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 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 ...
Instruction No. 27185 GDT (“Instruction 27185”) on the Display of Tax Registration Documents at Business Premises was issued by the General Department of Taxation on the 14th of November 2022 ...
pAs many of our readers know, a recurring theme in the industry is volatility and market uncertainty. Like recent quarters, the impact of inflation, Federal Reserve action, and interest rate movements continues to create uncertainty. In light of these conditions and declines in stock prices, we have observed many clients exploring less traditional ways to raise capital. Our corporate, financing, private equity and tax practices have been active in assisting in these efforts ...
Following the issuance of Prakas 003 on 26 January 2022 on the Rules for the Management, Establishment, and Functioning of Trusts (“Prakas 003”), on 3 November 2022, the Non-Banking Financial Services Authority (“NBFSA”) issued Prakas 052 regarding the Accreditation of Valuation Companies and Valuation Specialists in the Trust Sector (“Prakas 052”) in order to ensure the accuracy of the existing registered trust in Cambodia ...
A recent decision by a federal court of appeals found a New Orleans’ city code limiting short-term rentals of residential properties (such as AirBnB, Vrbo, Vacasa, etc.) to only landlords who lived inside the city was unconstitutional.In Hignell-Stark v. City of New Orleans, 46 F.4th 317 (5th Cir. Aug. 22, 2022), the Court held the city ordinance was an undue burden on interstate commerce ...
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 ...
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 ...
Shoosmiths’ specialist construction and regulatory teams have provided a detailed response to the government’s consultation on implementing the new building control regime for higher-risk buildings under Part 3 of the Building Safety Act 2022. The firm’s response draws on its expertise working with key stakeholders in the construction industry and first-hand experience of the issues that are relevant to the proposed regulations ...
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) ...
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 ...
In November 2022, South Africa is expected to present a report to the Financial Action Task Force (“FATF”) on the steps it has taken to address the shortcomings identified in the Mutual Evaluation Report concluded last year ...
Instruction No. 26118 GDT on the Use of Official Exchange Rate for Self-Assessment Taxpayers dated 28 October 2022 (“Instruction 26118”) has abrogated Instruction No. 10362 GDT, dated May 17, 2022 (“Instruction 10362”) ...
Does your contract contain a dispute resolution section that refers to the American Arbitration Association (“AAA”) rules, mediation and/or arbitration proceedings? If so, then you need to be aware of some changes that took effect last month. The AAA revised its Commercial Arbitration Rules and Mediation Procedures (“AAA Rules”) to update some existing rules and to add new rules ...
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 ...
The Royal Government of Cambodia will continue its relief measures to mitigate the economic impact of Covid-19 and support the recovery of the country’s tourism sector, according to an official announcement on 25 October 2022 ...
Alleged base erosion and profit shifting activities of multinational enterprises (“MNEs”) have been a hot issue globally and therefore the chances of an MNE being confronted with a transfer pricing audit have increased substantially over the last few years ...
On 6 October 2022, as part of the ongoing work of the OECD/G20 Inclusive Framework (“IF”) on Base Erosion and Profit Shifting (“BEPS”) to implement the Two-Pillar solution to address the tax challenges arising from the digitalisation of the economy, the OECD released its progress report for comment. Background The report was prepared for the purposes of obtaining further input from stakeholders on the administration and tax certainty aspects of Amount A ...
Due to the impact of the COVID-19 pandemic, many employers have seen an increased demand for international remote working arrangements. We have briefly touched upon the OECD guidelines relevant to these arrangements in a prior article ...
Please be informed that new Federal Law No. 332-FZ (“Law”) was passed on 14 July 2022 allowing the landlords to claim from the tenant the average monthly rent or to terminate the lease if the tenant's commercial activities are suspended. The Law establishes specific conditions under which the average rent could be claimed, imposes restrictions on landlord's right to terminate the lease agreement if foreign control over the lessee is terminated ...
RENT UPDATE COEFFICIENT FOR 2023 Law no. 19/2022 was published in Diário da República (Official Journal) on 21 October 2022 and, among other measures, it establishes the rent update coefficient for the calendar year of 2023. During the next year, the annual update coefficient for rents of the several types of leases, both urban and rural, established in article 24 of Law no. 6/2006 of 27 February, which approved the New Urban Lease Regime (NRAU), will not apply ...
pMany development authorities and other economic or industrial development authorities in the State of Georgia (each, an “Authority”) offer “Economic Development and Incentive” programs for private companies which commit to make new capital investments that promote trade and commerce and provide new employment or retain existing employment ...
With the end of the year just around the corner, it’s a good time to reassess plans and action-items. When reviewing your year-end estate planning or business transition concerns, there are several things to contemplate and review, such as year-end gift giving and tax considerations. Below is a list of items we’ve identified that you might want to consider as you plan for the end of the year and future transitions ...
On Aug. 16, President Joe Biden signed into law the Inflation Reduction Act (IRA) of 2022. Although it garnered headlines mostly for its $80 billion commitment to the Internal Revenue Service, the IRA went a long way toward providing tax incentives to real estate and related industries. Selecting a few primary issues from the IRA, as with any large-scale legislation, can be a challenge ...
