We would like to kindly remind you that from 7 January 2019 to 28 March 2019, the Financial Conduct Authority ("FCA") online system ‘Connect’ is open for EEA-based firms and fund managers of EEA-domiciled investment funds (UCITS and AIF) currently passported into the UK to notify the FCA about their intention to participate in the temporary permissions regime (“TPR”) ...
By Ordinance dated April 1ston emergency measures relating to staff representative bodies (“IRP”), the Government had provided for the possibility for companies to hold meetings with their IRP via videoconference or conference call but also by instant messaging app if the two first means cannot be used. By Decree published on April 10th, 2020, the Government provided clarifications on how to use conference calls and instant messaging ...
Several countries have already introduced the concept of “temporary non-residents” into their tax orders, thus enabling them to lay down special rules regarding the taxation of income received by those who are habitually resident in these countries, but take up residence in another country for a certain period – which as a rule does not exceed 5 years and is very often a result of secondment - and subsequently return to their former country of residence ...
Tech Start-Up Companies Toolkits - ǼLEX Legal .avada-select-parent .select-arrow{background-color:#ffffff}.select-arrow{background-color:#ffffff} Are you running a start-up or contemplating starting that business and you are uncertain on how to proceed? Do not fret as AELEX Fintech centre has compiled this start-up tool kit to guide you on setting up your business ...
Tech Companies and Fund Raising: The New Way of Going Public (Part 2) In the second part of our article, we focus on Spotify, a digital music service that utilised a direct listing to become a public company, the key steps they took that differed from a traditional IPO, and how the NSE can modify its current regulatory framework to include direct listings. Case Study: Spotify Technology S ...
A NEW PATHWAY From Uber to Jumia and even older technology (tech) companies like Etranzact and Chams Plc, it is arguable that Initial Public Offerings (“IPOs”) have not offered great returns for tech companies in Nigeria and across the globe[1]. Investors are speculating on whether the great tech bubble is about to burst because, considering the cost of IPOs, tech companies have to scrutinise the expected returns when contemplating an IPO ...
During the years of the recent property and development boom in the Turks and Caicos Islands (TCI), stamp duty on the real estate transactions became a substantial contributor to Government coffers. All real estate transactions in TCI are subject to stamp duty at varying rates depending on the size of the transaction and on the island on which the real estate is situate. In most cases, stamp duty is charged at the rate of 9.75% of the consideration passing ...
The Turks and Caicos Islands (TCI) has just enacted a revamped investor residency programme, entitling successful applicants to a permanent residence certificate (PRC). Qualifying criteriaThe qualifying criteria are:- Villasa. Investment of not less than $300,000 in actual construction of a new home, or in renovation of a distressed property as a home for the applicant and his or her dependants, on the islands of Grand Turk, Salt Cay, South Caicos, Middle Caicos or North Caicos; orb ...
Dear valued clients, colleagues and friends, In the recent case of Lam Ah Company Sdn Bhd (“taxpayer”) v Director General of Customs and Excise, the taxpayer succeeded in its judicial review application challenging Customs’ refusal to give effect to the exemption under section 155 of the Goods and Services Tax Act 2014, which exempted, among others, taxable supplies of goods or services made within a “designated area” (i.e ...
Cases challenging the constitutionality of state pass-through entity (PTE) nonresident owner withholding or composite return statutes are extremely rare. However, a recent Alabama Circuit Court decision, Black Eagle Minerals, LLC v. Alabama Department of Revenue, Case No. CV-2018-900328.00 (Cir. Ct. Montgomery County, Ala., July 27, 2020), highlights why such challenges may be more common when PTE composite returns are mandatory ...
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 ...
The COVID-19 pandemic has delayed and lowered revenues, creating an unprecedented period of fiscal uncertainty for borrowers of tax-exempt debt. Borrowers forced to navigate these conditions may request lenders defer scheduled debt payments to help weather the storm. Borrowers and lenders of tax-exempt debt must be mindful that a deferral of scheduled payments may endanger the debt’s tax-exempt status ...
On December 20, 2013, the Quebec Department of Finance and the Economy issued Information Bulletin 2013-14 (the “Bulletin”), announcing inter alia changes to various tax measures specifically applicable to the natural resources industry ...
With the growing globalisation of economic activity characterised by free movement of goods, capital and labour, more and more Rwandan residents are now working outside Rwanda, doing business with or in foreign countries, holding shares in non-resident companies and extending loans to non-resident borrowers. However, the tax treatment in Rwanda of foreign income earned from such activities is still the subject of some uncertainty, particularly with respect to double taxation relief ...
As part of its continuing efforts to develop legislation regarding the taxation of non-Israeli persons providing digital services in Israel, the Israel Tax Authority recently published a proposed amendment to the Value Added Tax Law (the “Proposed Amendment”) ...
The digital transformation experienced over the last number of years has resulted in unprecedented global economic and societal changes. This has resulted in global debates around international tax and the digital economy and whether the existing international tax rules, developed in a “brick-and-mortar” economic environment more than a century ago, remain appropriate for the modern global economy ...
Since we are in the season for the distribution of dividends, it is not without use to review and update, our last charter on this issue. It shall be recalled that in 2005 the Portuguese tax system streamlined its rules for the taxation of dividends, by harmonising rates which previously varied in accordance to the nature of the recipient of the dividends ...
Recently, in 2005, the Portuguese tax system streamlined its rules for the taxation of dividends, by harmonising rates which previously varied in accordance to the nature of the recipient of the dividends. This, along with the introduction of some provisions aimed at dealing with schemes that used exempt entities to evade tax, helped to turn the taxation of dividends more coherent and simple ...
SyCip Salazar Hernandez & Gatmaitan (SyCipLaw) senior partner Carina "Caren" Laforteza and special counsel Catherina "Kate" Fernandez discuss the taxation of AI in light of recent developments concerning the concept of situs of taxation as interpreted by the Bureau of Internal Revenue (BIR), the local tax authority in the Philippines ...
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 ...
We've become familiar with the Met Office issuing “traffic light” warnings about potentially disruptive weather. Couples contemplating divorce or separation could face similarly rough going when it comes to their tax affairs, especially Capital Gains Tax (CGT) when property or a business is involved. The alert level right now would be considered “amber” - think before you separate as you might not be able to complete a settlement in time for this tax year ...
SyCipLaw's Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the third quarter of 2023. Please read the full texthereor via thislink. The SyCipLaw T.I.P.S - International Edition covers the following tax issues: 1 ...
SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for October. The October 2023 issue covers the following tax issues: 1. In cases of real property taxes ("RPT") on land covered by the Torrens system, can treasurers of local governments rely on the certificates of title to determine the owner of the land for purposes of sending notices of deficiency RPT? 2 ...
The SyCipLaw T.I.P.S. for October cover the following tax issues: 1. When the taxpayer cannot be located, what are the options available to a Revenue Officer in serving an electronic Letter of Authority? 2. Is the sale, barter, exchange or other disposition through Initial Public Offering of shares of stock in closely held corporations subject to tax? 3 ...
