sábado, 26 de febrero de 2011

How to open a Non-Resident Accounts in Thailand

It is mandatory for International lawyers to know how to open a non-resident account in Thailand. To be considered the following facts.

Exchange control in Thailand is governed principally by the Exchange Control Act B.E. 2485 (A.D. 1942) (the “Exchange Control Act”) and Ministerial Regulation No. 13 B.E. 2497 (A.D. 1954), together with the Notifications and Notices issued there under. The Bank of Thailand is charged by the Ministry of Finance with the administration of foreign exchange in Thailand.

Presently, 13 Thai commercial banks and 18 foreign bank branches and one company (Asia Credit Public Company Limited) are registered and authorized by the Bank of Thailand. Subject to the conditions prescribed by the Bank of Thailand, non-residents are generally allowed to open and maintain both Thai Baht and foreign currency accounts with authorized agents (i.e. authorized banks and an authorized company) in Thailand.

miércoles, 9 de febrero de 2011

European Union Direct Taxes

Permanent Establishment is a vital concept in international taxation. While for direct taxes, it is mainly defined by the OECD Model Convention, the European VAT Directive and its implementing Regulation provide an EU-wide approach for VAT.
Difficulties arise as terminology and definitions in indirect and direct tax diverge. Moreover, countries have implemented and interpreted the EU and OECD rules in a different way, impacting on issues like cross-border reorganisations, transfer pricing, taxation of dividends and interest and royalties, tax residence, temporary and permanent transfer of assets, place of supply and VAT liability.
In both direct and indirect tax, the concept of Permanent Establishment has undergone very recent changes: The 2010 changes to the OECD Model Convention and Commentary, and in particular the new Art. 7, will be adopted in national law, as speakers from the Netherlands and Germany will report. The effect of the new definition on treaties with other countries will also be considered.
Some of this topic is addressed in the new book "European Union Direct Taxes", by the International Tax Professor Salvador Trinxet Llorca.
In indirect tax, the current more important issue is the practical consequences of the adoption of the Regulation implementing the EU VAT Directive in January 2011.