The concept of unjustified tax benefit is formalized in the Russian Tax CodeAugust 03, 2017Dear Sirsand Mesdames,We would like to inform you that the Federal Law No. 163-FZ dated July 18, 2017 (the “Law”) introduced amendments to the Russian tax legislation, codifying the concept of unjustified tax benefit, which was previously described by the Supreme Arbitration Court in 2006. The new Article 54 ...
1. Introduction With the further globalization of the world financial infrustructure accompanied by the persisting lack of international coordination in fiscal affairs? increasingly the attention of the major developed countries (in particular, such groupings as G 7 and G 10) is turned to the problems of erosion of national tax bases and international tax evasion/avoidance, as well as the role played in it be so-called tax haven ...
The incorporation of the Law on Security Interests in El Salvador has the objective to create a registry for security interests, that is to say, the inscription of the security interests’ creation, modification, extension, termination and execution, as well as the publicity of these instruments. The Commercial Value that some brands have, plays a very important role and represents, for some entrepreneurs, a mechanism which enables them to access credits ...
Currently, 33% of Ireland's Greenhouse Gas emissions are produced as a result of agricultural activities. In order to reduce emissions there must be a change in farming methods; opportunities are also present in the areas of forestry, bioenergy and land-use practices. While reducing emissions, policy in this area must also aim to: Maintain the "green" brand image of Irish food exports abroad ("Origin Green" etc.). Maintain good prices for producers ...
The economic substance requirements in the Cayman Islands, introduced by the International Tax Co-operation (Economic Substance) Act (as revised) (the “ES Act”) (Economic substance requirements in the Cayman Islands), have been extended to partnerships pursuant to the International Tax Co-operation (Economic Substance) (Amendment of Schedule) Regulations 2021, which came into force on 30 June 2021 ...
South Africa has a rapidly evolving climate change policy environment, which is in-keeping with the country¡¦s view of itself as a developing country leader in the climate change arena. Part of the policy environment includes attention to financial mechanisms that can be marshaled in support of the response to climate change. Flowing from the notion of using financial mechanisms in this manner, the National Treasury has taken initial steps towards the implementation of carbon taxation ...
On July 3, 2023, Ohio’s biennial budget bill[1] was signed into law by Governor Mike DeWine. In addition to major budget provisions, the bill also includes notable changes to Ohio’s Medical Marijuana Control Program (“MMCP”), the state program that regulates and licenses cultivators, processors, testing laboratories, dispensaries and medical marijuana cardholders. Beginning January 1, 2024, the MMCP will be under new management ...
After a rollercoaster of a ride, the Retained EU Law (Revocation and Reform) Bill has received Royal Assent and is now an Act of Parliament. From the initial proposal of an all-singing, all-dancing automatic revocation of thousands of retained EU laws by the end of this year, to a more restrained revocation of just under 600 irrelevant or redundant laws, the Bill will not deliver the big bang that it initially promised ...
This presentation will cover the Biden administration’s environmental policy goals and the regulatory changes we can expect from the administration in the environmental sphere. We will discuss potential changes we anticipate in the Clean Water Act WOTUS rule, changes to energy policy, and new regulation of PFAS compounds. We will also discuss the impact of the new administration at EPA and what clients can expect going forward in their dealings with EPA ...
The U.S. EPA proposed a new rule under the Clean Water Act reversing the Trump Administration’s rule for water quality certifications under section 401 of the Act. Section 401 provides states and tribes with authority to protect waters within their jurisdiction from pollutant discharges originating from federally-licensed or -permitted projects ...
The Benefits of Using a an Unlimited Liability Company (1) Introduction Unlimited Liability Companies (“ULC”) have become useful vehicles for the acquisition of a Canadian business by a U.S. investor. This paper summarizes the advantages of using a ULC, the treatment of a ULC in Canada and in the U.S. and the use of a ULC in a factual setting involving the acquisition of a Canadian business. Until recently, only Nova Scotia offered the possibility of incorporating a ULC ...
This article looks at what ESG means, what we really mean when we talk about ‘ESG lending’, and the types of ESG lending available. When people talk about ‘ESG Lending’ they’re often talking about sustainable lending - encompassing social loans, green loans and sustainability linked loans. Potentially available to all businesses, now is a great time to get familiar with these types of products, as well as the corresponding jargon ...
After all of the sand had run out of the hourglass, Congress finally passed (and the President signed) a compromise tax bill to avoid very substantial income tax increases on taxpayers with income under $400,000 ($450,000 for joint filers). The good news for our estate planning clients is the “permanent” extension of the current estate, gift, and generation-skipping transfer tax exemptions, and a slight increase in the tax rate from 35% to 40% ...
On March 31, 2021, the Biden Administration released a Fact Sheet for its proposed American Jobs Plan (the “AJP”). The full text of the AJP can be found here. Although the AJP is primarily a proposal for rebuilding our country’s infrastructure, positioning the U.S. to compete with China and creating millions of jobs, it also proposes important corporate tax changes necessary to fund the AJP ...
Fossil fuels are under attack in the legislative, regulatory, and judicial arenas, and in the market place—driven by environmental concerns, especially global warming and associated climate change. The Sierra Club, for example, has launched a “Beyond Dirty Fuels Initiative,” seeking to “push back against the construction of dirty fossil fuel infrastructure that would lock America into decades more of climate-polluting oil and gas production ...
The Chancellor announced the first eight Freeport locations: Solent, East Midlands Airport, Felixstowe & Harwich, Humber, Liverpool City Region, Plymouth and South Devon, Teesside and Thames ...
Over the past few years, the South African Revenue Service (“SARS”) appears to have created a new category of doubtful debts allowances which they have termed a “specific” doubtful debts allowance, as distinct from the “ordinary” doubtful debts allowance to which a taxpayer is entitled under section 11(j) of the Income Tax Act, 1962 (the “Act”) in the ordinary course in respect of its doubtful debts ...
In conversation with... Our panel of experts - Nina Pindham of No.5 Chamber, Sam Grange and Will Thomas from Shoosmiths and Rhys Bradshaw from DLP Planning took a fresh look at the new "Planning" Bill and gave us their thoughts. There are many questions that many have about the new ‘Planning’ bill... Is this the final Act for s ...
1. LAND AND BUILDING TAX On 26th January, the Cabinet approved legislation with measures to reduce the tax on land and buildings, and land registration fees for residential housing as a means of alleviating the ongoing impact of the COVID-19 situation in Thailand. The new measures include: A 90% reduction of the land and building tax for 2021 that will be implemented through the enactment of a royal decree pursuant to Section 55 of the Land and Building Tax Act 2019 (the “Act”) ...
The Royal Decree No. 750 (B.E. 2565) issued under the Revenue Code regarding income tax exemption on investment in Thai startups (the “Royal Decree”) was recently published in the Government Gazette, in cases where the funding for the startups is provided directly or indirectly through Venture Capital (VC), Corporate Venture Capital (CVC), or private equity trust (PE Trust). This Royal Decree aims to unlock capital gains tax on investment in startups under the Royal Decree No ...
According to an anonymous source, a ‘Centre for Economic Situation Administration’ (“CESA”) meeting chaired by Prime Minister Gen Prayut Chan-o-cha was held on Friday 4 June that approved (in-principle) a set of proposed stimulus measures aimed at encouraging wealthy expatriates to Thailand ...
The Thai cabinet has recently approved the draft Royal Decree issued under the Revenue Code regarding income tax exemption on investment in Thai startups (the “Draft Royal Decree”), in cases where the funding for the startups is provided directly or indirectly through Venture Capital (VC), Corporate Venture Capital (CVC), or private equity trust (PE Trust). This Draft Royal Decree aims to unlock capital gains tax on investment in startups under the Royal Decree No ...
