The underlying dispute relates to the MV «Cheshire» incident in 2017, where a cargo of fertiliser was subject to a major decomposition incident. The fertiliser that was carried on the vessel was damaged, and the vessel was declared a total loss. In February 2020, Oslo District Court ruled in favour of the cargo interests, holding the carriers liable for the cargo loss (approx. USD 25 million) (TOSLO-2017-180657-1). The carriers have appealed the judgement ...
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 ...
Introduced in 1979, the Quebec Stock Savings Plan (QSSP) was enormously success ful in the 1980s, encouraging the emergence of numerous Quebec SMEs which later became some of the most noteworthy success stories in Quebec business . On the other hand, the SME Growth Stock Plan, which replaced the QSSP in 2005, achieved a more mixed success . The 2009-2010 provincial budget, presented last March 19, attempts to remedy this situation ...
Following the publication of the proposal a few days ago, on 19 March the European Commission adopted the communication introducing a new temporary legal framework for State aid measures to support the economy in the current COVID-19 outbreak1. The last time the Commission had adopted a similar temporary framework was during the global financial crisis in 2008 ...
To create the most favorable environment for the intensive development of the IT industry and pooling resources for the new projects, the Russian Government has adopted a Law introducing a number of changes and tax incentives for the IT and Technology Companies. It will be effective starting from January 1st, 2021. Below, we provide our consolidated analysis of the new rules and recommendations on steps to be taken to prepare for the forthcoming changes ...
In January 2010, the decree-law that enacts the Accounting Standardisation System and repeals the Official Chart of Accounts (POC) will enter into force. This legislation was passed as part of a reform that is intended to be structural in nature and apply horizontally across the national accounting system ...
Dinsmore partner Kelvin Lawrence was published in Bloomberg Tax with co-author Bruce P. Ely from Bradley Arant Boult Cummings LLP. Their article, "The MTC Undertakes an Ambitious Study of Partnership Taxation," discusses the Multistate Tax Commission (MTC) Uniformity Committee's work group they created to study issues related to multistate taxation of pass-through entities ...
Last Friday, on 12 May 2023, the UAE Ministry of Finance (Ministry) published an Explanatory Guide which provides an explanation of the meaning and intended effect of each article of the Corporate Tax (CT) Law. The Explanatory Guide may be accessedHere ...
The Panamanian Limited Liability Partnership has been a part of Panama’s trade laws since 1916, when the Panamanian Commercial Code was issued. However, during 2009 it was subject to a profound reform in order to adapt it to an always demanding and changing market. As its “younger sister”, the worldwide famous “Sociedad Anonima” (1927), the limited liability partnership shall be filed at the Public Registry ...
I. The Liechtenstein Tax ReformThe former Liechtenstein Tax Act dated back to 1961. It was completely revised and the new Tax Act entered into force on 1 January 2011 (hereafter referred to as "Tax Reform"). The ratio for the year 2008 between the overall tax revenues in Liechtenstein and its GDP was 16.9%. In comparison, the equivalent figure in the USA was 20.3% and 23.1% in Germany.Liechtenstein has AAA rating and is totally debt free ...
It has a long been a principle of company law that the debts of a company are not the debts of its shareholders. It may be a surprise to some that this principle does not apply to certain tax debts thanks to section 181 of the Tax Administration Act No.28 of 2011 (“section 181”). This section allows shareholders to be held jointly or individually liable for the tax debts of their company. At first glance it seems unfair to punish those who do not manage the day-to-day running of a company ...
Speaking of compliance with tax obligations comes to our mind the duty to pay taxes (noun) as the Tax on the Transfer of Goods and Provision of Services (VAT) or Income Tax (ISR), which undoubtedly It is true; but equally certain it is that with the payment obligation exists another set of obligations formal or adjective. In this dual context of formal and substantive tax obligations, is of great relevance filing tax returns ...
On 29 May 2017, Judge Fabricius delivered judgment in the Gauteng High Court in the case of Pienaar Brothers (Pty) Ltd vs Commissioner for the South African Revenue Service and the Minister of Finance, in a case dealing with the Taxation Laws Amendment Act, 2007 (the “Amending Act”) which inserted section 44(9A) into the Income Tax Act, 1962 (the “Act”) ...
The King's Speech 2023 unveiled an ambitious vision for the future of transportation - heralding a new era of self-driving vehicles in the UK. The speech introduced a comprehensive plan to integrate autonomous vehicles into daily lives, as part of the government's commitment to advancing transportation technology. The proposed Automated Vehicles Bill will provide the Department for Transport with the necessary authority to certify the safety of driverless vehicles ...
The IVAucher programme was set up to stimulate private consumption in the sectors worst affected by the economic impact of the COVID-19 pandemic (catering, accommodation and culture). With regard to these sectors, “catering” is used in the broad sense to cover restaurants, cafés, bars and catering companies providing food and beverage services, and “accommodation” refers to hotels and other short-stay accommodation for holidays and business travel ...
The Internal Revenue Service (IRS) continues to generously interpret theFamilies First Coronavirus Response Act(FFCRA), deploying the “qualified leave tax credit” to maximize the benefit for employers and provide speedy aid, while adding new conditions to the “qualified family leave” mandate ...
This summer, the IRS significantly increased its efforts to police the taxation of Bitcoin, Ethereum, and other similar cryptocurrencies. On July 26, 2019, the IRS announced that it had begun sending letters to taxpayers who potentially failed to pay cryptocurrency taxes associated with digital currency transactions or failed to properly report those transactions. By the end of August, the IRS anticipates that it will have sent over 10,000 letters to taxpayers ...
On March 17, Treasury Secretary Steve Mnuchin announced a new tax plan to stimulate the economy during the COVID-19 crisis. Under the new plan, individuals and corporations can defer $1 million, and $10 million, respectively, in tax payments for 90 days. Importantly, individual and corporate taxpayers can take advantage of the new plan without incurring any interest or penalties ...
Having gone through a number of substitutions and amendments, the debt reduction rules contained in section 19 of the South African Income Tax Act, 1962 (the “Act”) and paragraph 12A of the Eighth Schedule to the Act now provide for the implications arising for a debtor where a debt owed to a creditor is waived, cancelled or capitalised by way of the issue of shares etc ...
On March 17, 2021, the IRS published IR-2021-59, postponing the deadline for filing individual income tax returns and payment of individual income taxes from April 15, 2021, to May 17, 2021. On March 29, 2021, the IRS issued Notice 2021-21, further clarifying the postponement of Federal income tax reporting and payment deadlines ...
In terms of the South African Income Tax Act, 1962 (the “Act”), distributions received by or accrued to a shareholder of a company may constitute either a dividend or a return of capital – each of which would give rise to different tax implications for the shareholder or company concerned ...
