On 7 July 2023, the Substitutive Amendment to Bill No. 2,384/2023 was approved, with the purpose of disciplining the proclamation of judgment results in the event of a tie vote within the scope of the Administrative Council of Tax Appeals (CARF), among other measures connected to tax litigation and the transaction in the collection of credits by the Federal Treasury.
Our latest Doing Business in South Africa Guide outlines some of the principal matters affecting an overseas entity that wishes to establish and operate a business in the country. The Guide offers a range of practical advice and useful guidance for entities seeking to do business in the country.
July sure is a busy month in the Two Pillar world, with various developments to digest, including today’s final piece of the Pillar Two Administrative Guidance. Here are the links to the relevant July documents. Please watch this space for our detailed alerts being prepared by our experts.
Welcome to the 2023 edition of Baker McKenzie’s Doing Business in Canada, a practical guide to the business and investment legal framework and developments in Canada. We hope that you find this guide a useful and practical resource.
In recent years, we have seen a significant increase in Custom Audits by both Federal and State Tax Authorities, mainly to companies with foreign investment. In this Quick Chat video, our International Commercial partners in Mexico along with the Managing Partner for Baker McKenzie’s Mexico offices discuss what to expect from an audit, the consequences including financial liability and the preventive measures Mexican companies must take.
By judgment dated 23 March 2023 (2 K 172/19), the Tax Court (Finanzgericht) Hamburg determined to what extent a tax office may request the submission of emails within the scope of a tax audit.
The Tax Court ruled that the request for submission of an overall journal in the form of a list of all emails, including emails that are not relevant for tax purposes (and that are not internal correspondence), was unlawful. According to the view of the Tax Court, the tax offices is not limited to conducting interviews since emails have an increased evidentiary evidence.
With a population of just over 100,000, Labuan is a small Malaysian island located off the coast of Borneo in Southeast Asia. Little known to most is that Labuan, a federal territory of Malaysia, has a special status as an International Business and Financial Centre (IBFC). Prior to its rebranding as an IBFC in 2008, in the 1990s, Labuan was initially declared as an international offshore financial center.
On 12 June 2023, the Rio de Janeiro Municipality enacted Law number 7,907/2023 (the so-called “Neutral ISS Law”) to promote the development of carbon credits market involving Rio de Janeiro taxpayers and encourage the reduction of greenhouse gas emissions.
The so-called UK Mandatory Disclosure Rules came into force in the UK on 28 March 2023. They comprise new cross-border tax avoidance arrangement disclosure rules that implement the OECD Model Mandatory Disclosure Rules.
On 18 June 2023, the Swiss electorate voted in a public referendum in favor of a constitutional amendment to implement the global minimum tax. After the vote, the focus now shifts to its technical implementation. MNEs now have the required certainty to proceed with their preparations and planning for Pillar 2.