On 12 January 2021, the Ministry of Economy and Finance issued Prakas N0. 009 on the Reclassification of Taxpayers under the Self-Assessment Taxpayer Regime (“Prakas 009”). The purpose of Prakas 009 is to amend the previous classification of taxpayers to ensure that the collection of taxes are carried out in a transparent and equitable manner which is in line with the growth of the Cambodian economy ...
This year marks the fifth anniversary of the introduction of the transfer pricing regime in Cambodia. Recent changes in local transfer pricing regulations, tax audit practices, and documentation mean that now – more than ever – you need the right advisor to reduce the tax audit risks associated with related party transactions. DFDL Cambodia’s specialized transfer pricing team combines international experience and deep knowledge of the local legal and tax environment ...
In an increasingly interconnected world facilitated by the rise of global digital commerce a number of gaps have been exposed in the tax systems of countries with perhaps one of the most significant issues being the difficulties in collecting tax from those providing digital goods and services without a physical presence in the jurisdiction where those goods and services are consumed ...
In terms of the South African controlled foreign company ("CFC") legislation contained in section 9D of the Income Tax Act, 58 of 1962 (the "Act"), where South African residents directly or indirectly hold more than 50% of the total participation rights (essentially, the right to participate in the benefits of the rights attaching to a share) in a foreign company, a proportional amount of the “net income” of that foreign company (as a CFC) will be included in the income of those residents ...
On 2 November 2015, the South African National Treasury published a Draft Carbon Tax Bill (the “Bill”) for public comment, with the comment period commencing immediately and continuing until 15 December 2015. Measurement, reporting and verification (“MRV”) of emissions data arising from greenhouse gas related activities underpin the effective functioning of the proposed carbon tax ...
South African President Cyril Ramaphosa has signed into law the Carbon Tax Act, 2019, which comes into effect on 1 June 2019. With the passing of the carbon tax into law, a price on carbon emissions is now a reality for the South African economy.The impact of the legislation, along with complementary measures such as the national greenhouse gas emission reporting regulations, will have a transformative effect on the South African economy ...
Our partner, Jessica Power, and our associate, Ximena Silberman, contributed to the Q&A section of the Chilean chapter in the “Corporate Tax 2020” edition of the International Comparative Legal Guides. Jessica Power has been a partner at Carey since 2008 and is co-head of the Tax Group ...
Amendments made to the Quebec Professional Code in 2001 authorize professional orders to allow their members to exercise their professional activities within the framework of a limited liability partnership, or a joint-stock company. In 2002, the Ordre des comptables agréés (Order of Chartered Accountants) was the first professional order to adopt a regulation to this effect. The Quebec Bar and the Ordre des comptables généraux licenciés (Certified General Accountants) followed suit in 2004 ...
The Malaysian Bar had challenged the DGIR’s power to undertake tax audits on the clients’ accounts of law firms on the basis that it contravened legal professional privilege ...
Reform is in the air for Central America’s tax systems. Alfredo Rodríguez, Diego Martín Menjívar, Armando Manzanares,Carlos Taboada and Diego Salto Van der Laatof Consortium Legal take a look. Central America’s tax systems have certainly evolved over the past few years. Looking ahead, the need to increase fiscal revenues and the lack of modernised systems will trigger further reforms in most of the countries ...
Under newly enacted Section 1400Z of the Internal Revenue Code of 1986 (the “Code”), beginning on December 22, 2017, taxpayers may defer, and in some cases partially eliminate, capital gains by making certain investments in “qualified opportunity zones.” A qualified opportunity zone is a “population census tract” in a state designated low-income community ...
The Ministry of Culture issued Decree 475, 2020, to amend the cultural sector’s conditions due to coronavirus. Due to the health crisis, the Ministry of Culture issued Decree 475, 2020, to amend the payment conditions of the pro-culture stamp duty, the contribution to public shows and the film development fee are modified. According to Decree 475, 2020, Governors and Mayors must transfer 20% of the culture stamp duty for the social security of creators and cultural managers ...
In recent months, a number of changes to the Russian tax legislation, implying long-term effects for both Russian taxpayers and foreign investors, are taking place. Amendments to the Double Tax Treaties ('DTTs') are among of the most important ones. Below, we provide our consolidated analysis of the forthcoming changes and recommendations on steps to prepare for them ...
Changes to Stamp Duty, LTT & EPTT in Jersey Increase to the first-time buyer threshold The Law provides a welcome amendment to first time buyer stamp duty rates (and equivalent land taxes such as land transactions tax (LTT) in respect of share transfer properties and enveloped property transactions tax (EPTT)), with the maximum purchase price threshold for first-time buyers increasing from £500,000 to £700,000 ...
Through an announcement issued by the Ministry of Finance, Mario Marcel, the government presented the general outlines of its tax reform proposal. This reform would consist of four bills (two of which would be submitted to Congress during July, and the remaining ones during the fourth quarter), which will be relevant to know in order to analyze the details of this announcement. On our web page (https://reformatributaria.carey ...
The State Administration of Taxation issued the Notice on Several Issues in the Implementation of Tax Agreements and the Individual Income Tax Law on Individuals With No Domicile in China on 23 July 2004. The Notice, which entered into effect on 1 July 2004, clarifies a number of issues related to the levy of PRC individual income tax ("IIT") on expatriate employees ...
On 16 March 2007, the Standing Committee of the National People’s Congress promulgated the Enterprise Income Tax Law of the People’s Republic of China. The Law harmonises the tax laws applicable to foreign and domestic enterprises. The new law marks a major change in PRC tax policy. Effective 1 January 2008, both domestic enterprises and foreign-invested enterprises (FIEs) will be subject to income tax at the unified rate of 25% ...
The State Administration of Taxation issued the Measures on the Self- Declaration of Personal Income Tax (Trial Implementation) on 6 November 2006. The Measures cover the filing process for those who satisfy one of the following conditions:1. Annual income of 120,000RMB or more; 2. Wages or stipends earned from two or more sources within China; 3. Income earned outside China; 4. Any acquired taxable income without withholding; 5 ...
At the 18th Session of the Standing Committee of the 10th National People’s Congress held on 27 October 2005 amendments were adopted to the Individual Income Tax Law of the People's Republic of China. The amendments were promulgated by President Hu Jintao on 27 October 2005 and enter into effect on 1 January 2006. Tax free allowance A first amendment raises the tax free allowance applicable to wages and salaries from RMB 800 to RMB 1,600 ...
On 27 November 2006, the Ministry of Finance and State Administration of Taxation jointly issued the Notice Regarding Several Stamp Tax Policies. The Notice states that:1. Stamp tax will be levied on contracts submitted electronically. 2. Stamp tax will be levied on purchase and sale contracts between power plants and power grid networks and on those between two power grid networks ...
The State Administration for Taxation issued the Reply of the State Administration of Taxation on Issues relating to Tax Refund for Reinvestment by Foreign Investors on 20 October 2005. The Reply explains the conditions under which a foreign investment enterprise (“FIE”) can obtain a rebate on its enterprise income tax (“EIT”) for re-investment of its profits if such re-investment is made in instalments or in phases ...
