November 2019

  • China
    • China Exempts Some Taxpayers’ Obligation to Declare Settlement and Payment of Individual Income Tax

      Premier Li Keqiang chaired a State Council executive meeting on November 20, 2019 to hear a report about the reform on individual income tax, introduce preferential tax measures to reduce taxpayers' burden, and passed the Law of the People's Republic of China on Urban Maintenance and Construction Tax (Draft). The meeting decided to further lower the tax burden on low- and medium-income groups. It passed a temporary decision to exempt those whose aggregate annual income is no higher than 120,000 yuan within a period of two years from the obligation to declare the settlement and payment of individual income taxes. In order to promote development of the shipping industry and meet the rapidly growing demand for seafood in the domestic market, the meeting decided that taxable income will be reduced by 50 percent for seamen who are at sea more than 183 days a year, from January 2019 through the end of 2023.
    • SAT Clarifies Management of Abnormal Value-added Tax Payment Receipts

      The State Administration of Taxation recently released the Announcement on Issues Concerning the Management of Abnormal Value-added Tax Payment Receipts, to be effective from February 1, 2020.   According to the announcement, there are six circumstances of abnormal value-added tax payment receipts, including the missing of the taxpayer, tax devices are stolen and invoices have not been issued or have been issued but not uploaded, and inconsistency between what's written on the invoices and what is indicated on the invoice management system.
    • New Rules on Collection of Income Tax from Cross-border E-commerce Exporters Released

      The State Taxation Administration recently released the Announcement on Issues Concerning the Verification and Collection of the Income Tax from Retail Exporters in the Cross-border E-commerce Comprehensive Pilot Zones, to be effective from January 1, 2020.   Cross-border e-commerce enterprises verified for collection of corporate income tax in comprehensive pilot zones shall accurately calculate the total income, and the corporate income tax will be determined by the unified taxable income rate of 4%. Where the enterprises meet the preferential policy conditions for small low-profit companies, they can enjoy the preferential income tax policy applicable to them; where their income belongs to the tax-free income as stipulated in Article 26 of the PRC Corporate Income Tax Law, they can enjoy the tax-free policy.
    • State Council Unveils 20 Measures to Further Utilize Foreign Investment

      The State Council released the Opinions on Further Improving the Utilization of Foreign Investment on November 7, 2019. The document put forward 20 policy measures in four aspects of deepening market openness to foreign investors, promoting investment, deepening reform to facilitate investment, and protecting the legitimate rights and interests of foreign investors. China will move faster to further open up the financial industry, eliminate all restrictions on the scope of business for foreign banks, securities companies and fund management companies, and remove requirements on total assets for the establishment of foreign-funded banks. In deepening reform to facilitate investment, China will lower the cost of cross-border capital use, make it easier for foreigners to work in China and optimize the approval process for the use of land for foreign-funded projects.
  • Hong Kong
  • South Africa
    • Cabo Delgado ‘gas city’ presented in Maputo will cost at least €1.5 billion

      The city being built near the natural gas projects in Cabo Delgado in the north of Mozambique will cost at least €1.5 billion and have 150,000 inhabitants, the entity in charge of the project said yesterday. The estimated 150,000 residents of the city include the 15,000 people currently living on the Afungi peninsula in Cabo Delgado, Lorenzo Monti, a representative of Italian company Renco Energy and project director of the future ‘gas city’ says. The city master plan commissioned by the National Hydrocarbon Company (ENH), the state partner in the megaprojects, was presented at the 6th Mozambique Gas Summit in Maputo yesterday. The plan foresees 1,200 hectares (ha) of residential areas, a 3,800 ha industrial area, 2,300 ha for agriculture, 8,000 ha for green areas and 214 ha for tourist infrastructure, making 15,500 hectares in total. The city will be sited close to the natural gas liquefaction units driving the development of the entire zone and based on investments worth around US$50 billion (€45.4 billion) by oil companies Total, Exxon Mobil. and Eni, and which should place Mozambique among the world’s leading producers of liquefied natural gas (LNG). Construction work is expected to start before gas extraction and liquefaction begin in 2025 and to progress gradually through to 2050, Monti said. The city will have 50 to 60 kilometres of electricity distribution network and 300 to 400 kilometres of water mains, along with a purification plant and pumping station. The water infrastructure will have the capacity to supply 25,000 to 30,000 cubic meters per day. The construction of a wastewater collection network and a solid waste separation, recycling and recovery facility is also planned. Public buildings housing health, education, security and other services, as well as dozens of kilometres of road network, complete the project. The industrial zone will be divided into four areas: one for the operation of a power plant, another for a petrochemical plant that will produce fuel, one for fertilisers and one for suppliers’ warehouses. The Gas City Master Plan also foresees a 214 ha tourist area, with a maximum capacity of 15 hotel units and 500 square metres of apartments. “The Gas City Master Plan is guided by five values: economic and social development; attraction of national and international investors; respect for the environment, nature and communities; development of infrastructure, industries and tertiary activities; and the establishment of a model of sustainable development,” the project director said.
    • Nigeria’s sovereign fund seeks co-investors for gas industrialisation projects

      Nigeria Sovereign Investment Authority (NSIA), the sovereign wealth fund of Africa's largest economy, is looking for co-investors to develop two gas industrialisation projects worth more than $1 billion (Dh3.67bn), as it continues to broaden its portfolio of investments. NSIA plans to develop a basic chemicals platform with a project value in excess of $1bn that will produce ammonia and fertilisers in Nigeria. The second one, a project to convert flare gas into LPG, could cost more than $100 million, Uche Orji, the chief executive of NSIA, who is in Abu Dhabi attending a two-day Africa Investment Summit hosted by the Abu Dhabi Investment Authority, told The National. “We will be looking hopefully to develop [the projects] with sovereign wealth funds and other co-investors,” he said. The talks are at early stages, he said and did not name any potential partners. Nigeria, Opec’s biggest crude producer in Africa, relies heavily on the oil and gas sector, which accounts for about 20 per cent of its gross domestic product, and 85 per cent of total exports, according to Opec data. The country expects investments worth $48bn between 2018 and 2025 in the sector, Maikanti Baru, former managing director of Nigerian National Petroleum Corporation (NNPC) said in July. Mele Kyari, who has replaced Mr Baru as the head of NNPC, said that state-owned energy companies Saudi Aramco and Abu Dhabi National Oil Company are also considering investing in Nigeria's energy sector. “We are open to all partners, all like-minded partners. We have no restrictions, we have ongoing discussions with so many people,” Mr Orji said of the potential deals with long-term investors across sectors of Nigerian economy. “We have health care, we have infrastructure [projects], it really depends on what the interest of our partners is.” Additional equity from the government, Mr Orji said, will help NSIA to broaden its investment base. The fund's current focus remains on achieving growth through joint investments. “I’m expecting more from the government but a lot of it would depend on the oil price movement,” he said. “We are very hopeful that we will get some funds,” he said. The current price level of $62 per barrel for Brent crude is still above “our benchmark rate”, which is $57 per barrel, he saoi. NSIA invests through its three main funds: the Stabilisation Fund, Future Generations Fund and Nigeria Infrastructure Fund, which account for 20, 30 and 50 per cent of its investments, respectively. NSIA not only manages its own funds, but it also those on behalf of the Nigerian government and its total assets under management are between $2.5bn to $3bn. Over the years, NSIA has increased its focus on domestic infrastructure projects and it is investing in three major transport infrastructure schemes – the Abuja-Kano highway, Second Niger bridge and the Lagos-Ibadan road projects. “These projects are quite significant altogether. When they are done, they would be around roughly $2bn [in value]”, he said. The projects are being financed through the funds provided by the government and NSIA’s own equity and it will look to raise $500m in external funding from the market next year, Mr Orji said. “We are appointing advisers next year to commence the capital raising process,” he said without specifying the timing of the deal. Development of power, agriculture and the healthcare sectors is among the top priorities for NSIA, and the authority is looking to join hands with sovereign wealth funds from the Middle East and beyond for co-investments in these sectors. “Less than 20 per cent of the Nigeria’s arable land is cultivated for agriculture so that’s an opportunity right there. We are talking about a large quantum of land here,” he said. Within the healthcare sector, it has already finished two projects this year and is on track to finish another in the first quarter of 2020. The country is looking to launch another two next year out of the active pipeline of 12 projects, he said
    • Ethiopia secures US$451m in funding to help farmers adopt to climate change

      ETHIOPIA – International Fund for Agricultural Development (IFAD) and Ethiopia have signed an agreement to fund the Lowlands Livelihood Resilience Project by injecting US$451m funded through a combination of debt and grant. The financing agreement was signed by Gilbert F. Houngbo, President of the International Fund for Agricultural Development, and Zenebu Tadesse Woldetsadik, Ambassador, Permanent Representative of the Federal Democratic Republic of Ethiopia to the United Nations Food and Agriculture Agencies in Rome. The funding includes a US$90 million loan from IFAD and $350 million in co-financing from the International Development Association (80 per cent loan and 20 per cent grant) and $11million from the beneficiaries themselves. The Lowlands Livelihood Resilience Project is aimed to increase resilience to climate shocks in the communities at the lowland areas of Ethiopia who are dependant on rain fed agriculture and pastoralism thus highly vulnerable to droughts, desertification and floods. The project is primarily designed to help achieve Sustainable Development Goals 1 and 2 (eradicating poverty and hunger) will install small-scale irrigation technology to reduce dependence on erratic rains. It will also help smallholder farmers to invest in research systems for faster adaptation to climate change and develop an innovative value chain approach to leverage private investment, productivity and win-win commercial linkages between local businesses. It also aims to improve nutrition by providing education on food handling and food preservation and the production of more nutritious and diverse crops with access to bio-fortified seeds and technical assistance, including on post-harvest handling. By strengthening rangeland and natural resources management, and improve the delivery of basic social services the project will also help mitigate conflicts over scarce resources in fragile pastoral and agro-pastoral ecosystems. The project is set to cover the pastoral and agro-pastoral areas in the Afar, Benishangul-Gumuz, Gambela, Oromia, Somali and Southern Nations, Nationalities and Peoples’ regions, reports APO-Group. Since 1980, IFAD has invested $755.5 million in 19 rural development programmes and projects worth US$ 1.8 billion in Ethiopia. These have directly benefited around 11.5 million rural households.
    • Johnson & Johnson raises investments in Egypt to LE 2.3B

      Johnson & Johnson International Pharmaceutical Industries injected LE 125 million in new investments in Egypt during 2019 to increase its investments to LE 2.3 billion, Minister of Trade and Industry Amr Nassar said Tuesday. Nassar said this step reflects the international business circles and multinational companies' interest to work in the Egyptian market as one of the most important markets in the Middle East and Africa. He expressed the ministry’s keenness to promote the pharmaceutical industry as one of the strategic industries in the national economy in order to meet the needs of the local market and export to regional and international markets, according to Minister Nassar. Nassar added in a statement that the Egyptian pharmaceutical products enjoy high quality and great competitiveness in the African market. This came during a meeting with Ziger Verkotern, vice president of Johnson & Johnson International Pharmaceutical Industries for Europe, Middle East and Africa and Ahmed Khalil, director of Government Affairs and Policy for North Africa. Nassar referred to the great investment opportunities in the Egyptian market in the field of producing medicine and health care products, which can be exported to the markets of neighboring countries and the African continent. The minister pointed out the possibility of establishing projects for Johnson & Johnson International in cooperation with the Egyptian pharmaceutical sector in the African continent in light of the ministry's keenness to launch industries in a number of East and West African countries with Egyptian expertise and inputs. According to the minister, Egypt's advantageous position can enable the company to access regional and international markets. The company can also exploit Egyptian ports on the Red Sea and the Mediterranean to reach countries of East Africa, Southeast Asia and Europe. He stressed that Egypt has a huge industrial base in the pharmaceutical sector that qualifies it to lead the pharmaceutical industry in the region.
    • UAE and Egypt launch $20bn joint investment platform

      The UAE and Egypt will establish a $20 billion (Dh73bn) investment fund, Sheikh Mohamed bin Zayed announced on Thursday. The Crown Prince of Abu Dhabi and Deputy Supreme Commander of the UAE Armed Forces launched the fund, along with Egyptian president Abdel Fattah El Sisi, during Mr El Sisi's two-day visit to the Emirates. The joint investment fund will implement social and economic projects for both countries. "Together with my brother, President Abdel Fattah El Sisi we launched a joint strategic investment platform between the UAE and Egypt worth $20 billion to implement vital economic and social projects for our brotherly countries," Sheikh Mohamed bin Zayed said on Twitter The Crown Prince also bestowed the Order of Zayed, the UAE's highest civilian honour, on Mr El Sisi at Qasr Al Watan. The Egyptian president now joins other global leaders such as Russia's Vladimir Putin and China's Xi Jinping in having been afforded this honour. Other deals struck between both countries included measures to prevent tax evasion, insurance issues and employment. It was a day of pomp and ceremony in Abu Dhabi. Mr El Sisi arrived at the palace just after midday, flanked by a guard of honour as the Al Fursan aerobatic team soared overhead. Egyptian and UAE flags fluttered in the breeze. It was Mr El Sisi’s second visit in less than two years and underlines the strong relationship between the two countries. Sheikh Mohamed welcomed Mr El Sisi to his “second home”. "The relations between the UAE and Egypt are historical and strategic and are based on trust and understanding,” said Sheikh Mohamed, noting that the late President Sheikh Zayed considered Egypt as the heart of the Arab region. "Egypt's security is as important as the UAE's security, and its progress, development and stability are important to the UAE and all Arab countries. Confronting the challenges and risks facing the Arab region requires intensifying the ongoing consultations between our countries and joint Arab action," he said.   Mr El Sisi was accompanied by a high-level delegation including Minister of Foreign Affairs, Sameh Shoukry, Maj Gen Abbas Kamel, chief of the Egyptian General Intelligence; and Sharif Al Badawi, Egyptian Ambassador to UAE. Ties between both countries are deep and historic. Sheikh Zayed met then Egyptian leader Anwar Sadat in Cairo in 1970, and again in 1971 when the UAE was established. Sheikh Zayed supported Egypt in the 1967 war with Israel and in 1973. Formal support from the Abu Dhabi Fund for Development began in 1974 and by 2009 Cairo had ranked the UAE as the leading foreign government investing in Egypt. About 10 years later, the UAE and Egypt established a strategic partnership to boost the performance of the Egyptian administration. Since Hosni Mubarak stepped down amid huge protests in 2011 to Mr El Sisi taking power in 2014, the UAE has consistently supported Egypt. Mr Al Badawi praised the UAE for standing by Egypt during the past few years. As many as 400,000 Egyptians live in the UAE, with many playing a key role in helping to build the country. Egyptian City planner Dr Abdulrahman Maklouf, for example, helped to draw up an early master plan for Abu Dhabi. Since those days, countless Egyptians have lived and worked in the UAE in sectors such as education, engineering and hospitality. Both leaders also discussed the regional situation. Sheikh Mohamed said the two countries are fighting against extremism, terrorism and attempts to threaten peace and security. "Egypt is a key country in the Arab region and is one of the cornerstones of Arab security," said Sheikh Mohamed. Mr El Sisi, meanwhile, expressed his happiness at visiting the UAE and stressed that a special relationship existed between the UAE and Egypt. He left the UAE on Thursday evening.
    • Gov’t secures $250m to establish National Development Bank in 2020

      Government has secured $250 million from the World Bank as initial capitalization to kick-start the operations of the National Development Bank (NDB) in 2020. Presenting the 2020 Budget in parliament, Finance Minister Ken Ofori-Atta said, “In view of the high level of interest generated, other Donors such as DFID, KFW, AfDB are expected to provide additional capitalization for the Bank once it becomes operational in 2020.” According to Mr Ofori-Atta, the government has completed a feasibility study for the establishment of National Development Bank envisioned to refinance credit to industry and agriculture as a wholesale bank; and also provide guarantee instruments to encourage universal banks to lend to these specific sectors of the economy. He said, “The National Development Bank (NDB) will be an independent institution with a strong corporate governance framework, and would be globally rated to enable it to leverage foreign private capital for industrial and agriculture development in the country.” According to Mr Ofori-Atta, “It is expected that the National Development Bank will provide cheaper and long term funding for the growth and expansion of key companies operating in the agriculture and industry sectors.” He said the development bank will also lend through specialized banks to key anchor industries at the Metropolitan, Metropolis and District Assemblies level to support the governments IDIF initiative. Mr Ofori-Atta in the 2019 Budget announced that they have made some progress in establishing the National Development Bank, which is expected to focus on industry and agriculture.
    • Dubai’s DP World signs deal to develop business park in Namibia

      Dubai’s DP World has signed a preliminary agreement with the Nara Namib Free Economic Industrial Zone to develop a dedicated business park in the Namibian port town of Walvis Bay. The park will be a ‘free economic zone’ for industry and logistics and initially cover an area of 50 hectares, according to a statement on Dubai’s government media office website on Tuesday. The park could eventually be spread across 1,500 hectares, it said. A free economic zone is often a dedicated area that has different laws or rules, such as fewer or no taxes, designed to attract investment. DP World and Nara Namib aim to reach a final agreement in the second quarter of 2020, the statement said.
    • US $2bn to be invested in construction of biomass power plants in Egypt

      US $2bn is set to be invested in construction of biomass power plants in Egypt. The government made the announcement and said that each of the governorates that will house a power plant will have to buy back US $6.65 per kWh and the remaining US $2.23 will be paid by the environmental agencies under the jurisdiction of the Ministry of Environment. The land that will house the plant will be offered by the host governorate under a usufruct regime ( The right granted to an entity to use property and enjoy the income it provides, without being the owner). In addition, each governorate that will house a factory will have to provide the waste necessary for its operation free of charge. These infrastructures upon completion will make it possible to transform 600 tonnes of waste into energy every day. The repurchase price per kWh of the energy to be produced is estimated at US $8 over a 45-year period, part of which will therefore be subsidised by the State. A number of both local and foreign investors have submitted their applications towards the development. Among them, the Egyptian Company for Solid Waste Recycling, Empower Energy, Global Knowledge Company (GKC), China Power International Development, Shanghai Electric.
      Energy mix and trend in Egypt

      The current energy mix and trend in Egypt is similar to that of other emerging economies, where the share of renewable energy in power generation is declining despite the increase in renewable energy diffusion and investments overtime, due to higher growth in overall energy demand.

      Current power generation in Egypt is dominated by natural gas, which contributes more than three quarters of total generation. The power sector consumes more than 50% of all natural gas, with the share of renewable energy declining from 13% in 2010 to 10% in 2014.
    • IVORY COAST: Joint agreement between IFC and government for 2 solar power plants

      An agreement was recently signed between the government of Ivory Coast and the International Finance Corporation (IFC), a subsidiary of the World Bank in charge of private sector financing. It concerns the implementation of two solar photovoltaic projects.

      Two solar photovoltaic power plants will soon be built in Ivory Coast. They will be located near the cities of Touba in the northwest and Laboa in the northeast of the country. These two projects were at the heart of a dialogue that culminated in an agreement between Prime Minister Amadou Gon Coulibaly of Ivory Coast and the heads of the International Finance Corporation (IFC), the World Bank’s private sector financing subsidiary. The agreement was signed on the margins of the recent Annual Meetings of the World Bank and the International Monetary Fund (IMF) in Washington, D.C., USA. “The agreement covers IFC’s assistance with the feasibility study, financing and advisory assistance. The two plants will have a capacity of 30 MWp each. Discussions with the IFC also focused on developing a strategy for targeted intervention for a more competitive private sector in the coming years…”, says the Prime Minister of Ivory Coast. No further details have been provided so far on the Touba and Laboa solar projects. However, the IFC’s request suggests that they will be developed by independent power producers (IPPs) as part of public-private partnerships (PPPs). The construction of these power plants will enable the country to integrate solar energy into its electricity mix. Several solar projects are currently under development in this West African country. One example is the Boundiali solar photovoltaic power plant in northern Ivory Coast. It will have a capacity of 37.5 MWp. The construction of this power plant will require an investment of 40 million euros. The government will finance the implementation of the project with loans from partners such as the European Union and the Kreditanstalt für Wiederaufbau (KfW), the German development agency.
    • Dangote Industries to spend $2bn on Togo phosphate project

      Accra — Dangote Industries will invest in a $2bn (R29.5bn) phosphate project in Togo, positioning itself to become a main supplier of fertiliser in West Africa. The company controlled by Nigerian billionaire Aliko Dangote will mine an estimated two-billion tonnes of phosphate in nearby Togo for processing as much as one-million tonnes of fertiliser a year at a new complex in Lagos, according to a joint statement by the company and the Togolese presidency. “Under the agreement, Togo will provide access to phosphate resources and the Dangote Group will provide access to ammonia and to the Nigerian market,” the parties said in the statement. Ammonia is a key ingredient in the production of phosphate fertiliser. Nigeria accounts for as much as 50% of harvested land in West Africa, making it a top market for fertiliser consumption growth, according to London-based commodities consultancy CRU.
    • Visa to snap up stake in African fintech unicorn Interswitch

      Visa is to spend hundreds of millions of dollars to acquire a stake in Interswitch, an African payments group, in a deal that will see it becoming the continent's latest technology 'unicorn'. Sky News has learnt that Visa and Interswitch are in advanced talks about a transaction that could be announced as soon as this week.
      Sources said on Sunday that the US-based multinational would invest $200m in Interswitch in return for a 20% stake. The deal will see Visa becoming a cornerstone investor in the Nigerian-headquartered company ahead of a prospective initial public offering in London during the first half of 2020. Interswitch is one of the largest Africa-focused electronic payments and infrastructure companies, with point-of-sale terminals, online consumer payment platforms and its own card, Verve. The latter is the biggest domestic debit card scheme in Africa, with more than 19 million cards active on its network. An investment by Visa will facilitate the formation of a strategic partnership to target the fast-growing African digital payment market. It will come months after its global rival, Mastercard, invested $300m in Dubai-based Network International ahead of its stock market debut in London. Network International, which is the largest payment processor in Africa and the Middle East, has since seen its shares perform strongly, bucking the trend of a stagnant environment for London IPOs. The rush to build stakes in African businesses by Visa and Mastercard is being driven by a desire to take advantage of established platforms in markets that are both fast-growing and under-penetrated. Unlike many fintech groups, Interswitch is both profitable and generating significant levels of cash. The two dozen countries it serves include some of the most populous in the world, including Nigeria, which is home to nearly 200 million people. Founded in 2002 by Mitchell Elegbe, an entrepreneur, Interswitch appointed Sir Kenneth Olisa, a prominent corporate governance stalwart, as its chairman in 2017. Sir Kenneth, a former deputy chair of the Institute of Directors, once memorably described the Kazakh mining company ENRC - on whose board he had served as "more Soviet than City". An eventual IPO for Interswitch would allow the company's majority shareholder, Helios Investment Partners, to begin selling down its stake if it chooses to do so. Helios has already floated a separate namesake business, Helios Towers, in London in recent weeks. JP Morgan is leading the syndicate of investment bankers which have been hired to work on Interswitch's eventual flotation. A previous plan to take Interswitch public stalled in 2016 amid a contraction in Nigeria's economy. Interswitch declined to comment, while Visa could not be reached for comment.
    • MTN South Africa launches 5G trial with Huawei

      Jackson Zhu, Huawei-MTN SA Key Account Director and Giovanni Chiarelli, MTN CTIO signing a 5G MOU.

      C-band, the so-called ‘golden band’ for 5G spectrum, is said to be a valuable slice of spectrum and comprises of a frequency range of around 3.3 – 3.8GHz. Many countries around the world are deploying this spectrum band to deliver their 5G services.
      MTN and Huawei signed a memorandum of understanding to establish a Joint 5G Innovation Program to assess and work on new technologies such as 5G and Artificial Intelligence (AI). Through these innovations, MTN SA hopes to develop use cases that have a social impact, including smart city and education driven by 5G and AI technologies. The launch demonstrated use cases including a live 5G speed test (with throughputs up to 1.6Gbit/s) and a series of live 5G demonstrations, such as Cloud VR gaming, a robotic arm guessing platform,  and augmented reality (AR) eyeglasses. “MTN is very pleased to launch the 5G C-band trial in South Africa,” says MTN CTIO, Giovanni Chiarelli. “This trial demonstrates the capability of this new technology while giving customers a glimpse of what the future holds, showcasing the next generation of applications for consumer and enterprise customers. MTN will further co-operate with Huawei to accelerate commercial 5G deployment.” Dean Yu, Huawei Carrier Business VP for Southern Africa, says, “5G is at the stage of large-scale deployment in 2019 globally. In 5G era, more “Cloud Native” services will appear. With the redefinition of the smart clients, broad pipes, and Cloud applications, devices can be significantly simplified and more capabilities can be mapped from clouds to devices. Huawei will keep supporting  MTN through its challenges and requirements, providing the most innovative product and solution for MTN, bringing the ultimate experience to MTN subscribers.”
  • Switzerland
  • United Arab Emirates
    • IMF releases Concluding Statement of 2019 Article IV Consultation with United Arab Emirates

      On 6 November 2019, the International Monetary Fund (IMF) released the Concluding Statement of the 2019 Article IV Consultation with the United Arab Emirates (UAE). The IMF makes the following tax policy recommendations:
      • strengthening transparent and rules-based fiscal frameworks to ensure sufficient saving of oil wealth for future generations and smoothing of short-term fluctuations; and
      • promoting the growth of the non-oil private sector, including small and medium-sized enterprises (SMEs).
      Note: Under Article IV of the IMF's Articles of Agreement, the IMF holds bilateral discussions with members, usually every year. The IMF is also allowed to monitor the exchange rate, monetary and fiscal policies, structural policies, and financial and banking policies of every member country. Based on these discussions and research, the IMF prepares a report, which is discussed and assessed by its Executive Board.
    • Cabinet resolution determining regulatory authorities concerned with business referred to in economic substance regulations – published

      On 25 November 2019, the Ministry of Finance published Cabinet Resolution 58 of 2019 defining the regulatory authorities for each type of relevant activity carried on and subject to the obligations provided by Cabinet Resolution No 31 of 2019 on the economic substance regulations (see also United Arab Emirates-1, News 19 September 2019). The regulatory authorities for each type of activity are set out below.
      • For banking business, the regulatory authority is:
        • the UAE Central Bank for banking business regulated by the Central Bank; and
        • the competent authority in the Financial Free Zone for banking business carried out therein.
      • For insurance business, the regulatory authority is:
        • the Insurance Authority for insurance business regulated by the Insurance Authority; or
        • the competent authority in the Free Zone for banking business carried out therein; and
        • the competent authority in the Financial Free Zone for insurance business carried out therein.
      • For investment fund management business, the regulatory authority is:
        • the Securities and Commodities Authority for investment fund management businesses regulated by the said authority;
        • the competent authority in the Free Zone for fund management business carried out therein; and
        • the competent authority in the Financial Free Zone for fund management business carried out therein.
      • For lease finance business, the regulatory authority is:
        • the UAE Central Bank for lease finance business regulated by the Central Bank;
        • the competent authority in the Free Zone for lease finance business carried out therein; and
        • the competent authority in the Financial Free Zone for lease finance business carried out therein.
      • For headquarter business, the regulatory authority is:
        • the Ministry of Economy for headquarter business regulated by the said Ministry;
        • the competent authority in the Free Zone for headquarter business carried out therein; and
        • the competent authority in the Financial Free Zone for headquarter business carried out therein.
      • For shipping business, the regulatory authority is:
        • the Ministry of Economy for shipping business regulated by the said Ministry;
        • the competent authority in the Free Zone for shipping business carried out therein; and
        • the competent authority in the Financial Free Zone for shipping business carried out therein.
      • For holding company business, the regulatory authority is:
        • the Ministry of Economy for holding company business regulated by the said Ministry;
        • the competent authority in the Free Zone for holding company business carried out therein; and
        • the competent authority in the Financial Free Zone for holding company business carried out therein.
      • For intellectual property business, the regulatory authority is:
        • the Ministry of Economy for intellectual property business regulated by the said Ministry;
        • the competent authority in the Free Zone for intellectual property business carried out therein; and
        • the competent authority in the Financial Free Zone for intellectual property business carried out therein.
      • For distribution and service centre business, the regulatory authority is:
        • the Ministry of Economy for distribution and service centre business regulated by the said Ministry;
        • the competent authority in the Free Zone for distribution and service centre business carried out therein; and
        • the competent authority in the Financial Free Zone for distribution and service centre business carried out therein.
  • United Kingdom
    • Budget 2018 – Finance Act 2019: Offshore Receipts in respect of Intangible Property: The Income Tax (Trading and Other Income) Act 2005 (Amendments to Chapter 2A of Part 5) Regulations 2019 made (S.I. 2019/1452)

      The Income Tax (Trading and Other Income) Act 2005 (Amendments to Chapter 2A of Part 5) Regulations 2019 (S.I. 2019/1452) were made on 4 November 2019. The Regulations amend existing legislation "Offshore Receipts in respect of Intangible Property" that taxes income arising from brands, patents and copyrights received by persons resident in low tax jurisdictions where the income is referable to the sale of goods or services in the United Kingdom. The main amendments of the Regulations are:
      • the introduction of modifications to the definition of UK sales and residence;
      • the creation of an exception for sales made by third parties where the intangibles make an insignificant contribution to the UK sales;
      • the creation of exemptions for: (i) companies resident in certain jurisdictions with which the United Kingdom does not have a double taxation agreement; (ii) tax transparent entities resident in a low tax jurisdiction and 100% held by residents in that jurisdiction; and
      • the introduction of a provision to avoid double taxation when the same income is taxed twice in respect of related entities.
      The Regulations came into force on 5 November 2019.
  • United States
    • IRS announces 2020 cost-of-living adjustments for pension plans

      On 6 November 2019, the US Internal Revenue Service (IRS) issued Notice 2019-59 with cost-of-living adjustments for pension plans and other retirement-related items under the US Internal Revenue Code (IRC) for the tax year 2020. The IRS also issued a related News Release (IR-2019-179) dated 6 November 2019. The 2020 cost-of-living adjustments affect various US pension plans, including section 401(k) plans, individual retirement arrangements (IRAs), simplified employee pensions (SEPs), and SIMPLE retirement accounts.
    • IRS announces inflation adjustments for 2020 – Part I

      On 6 November 2019, the US Internal Revenue Service (IRS) issued Revenue Procedure 2019-44 with inflation adjustments to tax allowances and other items for 2020. The IRS also issued a related News Release (IR-2019-180) dated 6 November 2019. The IRS will make these adjustments with effect from 1 January 2020. These adjustments are required to be made each year by the applicable provisions of the US Internal Revenue Code (IRC). The main adjustments announced by the IRS in Revenue Procedure 2019-44 are set forth below.

      Personal income tax rates and brackets

      The 2020 personal income tax rates and tax brackets are as follows: Married individuals filing joint returns:
      Taxable income (USD) Tax rate for bracket (%)
      not over 19,750 10
      19,751 – 80,250 12
      80,251 – 171,050 22
      171,051 – 326,600 24
      326,601 – 414,700 32
      414,701 – 622,050 35
      more than 622,050 37
      Heads of households:
      Taxable income (USD) Tax rate for bracket (%)
      not over 14,100 10
      14,101 – 53,700 12
      53,701 – 85,500 22
      85,501 – 163,300 24
      163,301 – 207,350 32
      207,351 – 518,400 35
      more than 518,400 37
      Unmarried individuals:
      Taxable income (USD) Tax rate for bracket (%)
      not over 9,875 10
      9,876 – 40,125 12
      40,126 – 85,525 22
      85,526 – 163,300 24
      163,301 – 207,350 32
      207,351 – 518,400 35
      more than 518,400 37
      Married individuals filing separate returns:
      Taxable income (USD) Tax rate for bracket (%)
      not over 9,875 10
      9,876 – 40,125 12
      40,126 – 85,525 22
      85,526 – 163,300 24
      163,301 – 207,350 32
      207,351 – 311,025 35
      more than 311,025 37
      Estates and trusts:
      Taxable income (USD) Tax rate for bracket (%)
      not over 2,600 10
      2,601 – 9,450 24
      9,451 – 12,950 35
      more than 12,950 37

      Unearned income of minor children

      Children below the age of 18 who have unearned income (e.g. investment income) over a threshold amount are subject to tax (the "kiddie tax") at the highest tax rate applicable to their parents. The threshold amount of unearned income at which the kiddie tax will begin to apply for 2020 will be the sum of:
      • USD 1,100; plus
      • the greater of (i) USD 1,100 or (ii) the itemized deductions applicable to the child's unearned income if the child itemizes his or her deductions.
      A parent may elect to include the income of a child on the tax return of the parent if the only income of the child is from interest and dividends, if the child has no earned income, and if the interest and dividends of the child are above a threshold amount and below a ceiling amount. The threshold amount for 2020 will be USD 1,100 and the ceiling amount for 2020 will be USD 11,000.

      Exemption amounts for Alternative Minimum Tax

      The 2020 exemption amounts for the alternative minimum tax (AMT) are:
      Filing status AMT Exemption (USD)
      married individuals filing joint returns 113,400
      unmarried individuals 72,900
      married individuals filing separate returns 56,700
      estates and trusts 25,400
      The AMT is imposed at the rate of 26% on the taxable excess (i.e. the excess of the AMTI over the exemption amount) up to specified levels and 28% on the taxable excess above the levels. The 2020 taxable excess amounts above which the 28% rate applies are:
      Filing status Taxable excess (USD)
      married individuals filing joint returns 197,900
      unmarried individuals 197,900
      married individuals filing separate returns 98,950
      estates and trusts 197,900
      The exemption amounts are phased out by an amount equal to 25% of the amount by which the taxpayer's alternative minimum taxable income (AMTI) exceeds specified thresholds. The 2020 threshold amounts at which the AMT exemptions begin to phase out are:
      Filing status AMTI threshold (USD)
      married individuals filing joint returns 1,036,800
      unmarried individuals 518,400
      married individuals filing separate returns 518,400
      estates and trusts 84,800

      AMT exemption amount for kiddie tax

      The alternative minimum tax (AMT) exemption amount for 2020 for children who are subject to the kiddie tax will be the lesser of (1) the sum of the child's earned income plus USD 7,900 or (2) the regular AMT exemption amount for single taxpayers.
    • IRS announces inflation adjustments for 2020 – Part II

      On 6 November 2019, the US Internal Revenue Service (IRS) issued Revenue Procedure 2019-44 with inflation adjustments to tax allowances and other items for 2020. The IRS also issued a related News Release (IR-2019-180) dated 6 November 2019. The IRS will make these adjustments with effect from 1 January 2020. These adjustments are required to be made each year by the applicable provisions of the US Internal Revenue Code (IRC). The main adjustments announced by the IRS in Revenue Procedure 2019-44 are set forth below.

      Standard deduction amounts

      The year 2020 standard deduction amounts are:
      Filing status Standard deduction (USD)
      married individuals filing joint returns 24,800
      heads of households 18,650
      unmarried individuals 12,400
      married individuals filing separate returns 12,400
      dependent claimed on another taxpayer's return lesser of (1) USD 12,400; or (2) greater of (i) USD 1,100 or (ii) sum of dependent's earned income plus USD 350

      Overall limitation on itemized deductions

      For 2020, the overall limitation on itemized deductions does not apply.

      Personal exemption amount

      The year 2020 amount for each personal exemption is USD 0.

      Expatriation to avoid tax

      The year 2020 average annual net income tax threshold at which US citizens and US long-term residents will be deemed to have expatriated from the United States for tax avoidance purposes will be USD 171,000. The US expatriation provisions of IRC section 877A will apply if the average annual net income tax for the five preceding taxable years exceeds this amount or if the individual has a net worth in excess of USD 2 million or fails to meet certain certification requirements. The year 2020 exclusion amount that will apply in computing the net gain subject to taxation on a mark-to-market basis for property owned on the date of expatriation will be USD 737,000.

      Foreign earned income exclusion

      The year 2020 annual limitation under IRC section 911(b)(2) for the foreign earned income exclusion of qualified US citizens and residents working abroad will be USD 107,600.

      Unified credit against estate and gift tax

      The 2020 unified credit against estate and gift tax for eligible taxpayers under IRC section 2010 is equal to an estate and gift tax exclusion amount of USD 11,580,000.

      Annual exclusions for gifts

      The year 2020 limitation on gifts that are not included in the total amount of taxable gifts under IRC section 2503 (other than gifts of future interests in property) will be USD 15,000. The year 2020 limitation on gifts that may be made to a spouse who is not a citizen of the United States (other than gifts of future interests in property) will be USD 157,000. Gifts up to this amount will not be treated as taxable gifts under IRC section 2503(b) and IRC section 2523(i).

      Reporting large gifts from foreign persons

      The year 2020 threshold at which US persons who receive gifts from foreign persons will be required to file an information return with the IRS under IRC section 6039F will be USD 16,649.
    • Final regulations issued on ownership attribution for determining whether person is related to CFC, and on rents derived in active conduct of trade or business

      The US Treasury Department and the US Internal Revenue Service (IRS) have issued final regulations (9883) under sections 954 and 958 of the US Internal Revenue Code (IRC) to provide guidance related to the determination of foreign base company income (FBCI), which is a subcategory of subpart F income. The final regulations were published in the Federal Register on 19 November 2019. The final regulations provide guidance regarding the attribution of ownership of stock or other interests for purposes of determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under IRC section 954(d)(3). The final regulations limit the application of the downward attribution rules of IRC section 318(a)(3)(A) for purposes of the definition of a related person in IRC section 954(d)(3) to avoid inappropriately treating entities, including CFCs, that do not have a significant relationship to each other as related persons. In addition, the final regulations provide rules for determining whether a CFC is considered to derive rents in the active conduct of a trade or business for purposes of computing foreign personal holding company income (FPHCI). The final regulations adopt the proposed regulations (REG–125135–15), published on 20 May 2019, without changes (see United States-1, News 20 May 2019). The final regulations are designated Treasury Regulations sections 1.954-0, 1.954-1, 1.954-2, and 1.958-2. The final regulations generally apply to taxable years of CFCs ending on or after 19 November 2019, and taxable years of US shareholders in which or with which such taxable years end.
  • Tax Treaties
    • Tax Treaties

      A tax treaty is a bilateral agreement made by two countries to resolve issues involving double taxation of passive and active income. Treaties Update – November 2019
      Date Country A Country B Object Status
      05.11.19 Colombia United Kingdom Income Tax Treaty Approved by Constitutional Court
      18.11.19 Egypt United Arab Emirates Income Tax Treaty Signed