On 8 October 2021, 136 member jurisdictions of the OECD’s Inclusive Framework signed up to a revised Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. The Statement confirms a number of issues left outstanding from the previous statement on 1 July. Notably, it confirms the amount of residual profits to be redistributed under Pillar One, the rates of tax under the new Global Minimum Tax regime and subject to tax rule, the calculation of the substance based carve out, and the timing of the implementation of the plan. The Inclusive Framework has been able to reach near unanimous political agreement on the broad architecture of the Two-Pillar solution and will now turn to the technical challenges of agreeing the finer details ahead of publication of implementation instruments.
Following the National Assembly’s adoption of the Law on Tax Administration, the Vietnam Ministry of Finance just issued Circular No. 80/2021/TT-BTC to provide implementing guidelines on the Law on Tax Administration and Government Decree No. 126/2020/ND-CP. One of the important provisions under Circular 80 is tax administration with respect to e-commerce business, digital-based business and other services of overseas suppliers without having a permanent establishment in Vietnam.
All but four of the OECD G20 Inclusive Framework members, including South Africa, have signed an agreement that will reform the world’s tax system. Two African countries – Kenya and Nigeria – have not yet signed the agreement. The new two-pillar system will set out a reallocation of taxing rights as well as a global minimum tax rate for certain organizations. It is expected that these changes will address global tax revenue imbalances, which is expected to benefit African countries.
The growth in demand for online retail services has led to extensive disruption in the Consumer Goods and Retail (CG&R) sector in Africa. Africa-based CG&R businesses have been adapting their digital operating models to keep up with demand, and multinational e-commerce organisations operating in the region are recording rapid growth. However, this digital expansion in the CG&R sector has numerous tax implications, both locally and regionally.
Taxpayers have the right to appeal HMRC’s decisions to the Tax Tribunal in most circumstances. In reality, many find the appeal process too arduous, time consuming and risky; resulting in taxpayers conceding or settling matters with otherwise good prospects of success. We expect that the recommendations of the Tax Law Review Committee, if implemented, will improve taxpayers’ access to justice and level the playing field between taxpayers and HMRC.
In this Quick Chat video, Baker McKenzie’s Labour and Employment, Global Immigration and Mobility, and Tax lawyers review the wide variety of legal issues for Canadian employers to consider regarding a temporary or permanent remote work opportunity outside of the province of the employment agreement and provide tips on how employers can offer employees flexibility while remaining compliant with employment, immigration and tax requirements.
In the current pandemic, many employers have been required to rapidly shift to a remote working model. This shift has raised a number of issues that employers have had to consider, including how best to monitor remote workers’ hours of work, how to appropriately supervise and mentor them, and how to appropriately address health and safety obligations outside the usual office environment.
With the tightening of Australia’s border controls restricting the ability of individuals to travel overseas and back again, employers are now also grappling with situations where employees who have traveled outside Australia are requesting the ability to work remotely whilst overseas.
Baker McKenzie has published its fully revised and expanded Global Guide to Legal Issues in Securitisation. This guide has been compiled by Baker McKenzie lawyers in 33 jurisdictions across the globe. It provides you with an overview of the general legal, tax, accounting and regulatory issues typically relevant to securitisation structures.
On 11 March 2021, the Court of Justice of the European Union issued its ruling in case C-812/19. The case concerned the VAT treatment of the supply of services from a head office, which was part of a VAT group in Denmark, to its branch in Sweden.
On 3 June 2021, the Trade Remedy Authority of the Ministry of Industry and Trade (MOIT) received a petition for an anti-dumping investigation with regard to office desks and chairs originating from China and Malaysia. The petitioners are Xuan Hoa Vietnam JSC, and Hoa Phat Furniture., JSC. On 1 September 2021, the MOIT issued Decision No. 2091/QD-BCT to officially conduct the investigation.