In this briefing, we will review the implications of the Law for property transactions in Jersey. Tax on purchase of residential properties which are not used as a main residence The key implication of the Law is that stamp duty (and equivalent land taxes such as land transactions tax and enveloped property transactions tax) on acquisitions of domestic residential property which will not be the purchaser's main residence will be increased ...
On October 15, 2020, the U.S. Small Business Administration (SBA) issued a final rule making changes to the SBA’s 8(a) program regulations “to more clearly articulate SBA’s intent with regard to certain aspects of the 8(a) program to eliminate confusion and decrease burdens on procuring activities and 8(a) participants ...
On October 15, 2020, the U.S. Small Business Administration (SBA) issued a final rule making changes to the SBA’s 8(a) program regulations “to more clearly articulate SBA’s intent with regard to certain aspects of the 8(a) program to eliminate confusion and decrease burdens on procuring activities and 8(a) participants ...
Emi Rowse Igusa, partner and head of the Japan practice at Kudun and Partners, was invited by the Thailand Arbitration Center (THAC) to share her insights as a panelist at the THAC Academy Launch Event. Kudun and Partners associate Joshua Yang also attended the launch event. The event featured several high profile keynote speakers including Dr. Phongthep Thepkanjana, Former Deputy Prime Minister of Thailand, Mr. Wallop Nakbua, Deputy Permanent Secretary of the Ministry of Justice and Dr ...
The Foreign Influence Registration Scheme (FIRS) will compel non-UK businesses and their UK agents or representatives to register if they are engaged in ‘political influencing activity’. Failure to register would be a criminal offence potentially leading to a fine or imprisonment. The FIRS is included in draft legislation – the National Security Bill - which, if adopted, is foreseen to come into effect in Q1 2023 ...
Trine Vabog is affiliated with the TMT team in Oslo. Trine is among Norway’s leading IT lawyers and works with complex ICT procurements and ICT contracts from both the customer as well as the provider side. She has a deep understanding and expertise within the ICT area, considerable experience as a project manager and negotiation manager for ICT acquisitions and advises parties within both public and private sectors ...
As CIT finalization approaches, we highlight the existing Transfer Pricing compliance requirements for Vietnam taxpayers, under Decrees 132 and 126, and Law No. 38: When does Transfer Pricing (TP) apply? When a Vietnam company or local subsidiary of a foreign company has intra-group transactions (goods, services, loans or royalty transactions) with its related parties ...
Over the past few weeks, the European Union has issued somewhat of a landmark act which is aimed at addressing the topical issue surrounding the lack of women in top-level corporate positions ...
The past two years have seen significant growth in the number of mergers and acquisitions nationwide with many agriculture and farming business owners choosing to liquefy their assets and move on. At the same time, employers have had to cope with numerous challenges that have made the task of hiring and preparing I-9s for new employees more difficult. Some employers (unlawfully) stopped preparing I-9s for new hires altogether ...
With the 2022 year quickly coming to an end, we take this opportunity to remind our clients and readers of the annual compliance obligations for enterprises in Cambodia. With each year that passes there seem to be more compliance obligations, and the latest 2023 compliance requirements continue this trend. With that in mind, we have provided below what we believe are the most important annual compliance requirements that enterprises in Cambodia should be aware of ...
The Norwegian Bar Association’s law committees are appointed by the association’s executive board. The committees consist of members with particular expertise within the selected field. The committees follow legislation developments closely and advise within their special field of expertise. With a focus on the rule of law and quality in legislation the Bar Association’s law committees deliver around 80 statements every year ...
On December 13th, 2022, Decree No. 84 was published in the Official Gazette approving the Regulations governing mediation, conciliation, and arbitration in consumer matters, which will enter into force six months after publication, that is, on June 23rd, 2023. The issuance of this regulation is framed in the recent entry into force of the Pro-Consumer Law that seeks to encourage consumer protection ...
With office attendance down and face to face events less frequent, the ability to meet and network with industry peers has been somewhat stymied in recent years. This is particularly true for the in-house lawyer community who, having worked through a period of sustained legislative, societal, economic and regulatory change, have arguably been one of the groups to have suffered the most from the inability hear how other IHLs across the industry have managed these challenges ...
Companies face the loss of a major tax break on research and experimental ("R&E") costs for 2022, absent Congressional action. Since 1954, Internal Revenue Code section 174 has allowed taxpayers to immediately deduct R&E costs. Effective January 1, 2022, the Tax Cuts and Jobs Act of 2017 ("TCJA") amended section 174 to eliminate the deduction of R&E costs. Instead, costs for R&E activities in the U.S ...
Kudun and Partners represented Altitude Development Co., Ltd., one of Thailand’s leading real estate development, in the offering of newly issued shares to Lotus Global Investment, a foreign PE fund, representing 12.49 percent of its total issued share capital, with a transaction value of THB 500 million (approximately USD 13.8 million). This transaction is an important milestone prior to the client’s initial public offering in the Stock Exchange of Thailand ...
In a Pre-Budget Report (PBR) announced to Parliament last week, the Government has set out its priorities for next year's budget. These include proposals to increase revenues via significant changes to the current employment tax regime. Perhaps the most headline-grabbing aspect of these potential reforms is the proposal to increase the employer portion of payroll tax for exempted companies, from 10.25% to 10.75% ...
What is ATAD III? In December 2021, the European Commission (“EC”) published its proposed Anti-Tax Avoidance Directive (known as “ATAD III”). ATAD III is intended to discourage the misuse of shell companies within the European Union (“EU”). The Directive is aimed at EU-resident entities which claim benefits under double taxation treaties and other EU Directives, but which lack a minimum level of economic substance ...
Here’s the Scenario: After months of working with a new developer client (and providing hours of unreimbursed value engineering) and hard negotiations over the cost plus GMP contract (fighting over indemnity/escalation/savings/liquidated damage clauses), you have a deal. You pop a cork with all involved since the developer has said this is one of many future projects. Your very patient subcontractors have held their prices ...
In Commissioner of Internal Revenue v Ruben U Yu,(1) the Court of Tax Appeals (CTA) en banc clarified that the 180-day period referred to in section 228 of the Tax Code, as amended, applies only to the period within which the Commissioner of Internal Revenue (CIR), or their duly authorised representative, may act on a protest against a tax assessment ...
Due to the covid-19 pandemic, registered business enterprises (RBEs) in the information technology-business process management (IT-BPM) sector have adopted work from home (WFH) arrangements to continue business operations. Now that movement restrictions have been relaxed, a balance must be struck between the requirement for RBEs to operate within economic zones and the clamour of RBEs to continue hybrid work arrangements while maintaining their fiscal incentives ...
The EU’s Digital Markets Act (DMA) [1] entered into force on 1 November 2022. A business that considers the platform it uses will likely be designated as a ‘gatekeeper’ and that the platform’s rules/behaviour are unfair can take certain steps now [2]. Q1 2023 to Q2 2023 - Engage with the platform to change its rules/behaviour ...
Meta continues to make headlines for the wrong reasons in the data protection field as this week the Irish data regulator, the DPC fined the tech company €265 million ($275 million) for infringements of Articles 25(1) and 25(2) GDPR. It is nothing new that Meta pushes data protection boundaries ...
As the Procurement Bill has made its way through Parliament, there has been much talk of giving 'smaller companies a bigger slice of the procurement pie'. It remains to be seen if, and to what extent, the relevant proposed amendments to the Bill are retained in the final version of the legislation. However, what is striking is the significant challenges many SMEs would continue to face in the event of a breach (or suspected breach) of the procurement rules ...
The EU revenue cap which limits certain electricity generators' revenues has raised many questions within the energy sector. In Finland, the revenue cap will likely be implemented in the form of a temporary windfall tax which would apply to profits made in 2023. Our energy team's associate Nelli Rönkkö has summarised the key points regarding the implementation of the EU revenue cap in Finland ...
