Against a backdrop of economic stagnation and geopolitical conflict, businesses are preparing for a challenging year. Global disputes will continue at pace, according to insights from more than 600 senior lawyers at large corporations, with ESG and employment risks the greatest areas of concern. Our seventh annual report provides detailed analysis of disputes trends, as well as sectoral and region-specific developments, to prepare your organization for The Year Ahead.
The Doing Business in the Philippines handbook aims to equip both local and foreign entrepreneurs with a practical guide to navigating the ever-evolving business landscape in the Philippines. It provides information on the requirements needed when setting up and operating a business in the Philippines, including incentives under special registrations, taxation, employment, IP, dispute resolution, and industry-specific regulations.
On 8 January 2024, Commissioner of Internal Revenue Romeo D. Lumagui Jr. issued an advisory regarding the cessation of the Bureau of Internal Revenue (BIR)’s collection of the Annual Registration Fee (ARF), in compliance with Republic Act (RA) No. 11976 or the “Ease of Paying Taxes Act.”
On 28 December 2023, the Treasury and the IRS issued a notice of proposed rulemaking regarding whether a debt instrument is worthless for US federal income tax purposes under Code section 166 (the “Proposed Regulations”). The Proposed Regulations would update the standards under Treas. Reg. § 1.166-2 used to determine when debt instruments held by regulated financial companies or members of a regulated financial group are conclusively presumed worthless.
Over the last few months, the United Arab Emirates (UAE) have made a few legislative changes in relation to the Ultimate Beneficial Ownership (UBO) regulations as well as the associated administrative penalties, with the issuance of:
The Bureau of Internal Revenue recently issued Revenue Regulations No. 16-2023, which sets out the guidelines on the imposition of withholding tax on gross remittances by electronic marketplace operators and digital financial services providers to online sellers/merchants, in connection with goods and services sold or paid through the former’s platform.
The Regulations took effect on 12 January 2024.
Earlier this year, Canada’s mandatory reporting rules were broadly expanded by lowering the thresholds to trigger a reporting obligation and increasing the information that must be reported to the Canada Revenue Agency As a result, taxpayers may be required to flag certain mergers and acquisitions transactions in real time if it could be reasonably concluded that one of the main purposes of entering into the transaction was to obtain a tax benefit.
In this In Focus video, our Canadian Tax and Corporate Transactions lawyers discuss how common contractual protection clauses could trigger an early reporting requirement and expose taxpayers to significant penalties if they fail to report.
On 16 December 2023, the House of Representatives approved the bill of Tax Reform, based on PEC 45 (Constitutional Amendment Bill), in the final round after the Senate’s approval.
The final wording was published on 21 December 2023 (Constitutional Amendment No 132/23).
In Christensen v. United States, the Court of Federal Claims held that a husband and wife could credit French income taxes against their US net investment income tax. Christensen has an immediate and direct impact on taxpayers who are subject to the 3.8% net investment income tax.
Taxpayers who pay the net investment income tax and who reside in treaty jurisdictions should review their treaty positions and evaluate their ability to claim foreign tax credits under an applicable treaty for prior years and going forward.
In November 2023, the Internal Revenue Service of Ecuador published a new version of the Technical File for the Standardization of the Transfer Pricing Analysis (Ficha Técnica), which incorporates changes to the content of the Comprehensive Transfer Pricing Report, and modifies some methodological elements. The criteria of the Ficha Técnica are applicable for the current taxable year 2023.