KGS. There are no secrets to success. It is the result of preparation, hard work, and learning from failure. Colin Powell INTEGRITY FIRST

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1 There are no secrets to success. It is the result of preparation, hard work, and learning from failure. Colin Powell INTEGRITY FIRST

2 Cost INDEX S. No. Topic 1. Foreign Tax Credit Rules 2. Brexit: Impact on Indian Economy 3. GST Series I - Registration 4. Form 15 CA & Form 15 CB 5. Managerial Remuneration under Companies Act 2013

3 Foreign ` Tax Credit Rules This article aims to describe About Foreign Tax Laws relating to Foreign Tax Credit Documentation and Forms Required to obtain FTC Tayyab Ali & Nidhi Matta

4 Foreign Tax Credit Rules The Central Board of Direct Taxes (CBDT) has released draft rules (the Rules) for granting Foreign Tax Credit (FTC) to Resident taxpayers in respect of taxes paid in overseas countries. The Rules lay down broad principles and conditions for computation and claim of FTC respectively. To provide relief to corporates with income abroad, the Income Tax Department has notified Foreign Tax Credit Rules allowing companies to claim credit for taxes, surcharge and cess paid overseas. The rules, which come into effect from April 1, 2017, allow the tax payers to claim Credit of Foreign Tax under dispute once it is finally settled. Meaning of foreign tax Foreign tax shall mean: - In respect of a country with which India has entered into a Double Taxation Avoidance Agreement (DTAA): Tax covered under the said tax treaty; and - In respect of any other country: the tax payable under the law in force in that country in the nature of income-tax including any excess profits tax or business profits tax charged on the profits by the Government of any part of the foreign country or by a local authority in that country. Law Relating to Foreign Tax Credit Section 295(2)(ha) of the Income-tax Act, 1961 (the Act) gives The Central Board of Direct Taxes the power to prescribe rules for claim of Foreign Tax Credit to Resident taxpayers in respect of taxes paid in overseas countries. Year of availability Foreign Tax Credit shall be available to the taxpayer in the year in which the income corresponding to such foreign tax has been offered to tax or been assessed to tax in India. Tax against which credit is available Foreign Tax Credit shall be available against the amount of tax, surcharge and cess payable under the Act. Foreign Tax Credit shall also be allowed against tax payment under Minimum Alternate Tax (MAT)/ Alternate Minimum Tax (AMT) provisions. Foreign Tax Credit shall not be available against the following: - Payment of any interest, fee or penalty under the Act, and -Any amount of foreign tax disputed by the taxpayer. Mode of computation Foreign Tax Credit is to be computed separately for each source of income arising from a particular country. Total available FTC shall be the aggregate of the amounts of FTC computed separately for each source of income. Foreign Tax Credit shall be the lower of: - Tax payable under the Act on the income; or - Foreign tax paid on the

5 Rate of Exchange Foreign Tax Credit shall be determined by conversion of the currency of payment of foreign tax at the Telegraphic Transfer Buying Rate on the date on which such tax has been paid or deducted. Mode of payment of Foreign Tax The mode of payment can be: -Direct payment or, -By way of deduction. Documentation Requirements The Rules require taxpayers to furnish certain documents, in the absence of which FTC will not be available. These documents are: 1. In cases where the foreign tax is deducted at source: - Certificate from the tax authority of the foreign country or the person responsible for deduction of tax specifying the nature of income and amount of tax deducted therefrom; and - A declaration by the taxpayer that the amount of foreign tax in respect of which credit is being claimed is not under any dispute. 2. In cases where the foreign tax is paid by the taxpayer: - Certificate from the tax authority of the foreign country specifying the nature of income and amount of tax paid by the taxpayer; - Proof of tax payment; and - A declaration by taxpayer that amount of foreign tax in respect of which credit is being claimed is not under any dispute. MAT Credit Implications Any excess Foreign Tax Credit available against tax payable under the Minimum Alternative Tax/ Alternative Minimum Tax provisions as compared to the tax payable under the normal provisions shall be ignored while computing the MAT/ AMT credit to be carried forward. Filing of Statements & Forms Taxpayers claiming Foreign Tax Credit shall now be required to file a Statement of Income from a foreign country with details of tax paid in the prescribed Form 67. The Central Board of Direct Taxes (CBDT) has also allowed tax payers to give self-certified statement, giving the nature of income and the amount of foreign tax deducted or paid accompanied with the counterfoil or acknowledgment of taxes paid and/or proof of taxes having been deducted at source, for claiming Foreign Tax Credit.

6 IMPACT ON INDIAN BREXIT: ECONOMY This article aims to highlight What is BREXIT? Why BREXIT? Impact on Britain Impact on Indian Economy CA Kunal Jain & Yash Jaiswal

7 Brexit: Impact on Indian Economy What is Brexit? The term 'Brexit' is a combination of BRITAIN and EXIT, meaning the exit of the United Kingdom (UK) from the European Union (EU). It is also known as United Kingdom European Union membership referendum, 2016 or EU Referendum or Brexit Referendum. Purpose of Brexit: It was a non-binding referendum to gauge support for the country's continued membership in the European Union. British withdrawal from the European Union is a political goal that has been pursued by various individuals, advocacy groups, and political parties since the United Kingdom joined the precursor of the European Union (EU) in The sudden increase in global risk aversion can impact the inflow from foreign portfolio investors (FPIs) to India. The Indian market, however, has to worry about another more major event: The upcoming big Foreign Currency Non-Resident (FCNR) fixed deposit redemption due in September. However, the recent spike in inflationary pressure may force the RBI to not go for accelerated cuts. Though the RBI may not go for accelerated rate cuts, the rate direction is still downward. This means short-term investors can bet on rate-sensitive sectors such as auto, infrastructure, banking, etc. Short Term Impact on the Economy: The immediate, short-term effect must be negative, with its severity depending on the extent to which the major economies in Europe are affected. If Brexit results in a sharp contraction in these economies, then their demand for Indian exports will shrink. These effects will smoothen out over time once the European economies recover. The devaluation of the Pound implies that imports will be costlier in Britain and this will be another source of decrease in imports over and above that caused by a shrinking economy. Long Term Impact: Brexit will have an impact on India's GDP growth. The aggregate 2016 GDP growth forecast for Asia excluding Japan has been lowered from 5.9% to 5.6% and India's 2016 GDP growth forecast to 7.3% from 7.6%. Also, even though India will be impacted by the global turmoil, it'll still be much better off. "Indian markets should perform better compared to most other emerging markets and also the developed markets," says Dipen Shah, Senior Vice-President and Head, Private Client Group Research. The impact on Indian FDI to the UK could potentially be over two time periods: the short-medium term and the long term. The short-medium term covers the interim period before the referendum, and is likely to see FDI decrease temporarily, the deterrents being the potential financial instability and a legal regime overhaul. Investors may put off investing till at least after the transition. A survey of 406 investors (31% of those surveyed) suggested that they would reduce or freeze potential investment until is a conservative estimate, since investors will be wary of investing in the transitory period after the referendum as well, waiting till the market shows confidence in the new investment regime. (P.T.O.)

8 It is difficult to predict the outcome of Brexit on Indian FDI because of other competing factors like the unstable European markets, a tumbling Euro and possible disintegration of the Eurozone, all tugging in different directions. Conclusion Only one thing is clear; Indian FDI in the UK is increasing. London is looking to attract this FDI. Makes for good negotiation. Although significant coverage has predictably focused on the fallout from the referendum, the UK s decision to leave the European Union presents a potential upside for India in numerous ways. Brexit will likely compel London to seek a more robust trade relationship with New Delhi. Britain and India have been so far unable to reach a free trade agreement, with negotiations having become mired in the convoluted financial politics of the 28-nation EU block. Some analysts predict Brexit could lead to changes in UK immigration policies that would favor highskilled workers from India. Divorced from the rest of the Europe, the UK could potentially face a dearth of high-skilled EU workers if the movement of professionals from the continent is curbed. India could benefit from the possible shortfall.

9 GST SERIES I - Registration This article highlights Key Terms in Model GST Law for Registration Garima Sharma & Kajali Aggarwal

10 GST Series I- Registration Registration- General: Every supplier shall be liable to be registered under this Act in the State from where he makes a taxable supply of goods and/or services if his aggregate turnover in a financial year exceeds INR 9 lakhs (reduced threshold limit of INR 4 lakhs prescribed for North-Eastern States including Sikkim). Threshold shall be computed on all India basis. Concept of Centralised Registration shall be no longer available. Mandatory - Registration: Following persons shall be required to be mandatorily registered irrespective of Basic Threshold Limit under GST: Persons making any inter-state taxable supply Casual taxable persons Persons who are required to pay tax under reverse charge Non-resident taxable persons Persons who supply goods and/or services on behalf of other registered taxable persons whether as an agent or otherwise Input service distributor Persons who supply goods and/or services, other than branded services, through electronic commerce operator Every electronic commerce operator An aggregator who supplies services under his brand name or his trade name Such other person or class of persons as may be notified by the Central Government or a State Government on the recommendations of the Council. Persons who are required to deduct tax under section 37 Registration Procedure: Every person who is liable to be registered under this Act shall apply for online registration in every such State in which he is so liable within (30)thirty days from the date on which he becomes liable to registration, in such manner and subject to such conditions as may be prescribed. Provided that if the person, other than an Input Service Distributor, is registered under an earlier law, it shall not be necessary for him to apply for fresh registration under this section and he shall follow the procedure as may be prescribed in this behalf. The State/Central Authorities shall grant Registration Certificate within 3 working days, provided uploaded documents are found in order. Grant of registration under CGST deemed to be grant of registration under SGST. In the absence of any discrepancy, registration deemed to be granted after the period prescribed has expired. Registration No: Under GST registration, it is likely to be linked with the existing PAN.The new business identification number was likely to be the 10-digit alphanumeric PAN, in addition to two digits for state code and one or two check numbers for disallowing fake numbers. The total number of digits in the new number was likely to be Amendment in Registration: Proper Officer to be informed in case of change in any information furnished at the time of registration or subsequently. Approval/rejection of such amendment to be at the discretion of the Proper Officer, subject to granting of opportunity of being heard/notice. Approval/rejection of amendment under CGST to be deemed to be approval/rejection under SGST and CGST both.

11 Cancellation/Revocation of Registration: Proper Officer, either suo moto/on application filed shall cancel registration in circumstances prescribed in law. Failure to furnish tax returns for three consecutive tax periods. Failure to furnish tax returns for six consecutive tax periods (in case of composition) Failure to commence business within six months from the date of voluntary registration. Revocation of Cancellation can be applied for within 30 days of receipt of cancellation order. Composition Scheme: A person having aggregate turnover in a financial year, upto INR 50 lacs can opt for composition scheme. Option not available in case of inter-state supplies of goods and/or services. Applicable tax rate under the scheme not less than 1% of turnover. Not eligible for input tax vredit. Tax cannot be collected from the recipient of goods/services. Penal provisions applicable equivalent to amount of tax payable. Migration of existing registrants: Existing registrants are those who are either registered with States or with the Centre or with both: For Taxpayers Registered under State For Taxpayers Registered under Service Tax VAT/Excise Taxpayers under Excise & Vat, source of data for issuing GSTIN to be VAT data State tax Authorities to communicate GSTIN/password to taxpayers for filling up remaining information, post which Authorities shall undertake verification For generation of GSTIN, it is to be ensured that PAN is validated. Taxpayers to themselves intimate the States where they would like to get themselves registered. Service Tax portal will check from GST portal whether GSTIN has been generated for combination of State & PAN of the taxpayer. If not generated request GST portal to generate the same. GSTIN shall be generated & communicated to taxpayer for filling up remaining information. Verification by Authorities, can be done post GSTIN issues Casual/Non-Resident Taxable Person Registration: The Certificate of registration issued to a casual taxable person or a non-resident taxable person shall be valid for a period of 90 days from the effective date of registration. Casual Taxable Person: A supplier who is not registered on regular basis, desiring to conduct business in a particular State for limited period can opt for registration as a casual taxable person Such supplier would be eligible to claim ITC. Not eligible for composition scheme. Separate Returns applicable Advance Tax on self-assessment basis would be required to be paid Non-Resident Taxable Person: A non-resident supplier is a person applying for registration in a State in which he is not a resident but registered in any other State. All other provision of casual taxable person (as mentioned above) to apply. Illustration: Registration in GST Vs. Existing Registration: e.g. XYZ is a Co. having 4 manufacturing Units and warehouses in 30 States Existing Registration: GST Excise:4 Service Tax (Centralised): 1 Separate Registrations: 30 VAT: 30 TOTAL: 35 TOTAL: 30

12 Form 15 CA & Form 15 CB This article aims to explain: About Form 15 CA & 15 CB Documents Required for getting Form 15 CA & 15 CB Amendments in Form 15 CA & 15 CB CA JITIN GIRDHAR & VISHWAS VIRMANI

13 Form 15 CA & Form 15 CB FORM 15 CA Form 15CA is a Declaration of Remitter and is used as a tool for collecting information in respect of payments which are chargeable to tax in the hands of recipient nonresident. This is starting of an effective Information Processing System which may be utilized by the Income tax Department to independently track the foreign remittances and their nature to determine tax liability. Authorised Dealers/ Banks are now becoming more vigilant in ensuring that such Forms are received by them before remittance is effected since now as per revised Rule 37BB a duty is casted on them to furnish Form 15CA received from remitter, to an income-tax authority for the purposes of any proceedings under the Income-tax Act. Whether Form 15CA has to be submitted in all cases since the Bankers demand it invariably? In this regards the attention is invited to the Headings of the Form which provides as under: Information to be furnished for payments, chargeable to tax, to a non-resident not being a company, or to a foreign company (To be filled up if the remittance is chargeable to tax and does not exceed fifty thousand rupees and the aggregate of such remittances made during the financial year does not exceed two lakh fifty thousand rupees) FORM 15 CB Form 15CB is the Tax Determination Certificate where the Issuer CA examines the remittance having regard to chargeability provisions under Section 5 and 9 of Income tax Act along with provisions of Double tax Avoidance Agreements with the Recipient s Residence Country. Therefore in my opinion, it is advisable to obtain 15CB even in cases where 15CA is not mandated. Though there is no penal provision prescribed in the Act if such Certificates in Form 15CB and Declaration in Form 15CA are not obtained, but it is in the interest of Assessee to have a tax determination in Form 15CB from a CA, since Nonresident taxation involves various complex issues and the consequences of Non deduction are severe. Major Changes and Amendments in 15CA and 15CB in respect of furnished information regarding payments made to non-resident of India under section 195 of the Act. CBDT has made some changes in Rule 37BB to reduce the compliance burden under Section 195 of the Income-tax Act regarding compliance and furnishing of information of Foreign remittance whether taxable or not. The major changes under the amended Rules are: An Individual is not required to furnish information in Form 15CA and 15CB for remittance which requires no RBI approval.

14 The list of payments of specified in Rule 37 BB which do not require submission of Forms 15CA and 15CB has been expanded from 28 to 33 including payments for imports. A CA certificate in Form No. 15CB is not required to be furnished if payments made to non-residents is not chargeable to tax and the amount of payment during the year does not exceeds Rs. 5 lakh. The Information in 15CA and 15CB is required to be furnished only in case of taxable Foreign Remittance. Such amendment will be effective from Documents required for getting 15CA and 15CB issued by a Chartered Accountant 1. PAN Card of Applicant (Remitter) 2. Invoice for which payment is to be made. 3. No PE Declaration from Non Resident (if applicable) 4. Bank Account Details (Cancelled Cheque) from which payment is to be made 5. BSR Code (Branch code of bank from which payment is to be made. 6. Digital Signature of Remitter. Form 15 CA & Form 15CB Requirement w.e.f 01/04/2016 for foreign payments Flow Chart Analysis

15 Managerial Remuneration under Companies Act 2013 This article highlights Who are Key Managerial Persons What is Remuneration Remuneration payable in case of No profit or inadequate profits Penalty in case of Non compliance CA Puneet Mehra

16 Managerial Remuneration under Companies Act 2013 Introduction Just as profits drive business, incentives drive the managers of business. Not surprisingly then, in a fiercely competitive corporate environment, managerial remuneration is an important piece in the management puzzle. While it is important to incentivize the workforce performing the challenging role of managing companies, it is equally important not to go overboard with the perks and the pay. In India, to keep a check on unnecessary profit squandering by companies and, at the same time, to ensure adequate and reasonable compensation to managerial personnel, the law intervenes to do the balancing act. Section 196 deals with appointment of Managerial Personnel and is applicable to private companies and public companies both. Whereas Section 197 which transacts with remuneration payable to managerial personnel is applicable to public companies only. Schedule V is partly applicable to private companies (i.e. in relation to Part I that transacts with appointment) and partly not applicable to private companies (i.e. Part II that transacts with remuneration). Who are Key Managerial Persons The Companies Act, 2013 has for the first time recognized the concept of Key Managerial Personnel. As per section 2(51) key managerial personnel, in relation to a company, means i. the Chief Executive Officer or the managing director or the manager; ii. the company secretary; iii. the whole-time director; iv. the Chief Financial Officer; and v. such other officer as may be prescribed. Definition of Managerial Remuneration The term Remuneration is defined under section 2(78) of the Companies Act,2013 which says that remuneration means any money or its equivalent given or passed to any person for services rendered by him and includes perquisites as defined under the Income Tax Act, Section 17(2) of Income Tax Act, 1961 has given an inclusive definition of the term perquisite. This clause comprises of eight sub clauses followed by two provisos, and they deal with the following perquisites: 1. Value of rent free accommodation provided to the assessee by his employer. 2. Value of any concession in respect of rent respecting any accommodation provided to the assessee by his employer. 3. The value of any benefit or amenity granted or provided free of cost or at a concessional rate to employee directors; or to employees who have substantial interest and certain specified employees with some exceptions. 4. Sums paid by the employer in respect of any obligation which, but for such obligation, would have been payable by the assessee. 5. Sums payable by the employer to effect an assurance on the life of the assessee employee or to effect a contract for an annuity. 6. W.E.F assessment year , value of securities / sweat equity shares allotted or transferred by the employer or former employer to the employee. 7. W.E.F assessment year a contribution made by an employer to an approved superannuation fund to the extent it exceeds Rs 1 lakh. 8. Value of any other fringe benefit or amenity as may be prescribed. 9. The first proviso states that certain medical benefits are not treated as perquisites in certain specific situations. We can say that definition of remuneration as well as perquisites are inclusive in nature and hence it covers every amount that the company pays or spends for or for the benefit of a Director, in whatever form and by whatever name. Moreover, any remuneration for services rendered by any such director which are of professional nature shall not be included in the managerial remuneration. Further, a director may receive remuneration by way of a fee for each meeting of the Board, or a committee thereof attended by him.

17 Remuneration to Managerial Personnel Section 197 of the Companies Act, 2013 prescribed the maximum ceiling for payment of managerial remuneration by a public company to its managing director whole-time director and manager which shall not exceed 11% of the net profit of the company in that financial year computed in accordance with section 198 except that the remuneration of the directors shall not be deducted from the gross profits. Further, the company in general meeting may, with the approval of the Central Government, authorize the payment of remuneration exceeding 11% of the net profits of the company, subject to the provisions of Schedule V. The net profits for the purposes of this section shall be computed in the manner referred to in section 198. The remuneration payable to any one managing director or whole time director or manager shall not exceed 5% of the net profits of the company and if there are more than one such director remuneration shall not exceed 10% of the net profits to all such directors and manager taken together. Except with the approval of the company in general meeting, the remuneration payable to directors who are neither managing directors nor whole-time directors shall not exceed, 1% of the net profits of the company, if there is a managing or whole-time director or manager; 3% of the net profits in any other case. Remuneration by a Company having no Profit or Inadequate Profit If, in any financial year, a company has no profits or its profits are inadequate, the company shall not pay to its directors, including managing or whole time director or manager, any remuneration exclusive of any fees payable to directors except in accordance with the provisions of Schedule V and if it is not able to comply with Schedule V, with the previous approval of the Central Government. In cases, where Schedule V is applicable on grounds of no profits or inadequate profits, any provision relating to the remuneration of any director which purports to increase or has the effect of increasing the amount thereof, shall not have any effect unless such increase is in accordance with the conditions specified in that Schedule and if such conditions are not being complied, the approval of the Central Government had been obtained The percentages aforesaid shall be exclusive of any fees payable to directors for attending the meeting of the board/committees or for such other purposes as decided by the board. Remuneration to Directors in other Capacity [Section 197(4)] The remuneration payable to the directors including managing or whole-time director or manager shall be inclusive of the remuneration payable for the services rendered by him in any other capacity except the following: (a) the services rendered are of a professional nature; and (b) in the opinion of the Nomination and Remuneration Committee (if applicable) or the Board of Directors in other cases, the director possesses the requisite qualification for the practice of the profession. Remuneration Drawn in Excess of Prescribed Limit If any director draws or receives, directly or indirectly, by way of remuneration any such sums in excess of the limit prescribed or without the prior sanction of the Central Government, where it is required, he shall refund such sums to the company and until such sum is refunded, hold it in trust for the company. [Section 197(9)] The company shall not waive the recovery of any sum refundable to it under sub-section 9 mentioned above, unless permitted by the Central Government. [Section 197 (10)] Insurance Premium as Part of Remuneration Where any insurance is taken by a company on behalf of its key managerial person for indemnifying any of them against any liability in respect of any negligence, default, misfeasance, breach of duty or breach of trust for which they may be guilty in relation to the company, the premium paid on such insurance shall not be treated as part of the remuneration payable to any such personnel. However, if such person is proved to be guilty, the premium paid on such insurance shall be treated as part of the remuneration.

18 Managerial Remuneration under Schedule V (Part II) Section I: Remuneration by Companies having Profits A company having profits in a financial year may pay remuneration to its managerial persons in accordance with Section 197. Section II: Remuneration by Companies having no profits or inadequate profits without Central Government approval Where in any financial year during the currency of tenure of a managerial person, a company has no profits or its profits are inadequate, it, may, without Central Government approval, pay remuneration to the managerial person not exceeding the higher of the limits under (A) and (B) below: (A) : Where the effective capital is Limit of yearly remuneration payable shall not exceed (Rs) Negative or less than 5 Crore 30 Lakhs 5 Crore and above but less than 100 Crore 42 Lakhs 100 Crore and above but less than 250 Crore 60 Lakhs 250 Crore and above 60 Lakhs plus 0.01% of the effective capital in excess of Rs. 250 Crore If a special resolution is passed by the shareholders, the above limits shall be doubled. (B) : In the case of managerial person who was not a shareholder, employee or a Director of the company at any time during the two years prior to his appointment as managerial person- 2.5% of the current relevant profit. If a special resolution is passed by the shareholders, this limit shall be doubled. Calculation of Net Profit for the purpose of Managerial Remuneration (Section 198) Section 198 of the Companies Act, 2013 lays down the manner of calculations of net profits of a company any financial year for purposes of Section 197. Sub- Section (2) specifies the sums for which credit shall be given and sub-section (3) specifies the sums for which credit shall not be given while calculating the net profit. Similarly, sub-section (4)/(5) specifies the sums which shall be deducted/not deducted while calculating the net profit. Recovery of Managerial Remuneration in certain cases (Section 199) This is a new provision introduced in the new Act. It provides for recovery of remuneration including stock options received by the specified Managerial Personnel, where the benefits given to them are found to be in excess of what is reflected in the restated financial statements. It states that without prejudice to any liability incurred under the provisions of this Act or any other law for the time being in force, where a company is required to re-state its financial statements due to fraud or non-compliance with any requirement under this Act and the rules made there under, the company shall recover from any past or present managing director or whole-time director or manager or Chief Executive Officer (by whatever name called) who, during the period for which the financial statements are required to be re-stated, received the remuneration (including stock option) in excess of what would have been payable to him as per restatement of financial statements. Penalty Clauses If any person contravenes the provisions of the section 197, he shall be punishable with fine which shall not be less than one lakh rupees and may extend to five lakhs rupees If a company or any officer of a company or any other person contravenes any of the provisions of this Act or the rules made there under, the company and every officer of the company who is in default or such other person shall be punishable with fine which may extend to ten thousand rupees, and where the contravention is continuing one, with a further fine which may extend to one thousand rupees for every day after the first during which the contravention continues.

19 Contact Us Contact Name Mobile Mr. Anuj Somani Mr. Bhuvnesh Maheshwari Head office: Branch Offices: Network Offices: DELHI MUMBAI BANGALORE Delite Cinema Hall GHAZIABAD BHOPAL 3 rd Floor, Gate No. 2, New Delhi, India GURGAON BUBNESHWAR SILIGURI CHENNAI CHENNAI KOLKATA Disclaimer This material and the information contained herein prepared by the authors is of a general nature and does not exhaustively deal with the subject discussed. Although the authors have put their earnest effort in providing accurate and appropriate information, the article is not intended to be relied upon as the sole basis for any decision which may affect you or your business. The authors recommend you take professional advice before acting on specific issues. is neither responsible for any views, opinions and statements made by the authors nor is liable for consequences, if any, arising from actions based on such views or opinion.