On 27 May 2022, the OECD released a new public consultation document presenting A Tax Certainty Framework for Amount A which will be the subject of this alert. Concurrently, a separate public consultation document dealing with Tax Certainty for issues related to Amount A was published, which is the focus of another alert. With these two new documents, the OECD has now released 7 out of 13 building blocks forming Amount A under Pillar One.
In the midst of regulatory developments, increased enforcement and greater coordination amongst customs and transfer pricing regulators, businesses need to stay abreast of the latest considerations with respect to the interaction between transfer pricing and customs valuation within their supply chain.
In the session on 23 June, senior tax and transfer pricing professionals will share their observations on the latest customs and transfer pricing developments in the EMEA region and provide practical guidance on how to mitigate risks on these issues.
In two recent cases, the Court of Appeal has provided some guidance on the test to determine if someone is an employee for tax purposes. In doing so, it considered and, in some key respects, distinguished the approach taken when determining whether someone is an employee or worker for the purposes of employment rights. The result may well be a different answer when determining status for tax purposes from the answer for the purposes of employment rights.
By means of Provincial Law 15,339, published in the Official Gazette of the Province of Buenos Aires on 7 June 2022, the province of Buenos Aires adhered to the Knowledge Economy Promotional Regime. By adhering to the Regime, through granting tax benefits, the province of Buenos Aires seeks to promote the development of those activities that apply the use of knowledge and the digitalization of information to obtain goods, provide services and/or improve processes.
On 24 February 2022, the Russian Federation launched a full-scale military invasion of Ukraine. The martial law is in effect in Ukraine since then. As a result, special legislation has been adopted in various areas, including that directly affecting business activity. Baker McKenzie lawyers are pleased to present the fourth edition of Ukrainian Laws in Wartime: Guide for International and Domestic Businesses, a brief overview of the key features of wartime legislation.
The UK and international tax landscape has never been quiet for fund and asset managers (GPs) but a number of recent tax developments will have the potential to significantly affect how these businesses operate. Some of these developments will, however, be welcome by most GPs.
For all current and potential investors in a country, understanding the legislation, the system, the guarantees and other nuances of local regulations is important, especially as the legal framework is constantly evolving. This is why Estudio Echecopar, member firm of Baker & McKenzie International, has put together Doing Business in Peru 2022, a handbook that offers find useful and current information related to the legal framework that every investor must take into account to operate in the country.
The Ministry of Justice and the Ministry of Internal Affairs and Communications have recently approached certain foreign companies (in particular tech companies) and issued notices requiring that the company make a registration in Japan under the Companies Act.
In this article, we comment on this issue and provide our perspectives on the Japanese Companies Act, tax and other related laws and regulations such as the Telecommunications Business Act.
On 11 March 2022, Supplementary Law #192 introduced the single-stage ICMS tax regime on transactions involving fuels. This new law aims to reduce the final customer’s tax burden on transactions involving the following fuels: gasoline, anhydrous ethanol fuel, diesel, biodiesel, liquefied petroleum gas and natural gas. Moreover, Supplementary Law #192 temporally reduces to zero the PIS and COFINS rates on transactions involving the above-mentioned fuels until 31 December 2022, without affecting the accrual of credits.
On 18 March 2022, the Brazilian Federal Revenue issued Normative Instruction No. 2,072/2022, which brought relevant changes to the import and export customs clearance.