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SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for July which covers the following tax issues: 1. Is a taxpayer always required to make the "payment under protest" under Section 252 of the Local Government Code of 1991, as amended, to assail real property taxes? 2. May services rendered to foreign entities outsourcing manpower recruitment in the Philippines qualify for a zero percent rate of value-added tax ("VAT")? 3 ...

SyCipLaw's Tax Department has prepared a double edition of its Tax Issues and Practical Solutions (T.I.P.S.) for May-June. The May-June 2024 issue covers the following tax issues: 1. Under the current VAT regulations, is input tax required to be directly attributable (or a factor in the production chain) to zero-rated sales, i.e., to come from purchases of goods and services that form part of the finished product of the zero-rated taxpayer in order to be creditable or refundable? 2 ...

SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for April. The April 2024 issue covers the following tax issues: 1. In assessing deficiency withholding tax on compensation of employees who were not individually identified, is it proper for the Commissioner of Internal Revenue ("CIR") to use the top withholding tax rate of 32%? 2. Which court has exclusive and original jurisdiction over criminal offenses involving tax claims amounting to PhP 1,000,000 ...

Simplified Stock Companies (SAS) have been implemented in El Salvador as a corporate solution aimed at micro-entrepreneurs and informal sector merchants who, due to entry barriers established in various regulatory bodies, were discouraged from forming a traditional corporate vehicle (e.g., Corporation, Limited Partnership, Limited Liability Company, among others) to conduct their business.   In pursuit of the objective mentioned above, the reforms to the Commercial Code (C. Com ...

Lavery Lawyers | August 2024

Tax opportunities under the Indian Act   Although it is not often well-understood in business and tax circles, the Indian Act (the ?Act?), coupled with federal and provincial tax laws, provides several tax planning opportunities for Indigenous taxpayers. These laws provide various tax exemptions for people who qualify as ?Indians? under the Act, as well as for ?bands? and other ?councils ...

Carey Olsen | July 2024

Shipping and Bermuda’s Corporate Income Tax Act The initial taxing determination You have determined that you have a shipping entity within a “Bermuda Constituent Entity Group”, which itself is within an “In Scope MNE Group” for the purposes of the Tax Act. Furthermore, you have already made various adjustments to the taxable income in accordance with Part 6 of the Tax Act ...

Transfer Pricing rules are fundamentally based on the Arm’s Length Principle, articulated in art. 9 of the OECD Model Tax Convention. This principle is pivotal for bilateral and multilateral tax treaties to avoid double taxation, reiterated in point 1.6 of the OECD’s “Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ...

Dinsmore & Shohl LLP | July 2024

The Supreme Court has overturned the Chevron Doctrine–a four decade-old ruling that enabled Federal agencies, including the Internal Revenue Service (“IRS”), to interpret ambiguous laws passed by Congress, and to have such interpretations enjoy a significant degree of deference ...

Afridi & Angell | May 2024

With the first UAE corporate tax registration deadline looming (31 May 2024), companies and other businesses need to ensure that they have checked their deadline to register as a taxable person.The registration process under the Federal Law No. (47) 2022 (CT Law) is still new to the UAE and 2024 marks the first mandatory year for companies to register with the Federal Tax Authority (FTA) as a taxable person ...

SyCipLaw's Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the first quarter of 2024. The SyCipLaw T.I.P.S - International Edition covers the following tax issues: 1. Are informal settlement agreements between the Commissioner of Internal Revenue and the taxpayer valid and binding? 2. While a tax case is pending in court, may the CIR and the taxpayer enter into a compromise agreement and request for judicial approval thereof? 3 ...

Lavery Lawyers | April 2024

On March 28, 2024, the Department of Finance Canada announced a one-year extension to the 15% Mineral Exploration Tax Credit (?METC?) available to investors in flow-through shares. The extension means that the METC will be effective until March 31, 2025. This announcement came at a time when uncertainty loomed over the industry and some stakeholders feared that the government would not renew the METC. Over time, this tax credit has become a key component of flow-through share financings ...

SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for February.The February 2024 issue covers the following tax issues:1. What is Republic Act No. 11976 and why is it relevant to tax?2. Are cross-border services provided by non-resident foreign corporations now subject to income tax and VAT under Revenue Memorandum Circular No. 5-2024?Please read the full texthereor via thislink ...

Carey Olsen | March 2024

British Virgin Islands Economic Substance - frequently asked questions Who has to comply with the Substance Legislation? All companies and limited partnerships that are registered or incorporated in the British Virgin Islands (“Entities”) must comply with the Substance Legislation. The Substance Legislation does not apply to trusts or general partnerships ...

Dinsmore & Shohl LLP | March 2024

On January 1, 2024, regulations implementing the Corporate Transparency Act (“CTA”) became effective, triggering new reporting obligations for many entities conducting business within the United States ...

Lavery Lawyers | March 2024

Although it is not often well-understood in business and tax circles, the Indian Act (the ?Act?), coupled with federal and provincial tax laws, provides several tax planning opportunities for Indigenous taxpayers. These laws provide various tax exemptions for people who qualify as ?Indians? under the Act, as well as for ?bands? and other ?councils ...

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 ...

Many founders are familiar with tax-exempt charitable organizations. These nonprofit entities—which are commonly known by reference to Section 501(c)(3) of the Internal Revenue Code—are operated exclusively for a broad range of charitable purposes.  501(c)(3) organizations come in a wide range of flavors, including private foundations, donor-advised funds, and public charities ...

ALTIUS/Tiberghien | March 2024

In an earlier article in this series, we already discussed the planned changes in terms of moveable income. Whilst the changes may seem relatively limited at first glance, Dutch residents immigrating to Belgium will however encounter several peculiarities as set out in this article. Capital gains   Capital gains, i.e. on shares, are in principle taxable in the state of residence ...

Afridi & Angell | February 2024

in the past week, guidance has been provided by both the Ministry of Finance and the Federal Tax Authority (FTA) regarding deadlines for Corporate Tax registration.The new deadlines have the potential to significantly reduce the time left for meeting the deadlines for Corporate Tax registration. For example, certain applicable taxable persons will be required to submit the Corporate Tax registration applications by 31 May 2024 in order to avoid a violation and the applicable penalties ...

SyCipLaw’s Tax Department has listed down its Top 10 Tax Issues and Practical Solutions (T.I.P.S.) for 2023. Please read the full text hereor via this link. The SyCipLaw's Top 10 Tax Issues and Practical Solutions (T.I.P.S ...

ALTIUS/Tiberghien | February 2024

The new double tax treaty between Belgium and the Netherlands will introduce significant changes  compared to the current Article 5 on permanent establishments. Due to the positions of Belgium and the Netherlands to the Multilateral Instrument (MLI), only the anti-fragmentation rule is applied under the current treaty. Under the new treaty, alignment is sought and found with the other changes proposed by the MLI for permanent establishments ...

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 ...

Recently, the General Directorate of Customs (DGA), under the provisions of art 440 of the Regulation of the Uniform Central American Customs Code (RECAUCA), has modified the period of stay for vehicles owned by foreign tourists, Salvadorans residing abroad, and Salvadoran students residing abroad ...

Shoosmiths LLP | February 2024

The use of cryptocurrency or crypto assets in employee incentive arrangements is a relatively new and evolving area and it is therefore important to carefully consider the potential advantages and disadvantages of their use in incentive arrangements. Different types of crypto assets Crypto assets can take many forms including digital currency such as Bitcoin and Litecoin and NFTs (non-fungible tokens) such as art NFTs and collectible real estate NFTs ...

Shoosmiths LLP | February 2024

Last year, the UK Government announced increases in fees for immigration and nationality applications as well as priority processing services which took effect from 4 October 2023. As mentioned in our previous article, these increases are substantial and likely to have a significant financial impact for applicants and their sponsors. In addition, the UK Government are increasing the Immigration Health Surcharge shortly on 6 February 2024 ...

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