023, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular (RMC) No. 71-2023 and Revenue Memorandum Order (RMO) No. 23-2023 to provide streamlined guidelines and the prescribed documentary requirements for the processing of value added tax (VAT) refund applications. The following significant amendments were introduced to the existing regulations outlined in this article ...
The European Commission has published its report outlining its proposed changes to the European energy market.In order to open the continent's gas and electricity markets up to greater competition, the Commission has proposed the separation of energy suppliers and producers, a move which would see the break up of firms such as E.ON and Electricite de France ...
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Most of our clients are aware that Congress dramatically increased the individual gift tax exemption from $1,000,000 to $5,120,000 in 2012, and that the exemption is scheduled to revert to $1,000,000 on January 1, 2013 unless Congress takes some action. If this reduction in the gift tax exemption occurs, clients may lose an opportunity to remove a substantial amount of assets from their estates, and, with it, the opportunity to reduce estate taxes payable by their children ...
In two recent decisions, the Tax Court issued rulings that could impact the effectiveness of family limited partnerships in estate planning. For the first time, the Tax Court held that assets of a limited partnership could be taxed as part of the estate of a decedent who held only a limited partnership interest ...
Advance payment can be understood as: “… the payment made before the occurrence of the generating event that constitutes the future and uncertain event on which the legal force of the obligation depends” (Giulani Fonrouge and Susana Navarrine in “Procedimiento Tributario”, Editorial de Palma, page 159) ...
There are three main challenges to increasing competition in the availability of enroute charging stations, especially at motorway service area (MSA) sites, and the common theme is cost. The main challenges are: High costs for connecting to the electricity network, which acts as a key barrier to charge point operators (CPOs) investing at MSA sites. Limited competition at MSA sites, which is linked to the high costs for connecting to the electricity network ...
At the end of the 19th century, mechanisms that transformed natural resources into energy began. The conception of electricity as a private good, which fosters economies of scale and the promotion of transmission and generation megaprojects in the sector, consciously and interestedly omit sustainable energy alternatives from a social and environmental point of view. The causes that leave aside this type of projects are based on the lack of economic profitability for investment interests ...
On 22 March 2016, the Organisation for Economic Development and Co-operation (“OECD”) released a standardised electronic format to facilitate the consistent and uniform preparation, filing and exchange of Country-by-Country (“CbC”) reports. The CbC reports will be transmitted between revenue authorities in accordance with the Extensible Markup Language Schema (“XML Schema”),which is a data structure for electronically holding and transmitting information ...
This alert describes certain information regarding the recently filed bankruptcy case of Emerald Oil, Inc. and is an example of current developments in the energy industry.Emerald Oil, Inc. and its subsidiaries (collectively referred to as the “Debtors”) filed voluntary petitions for relief under Chapter 11 of the U.S ...
Water Law Effective August 19, 2021, emergency regulations were approved for water curtailment orders and related reporting requirements in the Sacramento-San Joaquin Delta watershed, defined as Hydrologic Unit Code level 4 Sacramento and level 4 San Joaquin subregions (Delta Watershed), as shown in the map below ...
On September 29, 2023, Decree No. 4, dated January 25, 2023 (the "Regulation"), issued by the Ministry of the Environment (the "Ministry"), was published, coming into force the Emission Compensation System for stationary sources subject to Green Tax[1] (the “System”). The System promotes the development of emission reduction projects (the "Projects") ...
