June 2019

On 5 June 2019, the parliament voted at first reading amendments to the Tax and Social Security Procedure Code, as follows:

• the introduction of mandatory transfer pricing documentation requirements; and
• implementation of the EU Tax Dispute Resolution Directive (2017/1852) of 10 October 2017 on tax dispute resolution mechanisms in the European Union.

As regards the introduction of mandatory transfer pricing documentation requirements, the following changes were made to the initial proposal of the Ministry of Finance of 5 November 2018:

• the threshold for preparing mandatory transfer pricing documentation on loan transactions has been lowered to amounts of BGN 1 million (BGN 2 million in the initial proposal) or interest payments exceeding BGN 50,000 (BGN 100,000 suggested initially);
• the thresholds for a number of different transactions (e.g. goods, services, intangibles, loans) will be determined for each controlled transaction; only in specific cases, the transactions will be bundled (the initial proposal suggested that thresholds be calculated for each category of transaction with all related parties); and
• the first period for which transfer pricing documentation must be prepared will be 2020 (the initial proposal suggested that the first period be 2019).

As a next step, the proposal must be voted by parliament at second reading. Further developments will be reported when they occur.

On 5 June 2019, the parliament submitted a proposal for the introduction of new reduced VAT rates, as follows:

• a 9% VAT rate for medicinal products included in the list of medicinal products covered under the National Health Insurance Fund, and for dietary foods for special medical purposes; and
• a 5% VAT rate for meat, milk, eggs, flour and flour-based food products.

Currently, the only reduced VAT rate in Bulgaria is 9%, which applies to accommodation services provided in hotels and similar establishments. In addition, the threshold for general mandatory VAT registration is proposed to be increased from BGN 50,000 to BGN 100,000. The above amendments should apply as from 1 January 2020. As a next step, the proposal will be voted on at two readings by the parliament. Further developments will be reported once they occur.

Report from our correspondent Lubka Tzenova, Lawyer and Professor at Bulgarian University of Finance, Business and Entrepreneurship

On 5 June 2019, the Bulgarian parliament voted at first reading on amendments to the Tax and Social Security Procedure Code that include the following main topics:

• introduction of mandatory transfer pricing documentation requirements; and
• implementation of the EU Tax Dispute Resolution Directive (2017/1852) of 10 October 2017 on tax dispute resolution mechanisms in the European Union.

Tax disputes

Tax disputes will be resolved in accordance with the double taxation treaties to which the Republic of Bulgaria is a party, the EU Arbitration Convention and the new tax dispute resolution procedure. The procedure will be initiated by submitting a complaint to the Minister of Finance who has been designated as the competent authority for the resolution of such disputes in Bulgaria. A specialized department within the Tax Administration's head office will support the Minister of Finance in the decision-making process. Persons not satisfied with the decisions issued by the Minister of Finance may seek remedy with the relevant administrative court.

Transfer pricing documentation

The amendments introduce requirements for drafting special transfer pricing documentation which will consist of a local file and a summary file. The preparation of such documentation will be mandatory for local legal entities, foreign legal entities operating in Bulgaria through their place of business, and sole traders with a significant volume of business. The obligation will be waived for:

• persons whose net sales revenue is below BGN 16 million and whose assets have a balance sheet value of less than BGN 8 million;
• persons not subject to corporate taxation;
• persons subject to alternative taxation; and
• related parties based on 25% shareholding.

The deadline for submission of the documentation to the National Revenues Agency is 31 March of the following year. Failure to comply with this requirement will be subject to fines.

On 14 June 2019, members of parliament submitted a proposal for amendments to the Personal Income Tax Act regarding the tax deduction for dependent (minor) children. Currently, a tax deduction is available for up to three children in which case the annual taxable income of one of the parents is decreased by BGN 200 for one child, by BGN 400 for two children and by BGN 600 for three children. Under the proposal, the annual deduction would be increased to BGN 6,000 per child without the current limitation of up to three children. As a next step, the proposal will be voted on at two readings by the parliament. Further developments will be reported as they occur.

On 19 June 2019, the Italian Council of Ministers approved the China (People's Rep.) - Italy Income Tax Treaty (2019). Further developments will be reported as they occur.

Premier Li Keqiang chaired a State Council executive meeting on May 29, 2019. The meeting decided that China will take more steps to boost community-based elderly care, childcare and domestic services, including greater policy incentives in taxes and fees.   Between June 1, 2019 and the end of 2025, revenue from community-based elderly care, childcare and domestic services will be exempted from the value-added tax, and enjoy a 10-percent deduction in taxable income. Those providing real estate or land for any related services will be exempted from deed tax, property tax, urban land use tax and six types of fees, including registration fee for real estate. The scope of VAT exemption for domestic services companies with contract-based employment will be expanded.

Premier Li Keqiang chaired a State Council executive meeting on June 5, 2019, and decided to adopt more measures to further implement the innovation-driven development strategy and execute favorable tax policies to encourage research & development activities   The meeting decided to adopt more steps to drive business start-ups and innovation to further implement the innovation-driven strategy and energize the vitality of market players. The important role of business start-ups and innovation will be harnessed in supporting employment and promoting technology and innovation. It was also decided at the meeting to build platforms for business start-ups and innovation, and to promote the integrated development of companies in different sizes. The Internet Plus model will be upgraded. Financial institutions will be guided to lower real interest rates and overall cost for loans to micro and small enterprises. A higher ratio of nonperforming loans made to micro and small firms will be allowed. The non-performing loan ratio of such loans will be relaxed to no more than 3 percentage points higher than the overall NPL ratio, from the current 2 percentage points.

Guangdong Department of Finance issued on June 22, 2019 the Circular about Implementing Preferential Individual Income Tax Policies at the Guangdong-Hong Kong-Macau Greater Bay Area. The circular has been effective from January 1, 2019 and might be amended one year later. According to the circular, high-end and badly-needed overseas talents working in the GBA can be eligible to claim fiscal subsidies if their individual income tax rate is more than 15%. The subsidies will be granted by municipal governments of nine GBA cities in the mainland. According to the circular, the fiscal subsidies will cover such forms of income as wages, remuneration for personal services, royalties, business income, as well as allowances for honorary talent programs. The subsidies are designed to encourage foreign professionals to work and create their own businesses in the GBA.

The announcement regulates the type of income which once belonged to “other income” shall now belong to “Contingent income”. The taxable rate is still kept at 20%. Related income includes: 1)         Income from providing guarantees to others; 2)         Income from receiving house donated by others (taxable scope is same as before); 3)         Gifts income from an enterprise to individuals who are non-staff of the enterprise randomly in business promotion, advertising, etc.; 4)         Gifts income from an enterprise to individuals who are non-staff of the enterprise at annual meetings, seminars, celebration events and other activities; However, gifts income from consumer vouchers、cash vouchers、exchange coupon and discount coupon given by enterprises with price discount or concession nature can be exempted from IIT. Furthermore, the announcement also regulates that individual shall pay IIT when he/she begins to get pension income from Individual Tax-deferred Commercial Pension Insurance. The income shall belong to “Income from wages and salaries”, and taxable at 75%*10%=7.5%.  

Ten global companies have signed memoranda of understanding (MoUs) with the Ethiopian Investment Commission (EIC) to set up factories inside the Kilinto Pharmaceutical Industrial Park. With a total size of 337 hectares, the industrial park is nearing completion, said Temesgen Tilahun, Deputy Commissioner of the Ethiopian Investment Commission. Once completed, the Kilinto Pharmaceutical Industrial Park will have the capacity to accommodate more than 1,000 factories, he told FBC today. Located in the south of Addis Ababa, Kilinto is being developed in two phases in collaboration with the World Bank Group.

The Federal Government of Nigeria has revealed plans to invest US $38m in rehabilitation of the Murtala Muhammed International Airport, Lagos terminal. Minister of State for Aviation, Hadii Sirika, disclosed the report at the 2019 Stakeholders’ Forum. The Minister explained that the airport needed a revamp due to its poor state which has outlived its usefulness. He further noted that the terminal was built to handle 300,000 at inception but the passengers it handles have grown to 8 million in the past three years. “We require to spend US $38m as palliative on the refurbishment of the international terminal in Lagos. This airport was built in 1979 and intended to carry just 200,000 passengers annually, but it now does over eight million yearly. With the continuous over-used of its facilities, the amenities will not last for long,” said the minister. Mr. Sirika said that he government would need to close down the terminal, but pointed out this would not happen until the ongoing construction of the second international terminal was concluded. The airport will be featured with modern facility and due to the current number of usage, a permanent plumber will be deplored for the toilet facilities. Ongoing construction of the second international terminal would also be completed before the end of the year. The terminal, which is constructed by the China Civil Engineering Construction Corporation (CCECC), commenced in 2013 with a promise that it would be completed in 20 months. “We want the new terminal to come on stream before we commence any work on the old terminal. As it is, we can’t close it totally because it is the only international terminal we have in the state, but a part of it would be shut once the new terminal come onboard,” assured  Mr. Hadii Sirika.

The Moroccan Agency for Solar Energy has awarded the rights to build the landmark Noor Midelt I solar project, an 800MW hybrid project combining concentrated solar power project with photovoltaic generation, and a minimum of five hours of thermal storage, to a consortium led by French company EDF. The winning consortium – led by EDF through its EDF Renewables subsidiary, and including UAE-based renewable energy company Masdar and Moroccan independent power producer Green of Africa – expects to begin construction of the US$782 million/AU$1.1 billion  hybrid solar project in the last quarter of the year, with power being fed into the grid in 2022. The hybrid nature of the project is intended to increase the plant’s output beyond daylight hours, utilising the dispatchable and competitively-priced electricity from the concentrated solar power (CSP) section of the project, which is expected to provide up to five hours of stored electricity. Consisting of two CSP plants of 190 MW each, and two photovoltaic (PV) plants of around 210 MW each, the project will sell its electricity to the Moroccan Agency for Solar Energy (MASEN) under a 25-year Power Purchase Agreement (PPA). Located 20 kilometres north of the Moroccan town of Midelt, in the country’s centre, the Noor Midelt I project is described by EDF as “a key milestone” in the country’s efforts to generate 52% of its electricity from renewable sources by 2030. “EDF Renewables, Masdar, and Green of Africa would like to thank the Moroccan Agency for Sustainable Energy and the King of Morocco for having designated our consortium as the successful bidder to develop the innovative NoorMidelt I with an installed capacity of 800 MW hybrid concentrated solar power and photovoltaic power plant,” the consortium members said in a press release. “The consortium is fully committed to supporting MASEN and the realization of Morocco’s long-term renewable energy ambitions.” “At Masen, we are quite satisfied with the results of this tender and confident in the capacities of the group selected to carry out this project,” added Mustapha Bakkoury, CEO of MASEN, speaking in a press release translated from French, who went on to describe the project as “technologically disruptive.” According to MASEN, the project was awarded at a per-kilowatt-hour (kWh) price of 0.68 Moroccan dirhams – equivalent to US$0.07/kWh and AU$0.10/kWh. Plans for construction are already well underway and a 40-kilometre road has already been built to support the project. Further, this road will not only service construction and operation of the project but has the added benefit of providing greater access to nearby villages. Similarly, 50 kilometres of medium-voltage power lines have also been completed. All of the work done has been completed by Moroccan companies.

The largest free-trade in the world, spanning the African continent with its 1.2 billion people, has come into effect, aiming to eradicate tariffs and create single market for a potential market worth $2.5 trillion.

The African Continental Free Trade Agreement (AfCFTA) comes into effect on 30 May 2019, having been signed by 52 of the AU's 55-member states. Significantly, Nigeria, the continent's largest economy, has not signed the agreement due to pressure from its  manufacturer and labour industries. Calling it a "historic milestone," African Union (AU) commissioner for trade and industry Albert Muchanga tweetedthat its launch was a "triumph of bold, pragmatic and continent-wide commitment to economic integration". He says the market will formally launch on 7 July 2019 and will "begin the journey of transformation to secure inclusive prosperity". Muchanga and his team were congratulatedby AU Chairperson Moussa Faki Mahamat for "their relentless work to ensure the entry into force of AfCFTA in a record 18 months, ushering in the world 's largest trading market of 1,2 billion people with a combined GDP of $2,5 trillion. Today is a historical win for the #AfricaWeWant." The AU hopes the free-trade zone will bring about economic integration and investment in Africa, from within Africa. By eliminating tariffs, the AU foresees a boost in intra-continental trade by 60% within the first three years – a far cry from the current 16%.

Chinese group Huajian Group signed an agreement with Ethiopian authorities on May 30, 2019, for the management of  Jimma industrial park.

In the framework of that agreement, the Chinese group will invest $100 million in the construction of shoe manufacturing and coffee processing plants.

It will also help attract other Chinese groups in this 75-hectare park. Lelise Neme, managing director of the Ethiopia Industrial Parks Development Corporation, indicated that Jimma park would create 15,000 jobs in the long term.

Built by the China Communications Construction Company, Jimma industrial park was inaugurated in December 2018 by Ethiopian prime minister Abiy Ahmed.

Huajian Group has been operating in Ethiopia since 2011. It already has two shoe manufacturing plants that produce 5 million pairs yearly and employ more than 7,000 people.

Saipem, in Joint Venture with McDermott International and Chiyoda Corporation, has reached agreement with Area 1 Concessionaires on an EPC Contract to engineer and construct an onshore LNG project in Mozambique. Saipem, as involved in the project for a volume currently equal of about 6 billion USD, will operate as leader of CCSJV s.c.a.r.l. (“CCS JV”), the Joint Venture incorporated in Italy to execute the Project. The contract has been executed by Anadarko Moçambique Area 1, Lda., a wholly owned subsidiary of Anadarko Petroleum Corporation, which operates Offshore Area 1 and acts as front-runner of a Venture including other leaders in the energy sector, such as ENH Rovuma Área Um, S.A, Mitsui E&P Mozambique Area1 Ltd., ONGC Videsh Ltd., Beas Rovuma Energy Mozambique Limited, BPRL Ventures Mozambique B.V. and PTTEP Mozambique Area 1 Limited. The LNG project consists of the construction of two Natural Gas Liquefaction (LNG) trains, with a total nameplate capacity of 12.88 million tonnes per annum (MTPA), as well as all necessary associated infrastructure, storage tanks and export jetty facilities. The EPC Contract is subject to a full Notice to Proceed which Anadarko is expected to issue after the Final Investment Decision (“FID”). “After many years of dedication to this project, we are very happy to announce that we have reached full agreement for the contract. We congratulate Anadarko and its co-venturers for the achievement and grateful for the confidence demonstrated toward our CCS JV. We look forward to mobilising our teams to site after Anadarko issues notice to proceed following the Final Investment Decision”, commented Stefano Cao, Saipem’s Chief Executive Officer. “With this project, we will strengthen our presence in East Africa, confirming Saipem’s role among the leaders in the LNG market for the energy transition. A project of such a scale will contribute significantly to the economic growth of Mozambique as a new pole in the west-east energy routes and, as Saipem, we are proud of our substantial contribute to these future developments”. About Saipem Saipem is a leading company in engineering, drilling and construction of major projects in the energy and infrastructure sectors. It is “One-Company” organised in five business divisions (Offshore E&C, Onshore E&C, Offshore Drilling, Onshore Drilling and XSight, dedicated to conceptual design). Saipem is a global solution provider with distinctive skills and competences and high-tech assets, which it uses to identify solutions aimed at satisfying customer requirements. Listed on the Milan Stock Exchange, it is present in over 60 countries worldwide and has 32 thousand employees of 120 different nationalities. About McDermott McDermott (NYSE: MDR) is a premier, fully integrated provider of technology, engineering and construction solutions to the energy industry. For more than a century, customers have trusted McDermott to design and build end-to-end infrastructure and technology solutions to transport and transform oil and gas into the products the world needs today. Our proprietary technologies, integrated expertise and comprehensive solutions deliver certainty, innovation and added value to energy projects around the world. Customers rely on McDermott to deliver certainty to the most complex projects, from concept to commissioning. It is called the “One McDermott Way.” Operating in over 54 countries, McDermott’s locally focused and globally-integrated resources include approximately 32,000 employees, a diversified fleet of specialty marine construction vessels and fabrication facilities around the world. As used in this press release, McDermott includes McDermott International, Inc. and its subsidiaries and affiliates. About Chiyoda Chiyoda Corporation, is a world-leading, fully integrated international engineering company and EPC contractor. Since its founding in 1948, Chiyoda has provided engineering, procurement, construction, operation and maintenance services in a wide range of business fields including oil & gas, chemicals and petrochemicals in over 60 countries around the world.

Okechukwu Nnodim, Abuja The Italian government on Tuesday announced its readiness to invest in Nigeria’s transportation sector. It also said it would concretise the move to bring Italian companies to Nigeria through the public private partnership platform. The Italian Ambassador to Nigeria, Stefano Pontesilli, disclosed this when he led a delegation to the headquarters of the Federal Ministry of Transportation in Abuja. He was quoted in a statement issued by the Head, Press and Public Relations, FMOT, Mohammed Idris, as saying, “It is very important for us to have a high calibre of delegation in order to collaborate with the Nigerian government in the area of transportation.” Pontesilli further stated that the objective of the visit was to collaborate and have good synergy with the Federal Government for  effective and efficient transportation system in Nigeria. The Permanent Secretary, FMOT, Sabiu Zakari, said the government was committed to partnering stakeholders and investors both foreign and local in the transportation sector. Zakari, who was represented by the Director, Maritime Services, Mallam Galadanchi, said that the need to partner stakeholders, especially foreign investors had become necessary in view of the strategic position of the transportation sector in the economic wellbeing of Nigeria. “There is tremendous opportunity in the maritime domain, aviation sector and Nigerian railways, therefore, the need for partnership and collaboration with both foreign and local investors in the transportation industry.” Zakari urged Italian businessmen residing in Nigeria and abroad to utilise the opportunity to invest in Nigeria for the mutual benefit of both countries. He mentioned that the Nigerian Ports Authority had been under concession, adding that the business of the ports had been conducted on private public partnership where NPA served as a regulatory body. The permanent secretary then urged the Italian delegation not to hesitate to request for any information or clearance needed to facilitate the bilateral relationship.

CDC Group, the UK government’s foreign investment arm, has announced it will invest $300 million in power grid development in Africa over the next five years.   This contribution will be made through Gridworks, a company that will be launched shortly to this end. The company will make investments in African transmission networks, but also in the electricity distribution infrastructure.   CDC chief executive Nick O’Donohoe said, Gridworks Company, to be launched soon, will make funding in power transmission and distribution infrastructure, as well as off-grid electricity systems.   Mr O’Donohoe said that despite decades of investment in generating capacity in many African countries, at least 600m people are without access to electricity because of absence of networks to transmit and distribute power. Focused primarily on Africa, Gridworks’ ambition is to invest over $300m of long-term capital in viable projects over the coming years.   A recent McKinsey report estimates that a $345 billion investment in transmission and distribution is required by 2040 to absorb current and planned power generation in Africa. Once generated, electricity still needs to reach its intended users, reliably and safely, and users in turn need to be able to pay for it in a practical and efficient way.   CDC aims to open a regional office for West Africa in Nigeria’s commercial hub of Lagos early next year and establish a presence in Nairobi. It will also expand in Johannesburg and open representative offices in Abidjan and Cairo.

Swedish entrepreneurship hub Norrsken has announced its entry into the Rwandan market, in a move expected to boost the country’s entrepreneurship ambitions. The hub, which houses 340 entrepreneurs and 120 companies in the Swedish capital of Stockholm, will open its first hub in Africa-Kigali, in an announcement, which was made yesterday, by the government and Norrsken. The Kigali hub is Norrsken’s second global hub after its Stockholm hub and is expected to boost Rwanda’s vision to become a regional entrepreneurship and innovation hub. Announcing the entry of Norrsken into Rwanda, the Minister for ICT and Innovation, Paula Ingabire and the Rwanda Development Board (RDB) Chief Investment Officer Guy Baron, welcomed the entry of Norrsken into the Rwandan market, saying that it will go a long way in boosting entrepreneurship and innovation in Rwanda. Norrsken’s influence cuts across all sectors of the economy –from Healthcare, Education, Finance, Food and Agriculture and Environment, with a footprint in Sweden and Britain. “Rwanda to us is the natural gateway to the fast-growing markets and entrepreneurs of East and Central Africa”, said Norrsken CEO Erik Engellau-Nilsso Funda Sezgi, Chief Operations Officer, Norrsken, said that coming to Kigali is part of their 10 year plan where they want to have existence in 25 markets. They chose Rwanda as their second market because of its strategic location. Sezgi said Norrsken chose Kigali as its hub, because of Rwanda’s “strong infrastructure,  great connectivity, high economic growth and ease of doing business.” Sezgi also noted that their target is to attract and integrate ideas, talents and innovations across the region by creating an enabling and favorable environment for the entrepreneurs to development, prototype and scale their solutions. Ingabire welcomed and thanked Norrsken for believing in the country’s vision of establishing its self as both a regional and continental entrepreneurship and innovation hub. “We are grateful for the trust you have showed, and for you being here is a sober remainder that the country is on course of becoming a pan-African entrepreneurship and innovation creating solutions not only for Rwanda but the entire continent”, she said. Baron said that the hub is going to work as a catalyst for the local innovators to scale up their business based on the enabling environment it is going to create. According to Eric Ljunggren, Global Head of Communication and Marketing, Norrsken hub, has acquired Ecole Belge in Kigali where they'll construct the new Norrsken complex. Norrsken was founded by Niklas Adalberth in 2016. Norrsken’s portfolio consists of Swedish and British companies, several of them with operations in Africa. Norrsken aims to scale this with the opening of Norrsken Kigali and invest directly in African companies, it said.

Okechukwu Nnodim, Abuja The European Union on Tuesday announced that it had committed over €156.3m (N53.9bn at N344.88 to one euro) in different financing instruments in Nigeria’s power sector. It, however, regretted that the country’s power sector was losing N1.3bn daily despite efforts by stakeholders to address the challenges in the industry. Speaking at the Second Seminar for the Preparation of Performance Improvement Plans by the Nigerian electricity distribution companies, the Head of Trade and Economic Section of the EU Delegation, Filippo Amato, said the EU had scaled up its financial support for Nigeria’s power sector. He said, “Over the past years, the European Union has considerably scaled up its support to the sector with over €156.3m committed in different financing instruments, ranging from traditional grants to blended finance. We have been able to fund different technical assistance and infrastructural projects cutting across several areas both on and off the grid here in Nigeria.” Amato said the seminar, which held in Abuja, was designed by the French Development Agency and financed by the European Union with €2.3m, adding that it was implemented by the Association of Nigerian Electricity Distributors with the technical assistance of AF Mercados. He said, “You will agree with me that since the first Performance Improvement Plan seminar that was held in March last year, the Nigerian electricity supply industry is still facing deterioration and the liquidity crisis is keeping the system under stress. “Despite efforts made by all of you in tackling some of the key impediments to the development of the sector, the industry losses are still growing at a rate of at least N1.3bn per day and nowadays, the average operational capacity of the grid hovers around 4,500 megawatts and 5,500MW and cannot meet the needs of a growing population and industrial users.” Amato said Nigeria still relied too much on off-grid diesel generators, which unfortunately were not costly but unsustainable from a climate change point of view. According to him, power distributors have, by contract, a key role to play in making the distribution network work efficiently. “This they are supposed to do by reducing their Aggregate Technical, Commercial and Collection losses. By so doing, they will be able to make good use of the available electricity from the grid to serve customers. This is one step in the right direction that Discos must take if we want to come out of this liquidity crisis that is affecting the sector,” the EU official stated. He noted that the second seminar aimed at enhancing Discos’ strategic planning efforts provided modalities for the upcoming Performance Improvement Plan over the next five years.

At least 900,000 households, or 4.2 million people, will be connected to electricity in the next five years if the proposed solar factory begins operations. Dutch solar firm, NOTS, has announced it will invest $70 million (about Rwf61 billion) in the production of solar lighting products in Rwanda, raising the country’s prospects of achieving universal coverage by 2024. The development comes after the Government, early this month, said it had signed an agreement with the firm to manufacture and distribute solar home systems. The New Timeshas established that, under the agreement, NOTS will set up a factory in Rwanda for manufacturing solar home systems while the Government will be obliged to purchase from the firm solar systems for some 100,000 households in the next three years. “There is an arrangement to supply solar systems and we progressively pay them later. This model will help Rwandans get them timely and speed up access to energy compared to covering the cost immediately,” Claver Gatete, the Minister for Infrastructure told The New Times. Solange Mutezintare, NOTS Chief Operating Officer in Rwanda, said that they offer the home solar systems for Rwf52,500 payable in 100 weekly instalments. This is affordable for most Rwandan families, she said, even for households in the first and second Ubudehe categories. With the size of investment, the Government is also keen on supporting the firm to tap into the export market in the region as it increasingly bids to promote its Made-in-Rwanda programme to help bridge the trade deficit. “There are over 20 companies engaged in off-grid energy business, especially solar energy. And, they have been importing the products into the country. So, the aim of the firm is to set up a factory that will be making such products that those who were importing them buy them from Rwanda,” Gatete disclosed. The expected impact At least 900,000 units of home solar systems will be produced for the local market in the next four years, Mutezintare said, adding that extra one million units meant for the export market will be produced every year starting in 2022. Rwanda targets to achieve universal electricity connectivity by 2024. According to Rwanda Energy Group (REG), 51 per cent of Rwandan households are connected to electricity, with 37 per cent connected to the national grid and 14 per cent connected through off-grid systems, mainly solar. Entities whose agricultural, commercial and industrial activities require electricity as a direct input to production of goods or provision of services will be all connected before the end of the year 2022, government says. To achieve this objective, REG says it intends to increase the number of new connections by 500,000 every year, including 200,000 on-grid and 300,000 off-grid. Minister Gatete said that, after making solar systems for homes, the firm will later engage in developing solar products to be used in remote schools and health posts which have no access to electricity.

Morocco is set to commence the construction of the world’s largest sea water desalination plant in 2021, at the Southern Coastal City of Agadir. The US $301m Douira Sea Water Desalination plant is expected to have a treatment capacity of 75 million cubic meters of water per year. Abengoa, a Spanish company has been chosen by the Moroccan National Electricity and Drinking water Office (ONEE) to construct this new desalination plant.

Benefits of the plant

First, it will offer drinking water for the people of Ctouka Ait Baha region. It will also irrigate 15,000 hectares of land since the farmers of this region have also chipped in to finance the construction of the station. It will also promote the desire towards exploring sustainable energy in Africa through operating on wind power. The plant is expected to produce nearly 275,000 cubic meters of desalinated water daily before reaching its maximum capacity of 450,000 cubic meters per day. Abengoa Abengoa is a Spanish company that deals with application of innovative technology solutions for sustainability in the energy and environment sectors. Abengoa has a strategic plan to solve supply projects in parts of the world, mostly those that are affected by water projects. This mostly happens in North Africa. This project is one of Abengoa’s strategic plan. Since 1977 Abengoa has been present in Morocco, having offices in the cities of Rabat and Casablanca. Abengoa has undertaken very important projects in the region, for example the very first Integrated Solar Combined Cycle plant in the world, which is found in Ain Beni Mathar.

On 17 June 2019, HMRC released the outcome of the consultation, Draft legislation detailing a new capital allowance for new non-residential structures and buildings. The accompanying Policy paperwas published on 18 June 2019.

On 23 May 2019, the UAE Cabinet issued Decision No. 33 (the Decision) on Administrative Penalties for Violations relating to Marking Excise Goods. The Decision clarifies Decision No. 42 of 2018 on Marking Tobacco and Tobacco Products and introducing the Digital Tax Stamp (DTS). The DTS scheme requires tobacco and tobacco products importers and UAE based manufacturers to apply control markers (stamps) and codes to all tobacco products. Decision No. 33 sets out a range of violation penalties for non-compliance with the DTS scheme, as follows:

Description of violation	Administrative penalty (AED)
a person possessing or handling designated excise goods that do not carry stamps	- 50,000; and - 50% of the excise tax due on the designated excise goods
a person, knowingly, allowing his premises to be used for the sale of designated excise goods in the UAE that do not carry a stamp	- 25,000 for the first violation; and - 50,000 in case of repetition
a person altering stamps affixed to designated excise goods, or being engaged in overprinting any stamp affixed to designated excise goods	- 50,000; and - 50% of the excise tax due on the designated excise goods
a person failing to report the movement of designated excise goods via the electronic system defined in Cabinet Decision No. 42 of 2018	- 20,000 per incident
a person failing to comply with the requirements to securely store stamps as determined by the Federal Tax Authority	- 50,000 per incident
a person failing to comply with time limits to return unused stamps to the Federal Tax Authority	- 50,000 per incident
a person failing to affix stamps to designated excise goods in the manner and location specified by the Federal Tax Authority	- 25,000 for the first violation; and - 50,000 in case of repetition
a person conducting unauthorized trading, swapping, selling or otherwise supplying of stamps	- 25,000 for the first violation; - 50,000 in case of repetition
a person re-using stamps which have previously been used on a designated excise good	- 50,000; and - 50% of the excise tax due on the designated excise goods

As from 1 May 2019, tobacco products without the required DTS will not be permitted for importation into the UAE. And, as from 1 August 2019, tobacco products will not be allowed to be held out for sale, imported or produced in the UAE unless they carry the required DTS.

According to a press release of 26 June 2019, published by the US Senate Committee on Foreign Relations, on 25 June 2019 the US Senate Committee on Foreign Relations approved the amending protocol, signed on 23 September 2009, to the Switzerland - United States Income Tax Treaty (1996). The protocol will amend the existing 1996 treaty, if and when ratified by the full US Senate. Further developments will be reported as they occur.

According to a press release of 26 June 2019, published by the US Senate Committee on Foreign Relations, on 25 June 2019 the US Senate Committee on Foreign Relations approved the amending protocol, signed on 23 September 2009, to the Switzerland - United States Income Tax Treaty (1996). The protocol will amend the existing 1996 treaty, if and when ratified by the full US Senate. Further developments will be reported as they occur.

The Congressional Research Service (CRS) of the US Library of Congress has released a report entitled "Enforcing US Trade Laws: Section 301 and China". The CRS report indicates an updated date of 4 June 2019 and is designated IF10708 (Version 48). Due to its concerns over China's policies on intellectual property (IP), technology and innovation, the United States has implemented three rounds of tariff increases on a total of USD 250 billion worth of Chinese products under sections 301 through 310 of the Trade Act of 1974, as amended, which are commonly referred to as section 301. China has increased tariffs on USD 110 billion worth of US products. The CRS report states that a protracted and expanding US-China trade conflict could sharply reduce bilateral commercial ties, disrupt international supply chains, diminish global economic growth, and be costly to US consumers and firms that depend on trade with China. The CRS report also states that China could further retaliate by curbing operations of US-invested firms in China, reducing its holdings of US Treasury securities, and curtailing rare earth material exports to the United States. The CRS previously issued a related report entitled "China's Retaliatory Tariffs on US Agricultural Products" (IF11085, 29 January 2019). The CRS is an agency within the US Library of Congress and serves the US Congress throughout the legislative process by providing legislative research and analysis for an informed national legislature.

The US Treasury Department and the US Internal Revenue Service (IRS) have issued the third quarter update to their Priority Guidance Plan for 2018-2019. The third quarter update indicates an updated date of 31 March 2019, and a release date of 17 June 2019. The third quarter update to the Priority Guidance Plan for 2018-2019 reflects additional projects which have been published (or released) during the period from 1 January 2019 through 31 March 2019.

On 20 June 2019, the National Taxpayer Advocate (NTA) released the FY 2020 Objectives Report To Congress. The US Internal Revenue Service (IRS) issued a News Release (IR-2019-119) on the same day to announce the issuance of the Report. The Report provides an assessment of the key challenges facing the IRS and the Taxpayer Advocate Service (TAS) in the coming years. The Report also presents a review of the 2019 filling season. Further, the Report identifies and discusses 12 priority issues that the TAS plans to focus on during the fiscal year 2020. The TAS is an independent organization within the IRS whose mission is to help taxpayers resolve tax problems with the IRS and recommend changes that will prevent problems. The TAS is under the supervision and direction of the NTA.

A tax treaty is a bilateral agreement made by two countries to resolve issues involving double taxation of passive and active income. Treaties Update – June 2019  

Date	Country A	Country B	Object	Status
19.06.19	China	Italy	Income Tax Treaty	Approved by Italian Council of Ministers
26.06.19	Cambodia	Hong Kong	Income Tax Treaty	Signed