IN THIS ARTICLE, ABHILAASH SUBRAMANIAM DISCUSSES THE POTENTIAL IMPLICATIONS OF THE MOVE FROM GST TO SST. Introduction The much anticipated Sales Tax Act 2018 and the Service Tax Act 2018(commonly referred to as “SST”) was rolled out on 1 September 2018, together with their respective subsidiary legislations, to replace the previous Goods and Services Tax Act 2014 (“GST”) ...
Some may be wondering what a “telekung” is as it is probably not a common term. A Telekung is a Muslim prayer outfit for females. The general perception of prayer outfits is that they are dull and unfashionable as they have to be modest rather than trendy. However, there has been a drastic shift in the fashion industry in recent years where there are an increasing number of fashionable yet modest clothes in both local and international markets ...
The Tax Cuts and Jobs Act of 2017 (the “TCJA”) created a new tax incentive designed to encourage long-term investment in low income communities, as defined in Code Sec. 45D(e),1 which are specifically designated as “qualified opportunity zones” (“QOZs”) in accordance with procedures set forth in Code Sec. 1400Z-1 ...
The Taxation Laws Amendment Act, 2018 (“TLAA”), which was promulgated on 17 January 2018, amended South African tax legislation by overhauling two provisions relating to the reduction of debt, (the “Debt Benefit Rules”), namely section 19 of the Income Tax Act, 1962 (the “ITA”) and paragraph 12A of the Eighth Schedule to the ITA (the “Eighth Schedule”) ...
In this context, the judgements provide useful guidance on the concepts of abuse and beneficial ownership. Abuse concept According to the CJEU, it is settled case-law that there is, in EU law, a general legal principle that EU law cannot be relied on for abusive or fraudulent ends ...
The most important corporate tax measures concern the reduction of the maximum corporate income tax (“CIT”) rate and the introduction of the option provided by the anti-tax avoidance directive (“ATAD”)[1]. This allows for the application of the interest limitation rules at the level of a fiscal unity: For the time being CIT is levied at a rate of (i) 15% in case the net profits do notexceed EUR 25,000 and (ii) 18% in case the net profits exceed EUR 30,000 ...
In December 2018, Part I of this column was based on the Proposed 199A Regulations1 and included the applicable definitions and the basic concepts and mechanics of the 199A 20% deduction of Qualified Business Income (“QBI”) up to the 20% of the excess of the taxpayer’s taxable income over the taxpayer’s net capital gain ...
AFRICA: African Continental Free Trade Area Agreement developments Botswana and Zambia signed the African Continental Free Trade Area Agreement (“ACFTA”) on 10 February 2019 at the 32nd summit of the African Union in Addis Ababa, whereas the Ethiopian Council of Ministers approved the ACFTA on 2 February 2019 and the Parliament of Senegal on 23 January 2019 ...
In the listed sector, shareholders may be presented with various elections to be made as regards the nature of distributions made by companies in which equity investments are held. Shareholders can therefore be faced with an election to receive payment of a cash dividend, or in lieu thereof, to receive capitalisation shares from the underlying company or to partake in a dividend reinvestment plan ...
Sections 113 and 115 of the Companies Act, 2008 provide for an automatic statutory merger of two companies. The transfer occurs by way of operation of law, and barring any express prohibition to the contrary in a contractual arrangement, no third party consent is generally required to implement the merger. This type of transaction may typically give effect to a desired corporate reorganisation, in terms of which an existing company is liquidated, wound up and/or deregistered ...
The reportable arrangement provisions were established by the South African Revenue Service (“SARS”) with the objective of obtaining information on certain types of transactions. The circumstances under which a person should report an “arrangement” to SARS, as defined in section 34 of the Tax Administration Act, 2011 (the “TAA”), are contained in sections 34 to 39 of the TAA ...
Brexit Newsletter from AED The Registration Duties, Estates and VAT Authority (AED) has issued a Newsletter informing all taxpayers of VAT related consequences of a British exit from the European Union (EU) as from 29 March 2019, (in case no withdrawal agreement is agreed between the EU and the United Kingdom (UK). Click here to access to the AED Newsletter. In the meantime, the date of the withdrawal of the UK from the EU has been postponed until 12 April 2019 ...
The presence of a small amount of undeclared sesame in a particular product may seem trivial but, for those who are allergic, it can provoke a major reaction. Such was the predicament faced by Pret a Manger in July 2016, following the death of Natasha Ednan-Laperouse that same month due to the undeclared presence of sesame in a Pret baguette ...
Coordinating cross-border due diligence is a key skill that more often than not underpins complex, multi-jurisdictional merger and acquisitions (M&A) and private equity (PE)-led transactions. Where due diligence really adds value is in the early stages of the transaction, when local knowledge and expertise are vital to understanding the context of data room information ...
The Trump administration’s significant escalation of the trade dispute with China after months-long U.S.-China trade talks have faltered is a major news headline as the week concludes. The U.S. followed through on its warnings and increased tariffs on an estimated $200 billion of Chinese goods from 10 percent to 25 percent starting May 10th. At the same time, the U.S. announced importers will be able to apply for an exemption from these tariffs ...
The incorporation of the Law on Security Interests in El Salvador has the objective to create a registry for security interests, that is to say, the inscription of the security interests’ creation, modification, extension, termination and execution, as well as the publicity of these instruments. The Commercial Value that some brands have, plays a very important role and represents, for some entrepreneurs, a mechanism which enables them to access credits ...
Trademark law in Canada is undergoing a major change this year that will go into effect on June 17, 2019. We have compiled the three things you need to know and important steps you may want to take before the June 17, 2019 date passes. 1 ...
Recent research from the insurer Royal London found more than half of the UK adult population has not made a will, and a quarter of those have no intention of making one. Death, it seems, remains something of a taboo subject in the UK. This is in stark contrast to some other countries, such as Mexico, where each year the population celebrates Día de los Muertos, or the Day of the Dead ...
This is to inform you that the Central Bank of the Russian Federation approved the new list of foreign stock exchanges by the order no. 5095-Y dated 21st of March 2019, which gives new opportunities for Russian resident individuals with regards to currency transactions ...
Starting June 1, 2019 individuals once more receive the right to participate in the updated voluntary disclosure program ("amnesty"), which provide guarantees of exemption from some types of liability related to use of foreign bank accounts and foreign companies. Declarants may submit the special declaration until February 29, 2020 ...
Article PDF On April 17, 2019, the Treasury Department released a second round of proposed regulations (the "4/19 Regulations") providing additional guidance on the implementation of the Opportunity Zone (“OZ”) tax incentive included in the Tax Cuts and Jobs Act. The 4/19 Regulations are taxpayer-friendly and expand upon (but in some cases modify) the guidance provided in the initial proposed regulations released on October 19, 2018 (the "10/18 Regulations") ...
Article PDF On April 17, 2019, the Treasury Department released a second round of proposed regulations (the "4/19 Regulations") providing additional guidance on the implementation of the Opportunity Zone (“OZ”) tax incentive included in the Tax Cuts and Jobs Act. The 4/19 Regulations are taxpayer-friendly and expand upon (but in some cases modify) the guidance provided in the initial proposed regulations released on October 19, 2018 (the "10/18 Regulations") ...
Article PDF On April 17, 2019, the Treasury Department released a second round of proposed regulations (the "4/19 Regulations") providing additional guidance on the implementation of the Opportunity Zone (“OZ”) tax incentive included in the Tax Cuts and Jobs Act. The 4/19 Regulations are taxpayer-friendly and expand upon (but in some cases modify) the guidance provided in the initial proposed regulations released on October 19, 2018 (the "10/18 Regulations") ...
The Illinois legislature has approved and Governor Pritzker has signed into law significant revisions to the Illinois Tax Delinquency Amnesty Act (35 ILCS 745/10). The new amnesty program is the first in Illinois since 2010 and is an important opportunity for noncompliant taxpayers to resolve both known and previously unknown Illinois tax obligations. The amnesty program will run from October 1, 2019, through November 15, 2019, and is generally open to all taxpayers ...
