This year marks the fifth anniversary of the introduction of the transfer pricing regime in Cambodia. Recent changes in local transfer pricing regulations, tax audit practices, and documentation mean that now – more than ever – you need the right advisor to reduce the tax audit risks associated with related party transactions. DFDL Cambodia’s specialized transfer pricing team combines international experience and deep knowledge of the local legal and tax environment ...
In Ultima Services Corporation v. U.S. Department of Agriculture et al., Case No. 2:20-CV-00041, Ultima Services Corporation filed suit in the U.S. District Court for the Eastern District of Tennessee (Greenville Division) challenging the constitutionality of the Small Business Administration’s 8(a) Business Development Program ...
The rules on exit tax on shares and certain other securities mean that private individuals who move from Norway and becomes resident for tax purposes in another country must pay tax for latent profits on shares etc., as if the shares had been sold the day before emigration. Change in law is now in force As the rules have been until 28 November 2022, the exit tax ceased to apply if the shares were not realized five years after emigration ...
“With the energy crisis likely to continue throughout 2023 and pressures on governments, businesses and individuals to take action to tackle climate change, I expect that, whilst government funding may be limited, there will be no shortage of capital for investment in clean energy projects ...
Having experienced unprecedented levels of M&A activity in 2021 and the first half of 2022, followed by the market uncertainty of Q3 and Q4 of 2022, what can we expect from the M&A landscape in 2023? Here are some of our key predictions ...
We summarize here what we believe are the top 5 Alabama tax cases decided in the past year that would interest our CPA readers. Not surprisingly, almost all are Alabama Tax Tribunal rulings, so in those instances we deleted that reference and simply list the date of the latest ruling. If you’d like a copy of or have a question about any of these rulings, please email one of us ...
The Finnish Government has published a proposal for the temporary Windfall Tax Act in Finland, the draft of which was briefly discussed in our previous article on the subject. The proposed temporary windfall tax would be applicable to so-called windfall profits gained during tax year 2023 by companies operating in the electricity or the fossil fuel sector. The aim of the proposal is to tax said sectors' increased profits resulting from the current energy crisis ...
On December 9, 2022, the Office of Chief Counsel of the Internal Revenue Service (“IRS”) issued a General Legal Advice Memorandum (“Memorandum”) challenging the 1994 Tax Court decision inChilds v. Commissioner, 103 T.C. 634 (1994),aff’d without published opinion, 89 F.3d 856 (11thCir. 1996) (“Childs”) ...
On 14 December 2022, following a campaign by the Royal Yachting Association, the UK Government confirmed that it would not be implementing changes to HMRC policy to enable UK residents that purchased (EU) VAT paid UK vessels located in the EU prior to the end of the Brexit transition period (31 December 2020) to bring these vessels back into the UK without incurring a second (UK) VAT charge ...
Law.com International November 30, 2022 By Anne Bagamery, Coorespondent, Paris Jeantet has recruited a 14-person team, including three partners, from a rival French firm to create a new multidisciplinary department dedicated to energy transition and sustainable development. The move is part of a growth strategy for Jeantet, an elite firm with headquarters in Paris and offices around the world ...
A lesser-known state incentive in the nonprofit sector has created a boon for taxpayers, private education institutions and their students. Across the country, states are providing tax credits that reduce individuals’ state income taxes for any donation to a state-certified nonprofit organization providing scholarships to K-12 students to attend private schools ...
Earthrise Serves EPA with Notice of Intent to Sue, Challenging Washington’s Forest Practices Rules Nearly 20 years ago, the Washington Forest Practices Board adopted forest practices rules intended to address water quality impacts from nonpoint sources of pollution affecting Endangered Species Act (ESA)-listed species of salmon ...
In this briefing, we will review the implications of the Law for property transactions in Jersey. Tax on purchase of residential properties which are not used as a main residence The key implication of the Law is that stamp duty (and equivalent land taxes such as land transactions tax and enveloped property transactions tax) on acquisitions of domestic residential property which will not be the purchaser's main residence will be increased ...
Recently approved Cabinet Decision 85 of 2022 (the Decision) outlines the requirements and conditions for classification of persons as a “Tax Resident” of the UAE. We briefly outline below who qualifies as a UAE tax resident. Afridi & Angell have assisted a variety of clients in procuring tax domicile certificates and are well versed in the procedures and requirements ...
January 2022 began with the announcement that businesses and corporations will be subject to Corporate Tax (CT) from 1 June 2023. While the UAE Ministry of Finance helpfully provided information on the basic tenets of CT, including a comprehensive white paper, the CT Law governing CT was published on 9 December 2022 providing clarity. However, there are still a number of areas that will be further clarified through the implementing regulations ...
As CIT finalization approaches, we highlight the existing Transfer Pricing compliance requirements for Vietnam taxpayers, under Decrees 132 and 126, and Law No. 38: When does Transfer Pricing (TP) apply? When a Vietnam company or local subsidiary of a foreign company has intra-group transactions (goods, services, loans or royalty transactions) with its related parties ...
With the 2022 year quickly coming to an end, we take this opportunity to remind our clients and readers of the annual compliance obligations for enterprises in Cambodia. With each year that passes there seem to be more compliance obligations, and the latest 2023 compliance requirements continue this trend. With that in mind, we have provided below what we believe are the most important annual compliance requirements that enterprises in Cambodia should be aware of ...
The past two years have seen significant growth in the number of mergers and acquisitions nationwide with many agriculture and farming business owners choosing to liquefy their assets and move on. At the same time, employers have had to cope with numerous challenges that have made the task of hiring and preparing I-9s for new employees more difficult. Some employers (unlawfully) stopped preparing I-9s for new hires altogether ...
Companies face the loss of a major tax break on research and experimental ("R&E") costs for 2022, absent Congressional action. Since 1954, Internal Revenue Code section 174 has allowed taxpayers to immediately deduct R&E costs. Effective January 1, 2022, the Tax Cuts and Jobs Act of 2017 ("TCJA") amended section 174 to eliminate the deduction of R&E costs. Instead, costs for R&E activities in the U.S ...
In a Pre-Budget Report (PBR) announced to Parliament last week, the Government has set out its priorities for next year's budget. These include proposals to increase revenues via significant changes to the current employment tax regime. Perhaps the most headline-grabbing aspect of these potential reforms is the proposal to increase the employer portion of payroll tax for exempted companies, from 10.25% to 10.75% ...
What is ATAD III? In December 2021, the European Commission (“EC”) published its proposed Anti-Tax Avoidance Directive (known as “ATAD III”). ATAD III is intended to discourage the misuse of shell companies within the European Union (“EU”). The Directive is aimed at EU-resident entities which claim benefits under double taxation treaties and other EU Directives, but which lack a minimum level of economic substance ...
In Commissioner of Internal Revenue v Ruben U Yu,(1) the Court of Tax Appeals (CTA) en banc clarified that the 180-day period referred to in section 228 of the Tax Code, as amended, applies only to the period within which the Commissioner of Internal Revenue (CIR), or their duly authorised representative, may act on a protest against a tax assessment ...
Due to the covid-19 pandemic, registered business enterprises (RBEs) in the information technology-business process management (IT-BPM) sector have adopted work from home (WFH) arrangements to continue business operations. Now that movement restrictions have been relaxed, a balance must be struck between the requirement for RBEs to operate within economic zones and the clamour of RBEs to continue hybrid work arrangements while maintaining their fiscal incentives ...
The EU revenue cap which limits certain electricity generators' revenues has raised many questions within the energy sector. In Finland, the revenue cap will likely be implemented in the form of a temporary windfall tax which would apply to profits made in 2023. Our energy team's associate Nelli Rönkkö has summarised the key points regarding the implementation of the EU revenue cap in Finland ...
