With this continued interest, a number of Singapore are managers using Jersey as the jurisdiction in which to domicile their funds. This choice is driven by several factors. Singapore tax treatment of digital assets. Digital assets do not fall within the definition of a “designated investment” for the purposes of Singapore tax legislation. This means that a Singapore domiciled fund will be subject to tax in the country, and such tax leakage is hugely unattractive to investors ...
Tackling base erosion and profit shifting remains a priority for the National Treasury and the South African Revenue Service (“SARS”). It was recently reported that in the 2021 fiscal year, SARS dealt with 345 cases of transfer pricing, base erosion and profit shifting to the value of almost ZAR12-billion. Yet, only three South African courts have dealt with transfer pricing ...
Under Notice 2022-33, the Internal Revenue Service (IRS) has extended the deadline for adopting amendments to qualified retirement plans and individual retirement accounts (IRAs) to reflect certain changes made by the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), the Bipartisan American Miners Act of 2019 (Miners Act), and the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) ...
On October 21, 2022, the IRS announced in Notice 2022-55 cost-of-living adjustments to the tax-qualified retirement plan dollar limits for 2023. Most of the applicable dollar limits currently effective for 2022 will increase substantially compared with prior years. Below is a summary of the limits that are generally relevant for most retirement plans. Effective January 1, 2023: The elective deferral limit for 401(k), 403(b), and eligible 457(b) plans is increased from $20,500 to $22,500 ...
In March 2022, the Oregon legislature passed House Bill (HB) 4002, which imposes new overtime pay requirements for agricultural workers beginning on January 1, 2023. The bill also establishes a refundable tax credit for eligible employers to help offset all or part of the additional wage expenses attributed to overtime pay ...
Shoosmiths’ head of energy and infrastructure (E&I) sector, James Wood-Robertson, details and reacts to the much-anticipated E&I developments and proposals set out in the UK government’s 2022 Autumn Statement ...
While originally opened to great fanfare between 2017 and 2019, over the course of 2022 Shell has discreetly closed down all of its UK hydrogen filling stations, citing that "the prototype technology had reached the end of its life". This decision is perhaps not surprising, given the low volume of domestic fuel-cell electric vehicles (FCEVs) on UK roads ...
On 16 November 2022, the Internal Revenue Department (“IRD”) issued Public Ruling 3/2022, which clarifies how the tax authorities will interpret tax avoidance, underpayment, false or misleading tax information, and tax evasion as provided under Myanmar’s Tax Administration Law (“TAL”). This Public Ruling will take effect on 1 January 2023. A summary of the Public Ruling is provided here ...
The Philippines is currently a party to 43 double taxation agreements (DTAs), all of which contain a mutual agreement procedure (MAP) provision. The Department of Finance recently issued Revenue Regulations (RR) No. 10-2022, which took effect on 23 July 2022. RR No. 10-2022 prescribes the guidelines for filing a MAP request for assistance in resolving DTA disputes ...
On 17 November 2022, the State Administration Council (“SAC”) enacted the Law Amending the 2022 Union Tax Law (“2022 UTL Amendment”). This law provides tax exemptions for Battery Electric Vehicles (“BEVs”) and increases the corporate income tax rate of companies engaged in the oil and gas exploration and production sector in Myanmar. We highlight below the major changes under this law: 1 ...
Following the 2018 enactment of regulations governing contractual terms contained in vehicle hire-purchase agreements, the Office of the Consumer Protection Board (“OCPB”) has recently resolved to adjust such regulatory scheme as part of their initiatives to alleviate the ongoing economic downturn and financial hardships suffered by consumers as a result of the pandemic, and to prevent consumers being subject to any unfair contractual terms in this respect ...
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 ...
Last year a new landmark report was launched by the Chartered Institute of Building (CIOB), aimed at changing the diversity of the people building the critical national infrastructure - as they have not always reflected the diversity of the people and communities who will ultimately use it ...
December 6, 2022 By: Alexander Davis and Manuel Fishman In March 2020, the voters of San Francisco approved Proposition D, also known as the Commercial Vacancy Tax. The ordinance applies to ground floor, street-facing, commercial properties within any of the 32 districts listed in Section 201 of the Planning Code (which the regulation defines as “Taxable Commercial Space”) ...
Dr Ingrid Fenech participated in the Society Education Annual Conference on Aspects of Maltese Company Law held on 29th November, where she delved into the recent amendments to the Companies Act introducing the notion of cell companies carrying on or engaged in shipping or aviation business ...
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 ...
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 ...
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 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% ...
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 ...
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 ...
