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The Digital Assets Law, which is in force since February 1, 2023, aims to establish a legal framework that provides legal certainty to the transfer operations of any title of digital assets used in public offerings issued in El Salvador ...

Dinsmore & Shohl LLP | September 2021

On Sept. 13, 2021, the House Committee on Ways and Means released the remainder of its numerous tax reform proposals. The proposals will be subject to continued negotiations and are not law. But, the proposals are an indication of what may be coming soon ...

Shearn Delamore & Co. | July 2020

The Inland Revenue Board (“IRB”) has published an updated list of Frequently Asked Questions (“FAQ”) on tax matters arising during the MCO and CMCO period. For the updated FAQ (as at 10 June 2020), please refer to this link.  The Royal Malaysian Customs Department (“RMCD”) has also recently issued two updated announcements pertaining to payment of taxes due during the MCO and CMCO period. Find information here and here ...

The 2013 Federal Revenue Law was published yesterday and its Transitional Article 3 includes an amnesty covering payment of federal taxes and related government charges, as follows: a)  80% forgiveness of tax assessment consisting of federal taxes, antidumping duties, and fines for failure to comply with federal tax obligations, other than payment obligations, arising prior to January 1, 2007 ...

Carey | April 2020

Decree No. 553 establishes a tax measure for taxpayers subject to the presumptive income regime     On April 18, 2020, Decree No. 553 was published, which, in addition to Decree No. 420 , extends the deadline for taxpayers subject to the presumptive income tax system to exercise the option to pay taxes on income obtained during 2019, on the basis of effective income determined under full accounting. The deadline is extended until 31 July 2020 ...

This Tax Alert summarizes a recent ruling of the Karnataka Appellate Authority for Advance Rulings[1] which upheld that ‘Pre-sale and Marketing Services’ rendered by an Indian subsidiary (‘service provider’/ ‘supplier’) to its foreign parent entity ( (‘service recipient’) qualify as intermediary services, thereby subject to GST ...

Deacons | July 2021

In a decision that will no doubt come as a great relief to the funds, banking, and asset management industries, the Court of Appeal ruled in Nomura Funds Plc v Collector of Stamp Revenue [2021] HKCA 1040 that a merger effected by way of the universal succession of the merged company (i.e., the surviving company) to the assets and liabilities of the merging company (i.e ...

Default interest rates on tax debts and refunds are lowered.- Through Superintendency Resolution No. 066-2020/SUNAT, published on March 31, 2020, the following is established from April 1, 2020: i) The default interest rates (TIM) on tax debts in national currency will be 1% per month; and in foreign currency, it will be 0.50% per month. ii) The interest rate for reimbursement in national currency made for undue or excess payments will be 0.42% per month ...

New extension of deadlines is established for the submission of the PLAME.- Due to the extension of the State of National Emergency until April 26, 2020, through Superintendence Resolution No. 069-2020/SUNAT published on April 13, 2020, new expiration dates are established for the declaration and payment of the items contained in the PDT Electronic Sheet - PLAME, Virtual Form No. 0601: A ...

Arendt & Medernach | January 2023

General Trends – EU & international tax  > Click here for more details 2022 was another year rich in tax developments in Luxembourg and Europe. In an exceptional economic and geopolitical context, the European institutions continued to launch and implement international tax initiatives ...

Karanovic & Partners | April 2016

 Karanović & Nikolić is pleased to announce the election of one of its Partners, Tanja Unguran, to the position of AmCham Serbia's Chair of the Finance & Tax Committee. The Finance & Tax Committee, as one of the seven total AmCham Committees including those in charge of Combating Grey Economy, Healthcare Systems, Corporate and Business Law, Human Resources, Labour Task Force, and Real Estate Task Force, is tasked with improving the business environment via atwo-year agenda ...

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 ...

SyCipLaw's Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the second quarter of 2023. Please read the full texthereor via thislink. The SyCipLaw T.I.P.S - International Edition covers the following tax issues: 1. May a public utility treat corporate income taxes as operating expenses for purposes of computing rates chargeable to consumers? 2. For input value-added tax ("VAT") refund claims filed prior to RMC No ...

SyCipLaw’sTax Department has prepared Tax Issues and Practical Solutions(T.I.P.S.) for May. Please read the full text hereor via this link.SyCipLaw’s Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S ...

SyCipLaw's Tax Department has prepared the T.I.P.S. for July which covers the following tax issues: 1. May the Bureau of Internal Revenue validly serve an assessment notice through the central receiving station of an establishment where the taxpayer is a tenant without proof of authority of the person who allegedly received the mail as part of her functions? 2 ...

SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for August. The August 2023 issue covers the following tax issues: 1. May the ruling in the 2011 case of Commissioner of Internal Revenue v ...

SyCipLaw TIP 1: Based on reports, the BIR is considering applying a minimum threshold on who will be required to submit BIR Form No. 1709. The threshold may be based on the assets or revenue of the entity or the size of the transaction, or both. However, until the BIR issues the relevant circular, a taxpayer entering into transactions with related parties must ensure that it complies with the requirements under RR No ...

On June 13, 2016, the then Commissioner of Internal Revenue issued Revenue Memorandum Circular No. 62-2016 purporting to clarify the proper tax treatment of percentage tax or gross receipts tax (GRT) due on transactions covered by Sections 1211 and 1222 of the Tax Code which are shifted through contractual stipulations to borrowers/customers/clients(“passed-on” GRT) ...

SyCip Salazar Hernandez & Gatmaitan (SyCipLaw) has received Tier 1 rankings in “Patents” and “Copyrights/Trademarks” categories in the Philippines on Thomson Reuters’ Asian Legal Business (ALB) IP Rankings for 2022. ALB is a publication that provides insights on legal professionals throughout Asia and identifies and ranks top firms for intellectual property practice in Asia ...

Shearn Delamore & Co. | October 2020

A case note by Abhilaash Subramaniam Introduction In the recent case of SWW v Ketua Pengarah Hasil Dalam Negeri, the High Court of Malaya granted the taxpayer leave to apply for judicial review, a stay of proceedings pending the disposal of the taxpayer’s application for judicial review and subsequently allowed the taxpayer’s judicial review application on the merits, ordering a prohibition on all collection and enforcement action relating to disputed taxes and assessments

ENSafrica | March 2018

Surviving the transition to a 15% VAT rate   The South African Minister of Finance, Malusi Gigaba, tabled the 2018/19 Budget in Parliament on Wednesday, 21 February 2018. Government announced a lower than predicted 1% increase in the value-added tax (“VAT”) rate from the current 14% to 15% with effect from 1 April 2018 ...

    Supreme Court Ruling Sets the Foundation for GST on Secondment of Employees     AUTHOR: Reena Asthana Khair Senior Partner and Head International Trade & Indirect Taxation Kochhar & Co. EMAIL: [email protected]   Japanese Multinational companies often share their talent pool across borders and jurisdictions by secondment of Japanese nationals ...

Waller | June 2014

The United States Supreme Court ruling in Clark v. Rameker could have an impact on what are sometimes an individual’s most significant legacy assets: individual retirement accounts, or “IRAs.” A participant’s IRA is generally afforded protection in bankruptcy proceedings ...

Haynes and Boone, LLP | June 2018

On June 21, 2018, the United States Supreme Court, in South Dakota v. Wayfair, Inc., held that a state can now require companies not physically present in that state to collect tax on internet sales made to its residents. The explosive growth of e-commerce combined with the states’ eroding tax base convinced the Supreme Court to turn back a half century of jurisprudence ...

Under article 253(d) of the National Internal Revenue Code (NIRC), when an association, partnership or corporation commits an act or omission that violates the Tax Code, the penalty "shall be imposed on the partner, president, general manager, branch manager, treasurer, officer-in-charge, and the employees responsible for the violation". This means that any of the persons enumerated may be criminally prosecuted for the corporation or partnership's criminal act or omission under the code ...

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