The Spanish "REIT" was founded in October 2009 under the name of Sociedades Anónimas Cotizadas de Inversión en el Mercado Inmobiliario ("SOCIMI"). Its legal regime was set out in the Law 11/2009 of 26 October, which was subsequently amended by Law 16/2012 of 27 December to relax the legal requirements for their incorporation, remove the regulatory barriers and enhance the tax treatment applicable from 2009.
The aim of the RDL is to improve and clarify certain aspects of the rules governing outof-court protected refinancing arrangements and the so-called Spanish scheme or "homologación judicial" whilst trying to solve other inefficiencies of the legal regime applying to those refinancing arrangements that have arisen in practice. This is a preliminary review that we thought should be shared with you as soon as possible given the number of current debt restructurings that may be affected by its content.
Tax incentives granted at the federal level bolster the Brazilian economy. Those incentives apply to the oil and gas industry, in particular. Learn more about the Special Customs Regime of Export and Import of Goods destined to Exploration and Production of Oil and Natural Gas (“REPETRO”), which is one of the main incentives applicable to this industry.
Recently, the European Commission adopted decisions against the cartels in Euro and Yen interest rate derivatives, imposing fines to banks and financial institutions. These fines are the highest imposed by the Commission in cartel cases to the present day. These decisions illustrate the intense and added scrutiny to which the financial sector has been subjected by competition authorities in the EU and elsewhere.
This briefing is the first in a series that will look at legal aspects of the Solvency II regime and their implications for firms. It considers the legal framework of Solvency II, how near each element of the framework is to completion and what needs to happen next, how Omnibus II has changed the previously published regime, the transitional relief that firms can expect to get from 1 January 2016, and how Solvency II will be applied to insurers and reinsurers in the UK.
CRA narrowly interprets foreign affiliate income recharacterization rule. Read this short blurb to find out more.
As a general rule, no minimum corporate capital is legally required for a limited liability company. It is usually suggested that the amount of the corporate capital be consistent with the initial operational needs of the company. In the event that a higher amount is needed afterwards, the partners may increase the corporate capital amount at any time, provided that the initial corporate capital has been fully paid-in. This article discusses liability, obligations, and other legal issues associated with partners’ capital, in accordance with Brazilian laws.
In the recent decision of Nottawasaga Inn. Ltd. v. R. (2014 DTC 1021), the Tax Court of Canada (“TCC”) held that it had no jurisdiction to hear an appeal from a reassessmentof arrears interest where there exists a nil assessment of taxes and the sole basis for the appeal is not the calculation of the interest itself but the computation of the underlying taxable income on which the interest was calculated.
Last year, the Internal Revenue Service published Ordinance 1,793/2013, which lays out new criteria for monitoring high-value corporate taxpayers. The goal is to increase tax compliance and tax revenue. This article views which taxes are covered by the corporate tax monitoring programme.
A review of strategies to reduce social security contribution costs under Brazilian law.