The Finance Act, 2021
Tax AlertJuly2021The Finance Act, 2021Tracking the changesThe President signed the Finance Act, 2021 (“the Act”) into law on 29 June 2021.The Act has introduced amendments to the various tax statutes in Kenya, theCapital Markets Act, the Insurance Act, the Retirement Benefits Act, 1997, and theCentral Depositories Act.The amendments introduced by the Act largely mirror those under the Bill.However, there are some notable changes in the Act that we wish to bring to yourattention. You are advised to read this analysis together with our analysis of theBill that we issued in May 2021. Please click here to read our analysis of theFinance Bill, 2021.
Income Tax Act HighlightsEBITDA-based interest limitation replaces the thincapitalization interest limitationMinimum tax would still be expected to apply regardlessof whether a person is in tax losses or not.Effective date: 1 January 2022.The Finance Act has repealed the thin capitalizationinterest limitation rule and replaced it with an EBITDAbased interest limitation rule.Definition of the term “control”effective 1 January 2021.Effective date: 1 July 2021.The Act has introduced an expanded definition of theterm “control” in the Income Tax Act. A person would beThe thin capitalization interest limitation prohibits a foreign deemed to control another person if:controlled entity, except a bank, from claiming an interest The person (not being an unrelated financialdeduction corresponding to the debt in excess of the debtinstitution):to-equity ratio of 3 to 1. For extractive sectors (mining and- advances a loan to the other person and the loanpetroleum sectors), the prescribed debt-to-equity ratio isconstitutes 70% or more of the other person’s2:1.total assets’ book value; orUnder the EBITDA-based interest limitation rule, only- guarantees 70% or more of the totalinterest up to 30% of the Earnings Before Interest,indebtedness of the other person;Depreciation and Amortization (EBITDA) will be allowed asa deduction. Any amount above 30% of EBITDA shall be The person or assignee of the person:disallowed.- supplies 90% or more of the other person’spurchases, or purchases 90% or more of theBanks and financial institutions licensed under the Bankingother person’s sales; andAct, and micro and small enterprises registered under the- the Commissioner upon assessment, deemsMicro and Small Enterprises Act, 2012 shall be excludedinfluence in the price or other conditions relatingfrom the EBITDA-based interest limitation rule. Personsto the other person’s purchases or sales, as thewho do not fall within this category (including individuals,case may be;locally controlled entities, branches of foreign entities andentities that operative in the extractive sectors) shall be The person has authority and mandate to appointaffected.more than half of the other person’s board ofdirectors or at least one director or executiveThe introduction of the EBITDA-based interest limitationmember of the governing board;rule will likely discourage borrowing and punish early-stage The person is the owner or has the exclusive rightscapital intensive businesses that have significant financeover intellectual property over which the other personcosts to fund their investments and other entities thatwholly depends on for the manufacture or processingsignificantly rely on debt funding non-registered financial/of goods or articles, or business;lending institutions. In the long run, this could adverselyaffect investment in the country, as investors may consider The person deals or relates with another in a waywhich the commissioner deems to constitute control;diverting their investments to other countries. There isandneed to revise the provisions to reduce the adverse impact In the case of a company, the person holds 20% orof the interest limitation rule.more of the voting rights the company. The thresholdEffective date: 1 January 2022.was previously 25%.Removal of the tax loss carry-forward limitationThe introduction of the “control” definition corrects theThe Act has deleted the provision in Section 15(4) of theinadvertent deletion of the term by The Tax LawsIncome Tax Act that allowed taxpayers to only utilize tax(Amendment) Act, 2020 in April 2020. However, the newlosses in the year in which they arise and the subsequent 9 definition is very broad and will significantly widen theyears, or such other longer period that may have beenscope of transfer pricing by extending the meaning ofapproved by the Minister. In its place, a new provision that related entities. The definition will also impact theallows taxpayers to utilize tax losses indefinitely has beendeductibility of foreign exchange losses on loansintroduced.advanced to controlled persons. The exchange lossesshall be deferred and not be allowed until the debt-toThe removal of the tax carry-forward limitation may haveequity ratio of such persons falls below 3 to 1.been informed by the introduction of minimum tax, 2021 Deloitte & Touche LLP2
New definition of “permanent establishment”The Act has deleted the definition of permanentestablishment (“PE”) in the Income Tax Act and replaced itwith an expanded definition as follows: A fixed place of business through which business iswholly or partly carried on. This includes a place ofmanagement, a branch, an office, a factory, aworkshop, a mine, an oil or gas well, a quarry or anyother place of extraction or exploitation of naturalresources, a warehouse in relation to a person whosebusiness is providing storage facilities to others, afarm, plantation or other place where agricultural,forestry plantation or related activities are carried onand a sales outlet;A building site, construction, assembly or installationproject or any supervisory activity connected to thesite or project, but only if it continues for a period ofmore than 183 days;The provision of services, including consultancyservices, by a person through employees or otherpersonnel engaged for that purpose, but only wherethe services or connected business in Kenya, continuefor a period of, or periods exceeding in the aggregate,91 days in any 12-month period commencing orending in the year of income concerned;An installation or structure used in the exploration fornatural resources where the exploration activitiescontinue for periods not less than 91 days;A dependent agent of a person who acts on theirbehalf in respect of any activities which that personundertakes in Kenya including habitually concludingcontracts or playing the principal role leading to theconclusion of contracts that are routinely concludedwithout material modification by the person. 2021 Deloitte & Touche LLPThe new definition captures the concept of a servicePE in the domestic legislation and excludes activitiesof a preparatory or auxiliary character from beingregarded as a PE.The expanded definition aligns, to a large extent, thedomestic legislation with international best practice,as captured in Article 5 of the UN and OECD ModelTax Conventions, which are widely used as the basisfor negotiating tax treaties.The introduction of the new PEdefinition is likely aimed atminimizing the opportunity for taxavoidance through strategies tocircumvent the existence of a PE.However, the Model Tax Conventions normally use athreshold of 12 months (OECD) or 6 months (UN) todetermine the existence of a PE. The definitionintroduced by the Act has lower time thresholds of 91days for services and exploration activities whichincreases the risk of PE for non-resident entitiesengaged in service provision or exploration activitiesin Kenya.The introduction of the new PE definition is likelyaimed at minimizing the opportunity for taxavoidance through strategies to circumvent theexistence of a PE.Effective date: 1 July 2021.3
Country-by-Country reporting byKenyan headquartered MNEGsThe Act has introduced a Countryby-Country reporting (CbCR)requirement on any Kenyanheadquartered multinationalenterprise group (MNEG), referred toin the Act as an “ultimate parententity” (UPE).A UPE will be required to file a returnof its financial activities in Kenya,where its gross turnover exceeds theprescribed threshold, and in all otherjurisdictions where it has taxablepresence.The return will be due within 12months of the MNEGs financialreporting period. It will contain theGroup’s aggregated informationrelating to the amount of revenue,the profit or loss before income tax,the income tax paid, the income taxaccrued, stated capital, accumulatedearnings, number of employees andtangible assets other than cash orcash equivalent regarding eachjurisdiction that the MNEG operates.The CbCR requirements will enablethe Kenya Revenue Authority to havevisibility of financial and relatedinformation that will aid in assessingthe transfer pricing risk or any BEPSrelated risk and make determinationson how to allocate tax auditresources. For the taxpayers who arepart of a multinational group, thismeans additional transfer pricingreporting requirements.There is need to set a threshold forreporting to avoid overburdeningsmaller entities.Effective date: 1 January 2022Minimum taxThe Act has amended the Income TaxAct and exempted the followingpersons from the minimum taxregime: Persons engaged inmanufacturing and whosecumulative investment in thepreceding four years from thedate of assent is at least tenbillion shillings;Persons licensed under theSpecial Economic Zones Act,2015; andPersons engaged in distributionbusiness and whose income iswholly based on a commission 2021 Deloitte & Touche LLPThe above is in addition to thepersons that were added to theexemption list by the Tax Laws(Amendment) No. 2, Act, 2020. Thepersons include: Persons engaged in businesswhose retail price is controlled bythe Government; and Persons engaged in insurancebusinessAlthough the exemption of morepersons from the minimum taxregime is welcome, there is still moreto be done for the regime to befriendlier. For instance, the 1% taxrate is on the higher side comparedto the rates applicable in otherjurisdictions and there is need torevise the provisions to only apply toentities reporting several years ofconsecutive losses (3-5). It would alsobe welcome if the governmentintroduced a turnover thresholdbelow which minimum tax should notapply.Effective date: 1 July 2021.Investment allowance at 100%The Act has introduced anaccelerated investment allowance at100% in a given year where:The investment value outsideNairobi City County and MombasaCity County in the year is KES 250million; The cumulative investment in thepreceding 3 years outside NairobiCounty and Mombasa County isat least KES 2 billion; or The investment is incurred in aSpecial Economic Zone.This move is aimed at encouraginginvestment in Special EconomicZones and outside the two countiesof Nairobi and Mombasa, which arerelatively more developed comparedto other counties. It is a welcomerelief for qualifying investors. Effective date: 1 January 2022.Investment allowance on bulkstorage facilitiesThe Act has amended the Income TaxAct to provide that Paragraph 24E ofthe repealed Second Schedule shallcontinue to apply until 31 December2022.The Paragraph, which was expectedto apply until 31 December 2021,entitles a person to investmentallowance at 150% if the personincurs capital expenditure of at leastKES 5 billion on the construction ofbulk storage and handling facilities ofat least 100,000 MT storage capacityfor supporting the Standard GaugeRailway operations.We believe the intention of extendingthe application of the provision to 31December 2022 is to accord personswho had taken advantage of theprovision full benefit uponcompletion of their projects.Effective date: 1 July 2021.Basis of computing investmentallowanceThe Act has amended the basis ofcomputing investment allowancefrom reducing balance to straightline.Computation of capital allowances ona straight-line basis is simple andreduces the period of recovery ofcapital costs.Effective date: 1 January 2022.Income from registered trustsThe Act has amended Section 11 ofthe Income Tax Act to restrict theapplication of subsection 3 (whichdeems any amount received by abeneficiary from a trustee to havealready been taxed as per theIncome Tax Act) in the case of aregistered trust to the following: any amount that is paid out of thetrust income on behalf of anybeneficiary and is used exclusivelyfor the purpose of education,medical treatment or earlyadulthood housing; income paid to any beneficiarywhich is collectively below tenmillion shillings in the year ofincome; and such other amount as theCommissioner may prescribefrom time to time and at suchrate as prescribed in paragraph 5of the Third Schedule. To thiseffect, the Finance Act, 2021 hasalso introduced a rate of 25% inthe Third Schedule.The amendment introduced by theFinance Act will lead to taxation ofincome from registered trusts paidout to beneficiaries that do not fallunder the categories outlined above.Effective date: 1 July 2021.4
Income from settlementThe Act has amended the definitionof “settlement” as used in Section 25and 26 of the Income Tax Act, asdiscussed below. The amended definition underSection 25 excludes the “transferof assets made through a familytrust” in the definition of“settlement”. Section 25 deemsthe income paid by a settler to, orfor the benefit of his/ her childduring the settler's life to beincome of the settler. The sectionshall therefore not be expected toapply to the transfer of assetsmade through a family trust. The amended definition in Section26 excludes a registered familytrust from covenants that qualifyas “settlement”. Section 26 deemsthe income accrued to orreceived by a person under asettlement from assets remainingthe property of the settlor, to beincome of the settler. With thechange introduced by the FinanceAct 2021, income received undera family trust covenant shall notbe covered by Section 26.Deeming of income settled onchildren to be income of the settlermeans that tax on the income (if any)is borne by the settler and the childshall receive the income free of tax.We believe the changes to Section 25and 26 of the Income Tax Act areaimed at encouraging persons to usefamily trusts for successionpurposes.Effective date: 1 July 2021.Exemption of the income of a familytrust and transfers of property to afamily trustThe Act has introduced the followingincomes into the Income Tax Act’sexemption list: 2021 Deloitte & Touche LLP The income or principal sum of aregistered family trust;Capital gains relating to thetransfer of title of immovableproperty to a family trust; andCapital gains accruing to anindividual on the transfer ofproperty, including investmentshares, for the purpose oftransferring the title or theproceeds into a registered familytrust;The above changes are welcome asthey will encourage use of familytrusts for succession purposes.Effective date: 1 July 2021.Double taxation agreementsThe Act has repealed the provisionsof Section 41 of the Income Tax Act,which gives effect to double taxationagreements that the Government ofKenya has entered into with othercountries.The repealed provisions have beenreplaced by new provisions thatlargely mirror the repealedprovisions. A key highlight of the newprovisions is the presence of anexpress provision, which providesthat any agreement that thegovernment enters into shall besubject to the provisions of theTreaty Making and Ratification Act,2012, (TMRA). The TMRA provides theprocedure for the making andratification of treaties and connectedpurposes. This amendment is, in ourview, aimed at voiding anyarrangement that has not compliedwith the provisions of the TMRA. Thisaligns with recent court ruling on, forinstance, the Kenya-Mauritius DTA.Effective date: 1 July 2021.Tax rebate on graduateapprenticeshipsThe Act has amended Section 39B ofthe Income Tax Act and extended thetax rebate on graduateapprenticeships to technical andvocational graduates.Employers who engage at least 10university, or technical and vocationalgraduates for 6 to 12 months, underan apprenticeship contract, will beentitled to an additional deductionequivalent to 50% of the employmentcosts expended on the apprentices.Previously, only the cost incurred onuniversity graduates was eligible forthe rebate.This amendment shows that thegovernment is keen to createopportunities for not just universitygraduates, but also other institutionsthat train individuals to acquire skillsfor the job market. However, giventhe low uptake of the apprenticeshipprogram since its introduction in2016, the government shouldconsider relaxing the strictrequirements set out in the IncomeTax (Set-Off Tax Rebate for GraduateApprenticeships) Regulations, 2016to improve the uptake.Effective date: 1 January 2022.Personal income tax changesThe Act has expanded the scope ofinsurance relief to also covercontributions made to the NationalHospital Insurance Fund (“NHIF”).The relief is computed at 15% of thepremiums paid, subject to amaximum of KES 60,000 per annum.This is expected to encouragevoluntary NHIF contributionsEffective date: 1 January 2022.5
Digital service tax changesValue Added Tax HighlightsExemption of exported servicesThe Act has introduced the followingchanges on digital service tax (DST): Expansion of the scope ofapplication of digital service tax(DST) to capture any income froma business carried over theinternet or an electronic network,including through a digitalmarketplace. Previously, digitalservice tax was only applicable onincome accruing through a digitalmarketplace. Amendment of the definition of“digital marketplace” to cover any“online platform, which enablesusers to sell or provide services,goods or other property to otherusers”. Exemption of resident personsfrom the DST regime. This is apositive move, as the impositionof DST on residents would haveincreased the backlog of refundsgiven that residents were entitledto an offset of the DST paidagainst their income tax liability.However, it is worth noting thatnon-residents operating in Kenyathrough PEs have not beenexcluded from the DST regimedespite their income being taxedin Kenya through the selfassessment regime. We believethe PEs should be exempted forthe same reasons that residentsare. Aligning the due date for payingDST with the due date for filingthe DST return. The law previouslyrequired DST to be paid at thepoint of paying the digital serviceprovider. A person may thereforedefer the payment of DST up to20th of the following month. Exemption of income subject towithholding tax and that of a nonresident person who carries onthe business of transmittingmessages by cable or radiocommunication, optical fibre,television broadcasting, VerySmall Aperture Terminal (VSAT),internet or any other similarmethod of communication, fromthe DST regime. It is noteworthythat this was already anchored inthe Income Tax (DST) Regulations,2020, but may have beenintroduced in the main legislation,perhaps to cure anycontradictions.VAT on imported servicesThe Act has changed the status ofexport of taxable services from zerorated to exempt. This move is aimedat reducing cases of VAT refundclaims and is probably a reaction tothe numerous disputes on thematter of VAT on export of services.Effective date: 1 July 2021. 2021 Deloitte & Touche LLPThe Finance Act, 2019 expanded thescope of persons subject to VAT onimported services to cover personsnot registered for VAT. However, thechanges did not conclusively amendthe applicable sections of the VAT Act2013.The Finance Act 2021 has nowintroduced a raft of changes toSections 2, 10 and 19 of the VAT Act2013 to clean this up.Effective date: 1 July 2021VAT on supplies through digitalmarketplacesThe Act has been amended to clarifythat supplies made over the internet oran electronic network through a digitalmarketplace are chargeable to VAT. Inaddition, the definition of “digitalmarketplace” under the VAT Act tomean “online platform which enablesusers to sell or provide services, goodsor other property to other users”.This change is aimed at widening theVAT net. The previous definition onlyenvisaged a platform that enableddirect interaction between sellersand buyers of goods and serviceselectronically. This definition mayhave been deemed restrictive, andhence the move to make thedefinition broader to capture moresupplies. Players in the digital space,whose transactions may not havebeen previously covered based onthe prior definition will thereforeneed to consider if they now fallwithin scope.Effective date: 1 July 2021Deductibility of input taxThe Act has amended Section 17(4)of the VAT Act to prohibit thededuction of input tax suffered onthe hiring or leasing of passengercars and minibuses. However, in linewith existing provisions of the law,this prohibition applies to the extentthat a registered person does nothire or lease such vehicles toexclusively deal in the business ofselling, dealing in or hiring of suchvehicles.Businesses that may acquire, hire orlease passenger cars and minibusesshould take note of this change andaccordingly not deduct the attendantinput tax.Effective date: 1 July 2021.As a result of this change, affectedbusinesses (those providing servicesfor use/consumption outside Kenya)will have to absorb input tax as abusiness cost.The move to exempt the export oftaxable services offends theneutrality and destination principlesof VAT. It negates international bestpractice. While the move may bedriven by the desire to reduce casesof VAT refund, its impact onbusinesses engaged in cross bordertrade in services, including sharedservices, may be dire.Effective date: 1 July 2021.Ordinary bread to remain zero-ratedThe Finance Bill 2021 had proposedto delete the supply of ordinarybread from the list of zero-rateditems. As a result, it was argued thatthe deletion rendered ordinary breadtaxable at 16%. However, it has beenclarified that there was a draftingerror and the exempt schedule stillexempted ordinary bread from VAT.The Act now deletes the supply ofordinary bread from the exemptionschedule and retain the same underthe zero-rated schedule.This is a welcome move, as breadremains an essential dietary item. Amove to either exempt or standardrate the product would havenegatively impacted its affordability.Transportation of goods from Kenyato another country to be zero-ratedThe Act has introduced thetransportation of goods originatingfrom Kenya to a place outside Kenyainto the zero-rating schedule.This move may be geared towardsensuring the transport sector does notsuffer the effects of changing the statusof exported services, hence, keepingthe sector at par with competitors fromother countries in the East Africanregion.Effective date: 1 July 2021.6
Transportation of sugar-cane from milling firms tofactories to be zero-ratedThe Act has introduced the transportation of sugarcanefrom farms to milling factories into the zero-ratingschedule.This move may be seen as an effort to support the revivalof the ailing sugar sector.Effective date: 1 July 2021.Zero-rating of maize flour, cassava flour and wheat ormeslin flourThe Act has introduced the supply of maize (corn) flour,cassava flour, wheat or meslin flour and maize flourcontaining cassava flour by more than ten percent inweight into the zero-rating schedule/upon enactment of the Bill into law. In effect, groupregistration provisions will remain under the VAT Act2013.However, due to lack of regulations to supportimplementation of group VAT registration, thisprovision has not been applied in recent time.Perhaps it’s the high time the Cabinet Secretary putsin place the applicable regulations.Other VAT changesThe Act has retained the proposed changes in theFinance Bill 2021, which sought to introduce severalitems into the exemption schedule. A full listing ofthese items is as contained in our tax alert for theFinance Bill 2021.This makes these essential products more affordable.The following additional items have been introducedinto the exemption schedule, effective 1 July 2021:Effective date: 1 July 2021 Retention of veto power over regulationsThe Finance Bill 2021 had proposed to delete therequirement to table VAT regulations before the NationalAssembly before they become effective. This would haveaccorded the Cabinet Secretary in charge of Treasuryunchecked delegated legislative authority.The Act has done away with this proposed change and,as such, VAT regulations made by the Cabinet Secretaryin exercise of delegated law-making authority will remainsubject to approval by the National Assembly. Taxable supplies including fish feeding andhandling, water operations, cold storage, fishcages, pond construction and maintenance, andfish processing and handling, imported orpurchased for direct and exclusive use on therecommendation of the relevant statedepartment,Pre-fabricated biogas digesters,Biogas,Sustainable fuel briquettes for household andcommercial use,The supply of denatured ethanol of tariff number2207.20.00, andRetention of group registration The Finance Bill 2021 had proposed the repeal of thegroup registration provisions under Section 34(9) of theVAT law. This proposed repeal has however been deletedThe Act has also retained the proposed clean up oftariff codes. Further details are contained in ourFinance Bill 2021 tax alert. 2021 Deloitte & Touche LLPTractors other than road tractors for semitrailers.7
Excise Duty Act HighlightsIntroduction of excise dutyThe Act has introduced excise duty on various products as outlined below.ProductRateLocally manufactured white chocolate, chocolate inblocs, slabs or bars of tariff code1806.31.00,1806.32.00 and 1806.90.00.KES 209.88 per kgJewellery of tariff heading 7113 & imported jewelleryof tariff heading 711710%Products containing nicotine or nicotine substitutesintended for inhalation without combustion or oralapplication but excluding medicinal productsapproved by the Cabinet Secretary responsible formatters relating to health.KES 1,200 per KgArticles of plastic of tariff heading 3923.30.0010%Imported pasta of tariff heading 1902 whethercooked or not, stuffed (with meat or othersubstances) or otherwise prepared such asspaghetti, macaroni, noodles, lasagna, gnocchi, ravioli,cannelloni, couscous, whether or not prepared20%Imported furniture of any kind used in offices,kitchen, bedroom and other furniture of tariffheading 940325%Imported eggs of tariff heading 040725%Imported onions of tariff heading 070325%Imported potatoes, potato crisps & potato chips oftariff heading 070125%Unsaturated polyester of tariff code 3907.91.0010%Alkyd of tariff code 3907.50.0010%Emulsion Vinyl Acetate Monomer (VAM) of tariff code3905.91.0010%Emulsion-styrene acrylic of tariff code 3903.20.0010%Homopolymers of tariff code 3905.19.0010%Emulsion B.A.M of tariff code 3906.90.0010%Betting and Gaming7.5% of the amount wagered or stakedPrice competition7.5% of the amount paid or charged to participate in thecompetitionLottery (excluding charitable lotteries)7.5% of the amount paid or charged to buy the lotteryticket. 2021 Deloitte & Touche LLP8
The introduction of excise duty onimported onions, potatoes and eggsis aimed at shielding local farmers ofthese products from competitionarising from cheap imports. Thismeasure is in line with similar importduty changes on agriculturalproducts introduced through theEast African Community Gazette of30 June 2021 and is aimed atpromoting growth of the agriculturalsector and improve the livelihoods ofmost Kenyans in the rural areas whorely on farming as a primary sourceof income. However increased taxeson imports is not the answer if otherchallenges affecting the agriculturalsector are not addressed andtherefore this may only lead toincreased cost of products forconsumers without necessarilyimproving local production.The Finance Bill had proposed toreintroduce excise duty on betting at20%. However, the 20% excise ratewas quite significant and would havepotentially curtailed the operations ofbetting firms in the Kenyan market. Inthis regard, the Act has apportionedthe 20% excise duty amongst otheractivities under the Betting Lotteriesand Gaming Act ( gaming, pricecompetition and lottery) that arecurrently not subject to excise duty.The introduction of excise duty onimported furniture is in line with theincrease in the import duty onfurniture and is aimed at promotinglocal manufacture of these products.However, given other factors thataffect local production such asavailability of raw materials and costof production, it may not achieve thedesired goal.Effective date: 1 July 2021Increase of excise duty ratesThe Act has increased the excise dutyon imported sugar confectionary oftariff heading 1704 from KES 20.99per kg to KES 35 per kg. The FinanceBill 2021 had proposed to introduceexcise duty on locally manufacturedconfectionery. However, the NationalAssembly did not approve thisproposal, as it would go against theGovernment s agenda of promotinglocal manufacturing. The increase ofexcise duty on imported sugarconfectionery could be aimed atbridging the revenue that would havebeen expected from locallymanufactured confectionery. 2021 Deloitte & Touche LLPThe Act has also increased duty ontelephone and internet data servicesfrom 15% to 20%. This measure willlikely increase the cost ofcommunication via telephone andaccess to internet.Effective date: 1 July 2021Amendment of the definition of otherfees charged by financial institutionsThe Act has amended the definitionof “other fees” in the Excise Duty Act(EDA) by deleting the words “fees orcommissions earned in respect of aloan”. The revised definition of “otherfees” is as follows.“Other fees” means any fees, charges orcommissions charged by financialinstitutions relating to their licensedactivities but does not include intereston loan or return on loan or any shareof profit or an insurance premium orpremium based, or relatedcommissions specified in the InsuranceAct or regulations made thereunde
The Finance Act has repealed the thin capitalization interest limitation rule and replaced it with an EBITDA-based interest limitation rule. The thin capitalization interest limitation prohibits a foreign controlled entity, except a bank, from claiming an interest deduction corresponding to the debt in excess of the debt-to-equity ratio of 3 to 1.
May 02, 2018 · D. Program Evaluation ͟The organization has provided a description of the framework for how each program will be evaluated. The framework should include all the elements below: ͟The evaluation methods are cost-effective for the organization ͟Quantitative and qualitative data is being collected (at Basics tier, data collection must have begun)
Silat is a combative art of self-defense and survival rooted from Matay archipelago. It was traced at thé early of Langkasuka Kingdom (2nd century CE) till thé reign of Melaka (Malaysia) Sultanate era (13th century). Silat has now evolved to become part of social culture and tradition with thé appearance of a fine physical and spiritual .
On an exceptional basis, Member States may request UNESCO to provide thé candidates with access to thé platform so they can complète thé form by themselves. Thèse requests must be addressed to esd rize unesco. or by 15 A ril 2021 UNESCO will provide thé nomineewith accessto thé platform via their émail address.
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Dr. Sunita Bharatwal** Dr. Pawan Garga*** Abstract Customer satisfaction is derived from thè functionalities and values, a product or Service can provide. The current study aims to segregate thè dimensions of ordine Service quality and gather insights on its impact on web shopping. The trends of purchases have
Chính Văn.- Còn đức Thế tôn thì tuệ giác cực kỳ trong sạch 8: hiện hành bất nhị 9, đạt đến vô tướng 10, đứng vào chỗ đứng của các đức Thế tôn 11, thể hiện tính bình đẳng của các Ngài, đến chỗ không còn chướng ngại 12, giáo pháp không thể khuynh đảo, tâm thức không bị cản trở, cái được
Le genou de Lucy. Odile Jacob. 1999. Coppens Y. Pré-textes. L’homme préhistorique en morceaux. Eds Odile Jacob. 2011. Costentin J., Delaveau P. Café, thé, chocolat, les bons effets sur le cerveau et pour le corps. Editions Odile Jacob. 2010. Crawford M., Marsh D. The driving force : food in human evolution and the future.
Le genou de Lucy. Odile Jacob. 1999. Coppens Y. Pré-textes. L’homme préhistorique en morceaux. Eds Odile Jacob. 2011. Costentin J., Delaveau P. Café, thé, chocolat, les bons effets sur le cerveau et pour le corps. Editions Odile Jacob. 2010. 3 Crawford M., Marsh D. The driving force : food in human evolution and the future.
