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Enron Mail |
FYI
W. Wayne Gardner Enron Broadband Services 1400 Smith Street Houston, TX 77002-7361 Phone: 713 853 3547 Fax: 713 646 2532 ----- Forwarded by Wayne Gardner/Enron Communications on 08/02/2001 18:28 ----- Wayne Gardner 08/02/2001 09:24 To: Paul Racicot/Enron Communications@Enron Communications cc: James Ginty/Enron Communications@Enron Communications Subject: Trading in Asia Paul, as we discussed this morning, Regulatory is telling us that it is likely that we will be able to establish a regional trading desk in Singapore that will hold all the licenses necessary to trade in all of the priority countries in Asia. Regulatory expects to receive confirmation next week that the 1% annual Singapore telecom license fee will apply only to Singapore bandwidth. Given that Asia trading will be centralized in Singapore, we want to make sure that the activities of traders outside of Singapore do not cause the Singapore trading operations to be subject to tax outside of Singapore. In this regard, Asia traders should keep in mind the following general rules: Traders that regularly engage in the execution of trades outside of Singapore will create a taxable presence outside of Singapore that will likely result in double taxation. Traders that regularly engage in the negotiation of trades outside of Singapore will create a significant risk that local tax authorities will assert that such activities created a taxable presence outside of Singapore that would likely result in double taxation. EBS Tax would want to monitor such a situation very closely, so please let us know immediately if these circumstances arise. Traders engaging only in the solicitation of business and the provision of product information (including pricing) outside of Singapore will not create a taxable presence outside of Singapore. In this regard, please note that even if traders restrict themselves to business solicitation, a large scale presence in any given country could attract the attention of the tax authorities who may adopt aggressive positions with regard to the creation of a taxable presence. When in doubt as to the application of these general rules to a specific situation, please do not hesitate to call. Thanks. W. Wayne Gardner Enron Broadband Services 1400 Smith Street Houston, TX 77002-7361 Phone: 713 853 3547 Fax: 713 646 2532
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