IMPACT – MEDIUM

Thailand’s Ministry of Interior has announced the launch of a special tourist visa scheme for long-staying visitors.

Key Points:

·         Effective from Sept. 30, until Sept. 30, 2021, the visas will be made available to long-staying visitors from countries with lower COVID-19 infection rates, as determined by the Ministry of Public Health.

·         Visa holders will be required to comply with Thailand’s COVID-19 control measures and undergo a local state or hospital quarantine for a minimum of 14 days. They will have to present proof of payment for local state or hospital quarantine and one of the following: a hotel reservation for long-stay purposes, evidence of ownership of a condominium or a house or condominium rental contract.

·         In addition, visa holders must have health and accident insurance coverage that covers the period of their stay in Thailand, with a minimum THB 40,000 coverage for outpatient treatment and a minimum THB 400,000 coverage for inpatient hospital and physician services.

·         Eligible visitors can apply for the special tourist visa at Thai embassies and consulates worldwide. The visa will cost THB 2,000 per 90-day period and will be valid for a single entry. Requests for extension can be made twice, each for an additional 90 days. The special tourist visa cannot be converted to other types of visas.

Analysis & Comments: The special tourist visa scheme will allowed a limited number of travelers to enter the country. The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

Thailand recently extended its ban on inbound commercial flights to mitigate the spread of COVID-19.

Key Points:

  • The inbound commercial flight ban has been extended until further notice. During the extension, foreign nationals will only be permitted to travel for repatriation flights and cargo flights to Thailand.
    • Exceptions exist for the following types of flights:
    • State or military aircraft.
    • Emergency landing flights.
    • Technical landing flights with no passengers disembarking.
    • Humanitarian aid, medical and relief flights.
    • Repatriation flights.
    • Cargo flights.
  • Exceptions also exist for the following types of aircraft passengers:
    • Thai nationals.
    • Individuals with permission or an invitation from the Prime Minister. Individuals with permission from an authority responsible for emergency management who are considered necessary for the resolution of emergencies.
    • Individuals performing diplomatic or consular missions or who are working for international organizations.
    • Foreign government representatives who are performing their duties in Thailand.
    • Representatives of international agencies who are performing necessary duties within Thailand and their family members.
    • Persons transporting necessary goods who will return immediately after completing their work.
    • Crewmembers with a need to enter the country because of their work who also have a specific return date and time.
    • Non-Thai nationals married to a Thai national or who are parents or children of a Thai national.
    • Non-Thai nationals with a valid permanent resident certificate or who have permission to establish residency.
    • Non-Thai nationals with work permits or permission from government agencies to work in Thailand, including their spouse and/or children.
    • Non-Thai national students at educational institutions approved by authorities in Thailand. This exception includes the students’ parents or guardians.
    • Non-Thai nationals who require medical care in Thailand and persons traveling with them. This exception does not include medical care for COVID-19.
    • Non-Thai nationals who have a special arrangement with a foreign country.
  • The foreign nationals listed above must enter 14-day quarantine at their own expense in an Alternative State Quarantine (ASQ) upon entering the country.
  • Foreign nationals referred to in the list above must communicate with a Royal Thai Embassy/Consulate before their departure date to apply for a Certificate of Entry (COE).
  • The local Thai Embassy in the departure country should confirm the list of required documents used to obtain the Certificate of Entry.
  • Foreign nationals are required to present the following documents to enter Thailand:
    • A Certificate of Entry into the Kingdom of Thailand (COE).
    • A valid non-immigrant visa.
    • A completed and signed Declaration form.
    • A Fit to Fly health certificate.
    • A COVID-19 medical certificate with a negative lab result from an RT-PCR test issued within 72 hours before departure.
    • A copy of a health insurance policy with minimum coverage of US$100,000 for COVID-19 in Thailand.
    • Documents used to enter the country such as the following:
      a valid work permit, or a letter of work permission from a relevant government agency or a pre-work permit approval letter issued by the Department of Employment (DOE), Board of Investment (BOI), or Industrial Estate Authority of Thailand (IEAT). For students, a confirmation letter issued by the applicant’s school is required.
    • Confirmation of a 14-day Alternative State Quarantine (ASQ) reservation at the applicant’s expense and arrangement of personal flight tickets.
    • A T.8 form.
    • An in-country itinerary so the applicant can be tracked within Thailand.

Analysis & Comments: The travel ban extension and requirements for foreign national entry will restrict and slow movement into Thailand. Employers should take note and arrange plans for affected employees accordingly. The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? Requirements for local residence notification of foreign nationals with the Immigration Bureau or Provincial Immigration Offices have been updated.

What does the change mean? Landlords, property owners and hotel managers will only have to submit local residence notification for a foreign national once, if they are staying at the same residence address and under the same contract.

  • Implementation time frame: June 30.
  • Visas/permits affected: TM.30 local residence notification.
  • Who is affected: Foreign nationals holding a visa in Thailand, and landlords, property owners and hotel managers.
  • Next steps: Landlords, property owners and hotel managers need only notify the Immigration Bureau or Provincial Immigration Offices of a foreign national’s residence once if he or she is staying at the same residence address and staying under the same contract.

Background: Previously, notification was required within 24 hours of the foreign national having taken up residence. This was required even when the foreign national returned to the same address where he or she previously resided, regardless of whether the temporary departure was for domestic or international travel. The new regulation requires that it be submitted only once, within 24 hours of the foreign national’s taking up residence to begin a new term of stay (such as a new rent contract, or a new check-in at the hotel) at the same address, or at a new address.

Additional information: Deloitte will alert clients to additional changes or restrictions as information becomes available.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

The Board of Investment has issued the process for a BOI-registered company to make a special request to bring foreign national employees to Thailand regardless of whether or not they already hold a work permit/permission to work (BOI Pre-Visa Approval). The process can take up to 20 working days.

The following documents are required for this process:

  • Letter from the company citing the necessity to bring the foreign national employee to work for the company in Thailand. The letter must also include the following information:
    • Reason for bringing foreign national employee to work in Thailand.
    • Loss or negative impact on company if it does not bring the foreign national employee to work in Thailand. If the contingent loss or value thereof can be demonstrated, this should be provided as well.
    • What stage of BOI project the company is operating in.
    • The specific expertise of the foreign national employee that the company requires.
    • Intended Thailand arrival date/flight information (if applicable).
  • Copy of passport. If the foreign national employee already has a visa under the BOI privilege, copy of the most updated BOI visa must be provided.
  • Copy of work permit (if applicable).
  • Copy of Pre-Visa Approval (if applicable).
  • Copies of evidence and/or contracts showing the loss or negative impact on the company would experience if the foreign employee was no permitted to enter Thailand. This may be requested by the officers after the submission, as they deem necessary.

Additional information: Restrictions on international commercial flights to Thailand have been extended until June 30. Foreign national employees are still required to obtain the following before entering Thailand: a completed and signed “Declaration Form” obtained from the Thai Embassy/Consulate; a “Fit to Fly” Health Certificate issued within 72 hours before departure; a copy of their Health Insurance Policy with at least US$100,000 coverage for COVID-19 in Thailand. Upon arrival in Thailand, foreign nationals must go into 14-day quarantine in a government-designated Alternative State Quarantine (ASQ) at their own expense and comply with all health regulations under Thailand’s Emergency Decree.

Analysis & Comments: The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.

IMPACT – HIGH

Thailand recently extended the suspension of all incoming international flights again to mitigate the spread of COVID-19.

Key Points:

  • The temporary ban on incoming international passenger flights to Thailand has been extended from June 1 to June 30.
  • There are exceptions for state or military aircraft, emergency landings, technical landings without passengers exiting the plane, repatriation flights, humanitarian aid, medical and relief flights and cargo flights.
  • Passengers on such flights arriving in Thailand will enter a 14-day quarantine and are subject to regulations defined by the Emergency Decree on the State of Emergency.

Background: The temporary flight ban was initially implemented in April. The ban was extended 12 days later until the end of April. At the end of April, it was extended again until the end of May. It has now been extended until the end of June.

Analysis & Comments: Employers should anticipate significant disruptions to employee mobility and all but essential business. The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

The government has banned entry to most foreign nationals and extended the validity of some visas amid the ongoing COVID-19 pandemic.

Key Points:

  • International passenger flights are banned until May 31. Exceptions still apply to certain categories of flights (e.g., humanitarian, cargo, etc.), though those arriving on these flights will be subject to 14-day quarantine and other regulations.
  • Domestic flights will resume May 1; however, airlines must implement strict safety measures during check-in, boarding and after landing.
  • Temporary and long-term visas expiring on or after May 1 will be extended until July 31. No application is required.
  • 90-day reports due from May 1 to July 31 will also be temporarily extended until July 31.
  • Foreign nationals who are permanent residents or who hold a Border Pass are no longer exempted under the latest announcement.
  • Long-term non-immigrant visa holders whose visa will expire between May 1 and July 31 can apply for a visa extension in order to avoid the rush to file applications after July 31. They should also take into consideration work permit renewal timelines, as a valid Non-Immigrant visa may be required to support work permit renewal applications.
  • All visas or 90-day reports which expire or are due on or after July 31 must be promptly extended or reported within the period to be announced by the Thai Immigration Bureau. Failure to do so may result in penalties under the Immigration Act.

Background: Thailand banned international passenger flights effective April 6 and then extended the ban until April 30.

Analysis & Comments: The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.

IMPACT – HIGH

Thailand has extended the temporary ban on inbound international flights to mitigate the spread of COVID-19.

Key points:

  • The flight ban has been extended from April 19 to April 30.
  • There are some of exceptions to the ban for, including for medical and relief flights, repatriation flights, cargo flights, state or military aircraft, emergency landings, technical landings without disembarkation and humanitarian aid. Passengers on these flights may be subject to 14-day quarantine or other measures.

Analysis & Comments. The response to COVID-19 continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

The Thailand government recently implemented a ban on international flights to mitigate the spread of COVID-19.

Key points:

  • All inbound international passenger flights are banned from April 6 to April 18, 2020. For the same period, flight permits for international passenger flights have been cancelled.
  • Exceptions are available for: medical and relief flights, repatriation flights, cargo flights, state or military aircraft, emergency landings, technical landings without disembarkation and humanitarian aid.

Analysis & Comments: The response to COVID-19 continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

What is the change? The Ministry of Labor’s Foreign Workers Administration Office in Bangkok (MOL) closed the services to the general public last month. The MOL will finalize all pending work permit applications, but is no longer accepting new ones.

What does the change mean? Companies (1) with a registered address in Bangkok, (2) with either paid-up capital, or current company assets of less than 30 million baht or (3) with either paid-up capital or current company assets of more than 30 million baht that are applying for work permits for positions below the manager level must now submit all work permit-related applications and notifications to their local Labor Office.

  • Effective date: Immediate.
  • Documents affected: All work permit-related documents.
  • Who is affected: Companies filing work permit-related applications and notifications at the MOL.

Background: Eligible companies as described above had been able to submit work permit applications (including renewals and amendments) and cancelations to the MOL. The local Labor Offices has now taken over work permit-related duties.

Analysis and Comments: Employers should anticipate that processing time lines and document requirements may vary, depending on the individual local Labor Office. It should be noted that other Department of Employment offices under the Ministry of Labor will continue to operate. This change will not affect companies with a registered address in Bangkok and either paid-up capital or current company assets of more than 30 million baht that are applying for positions at or above the manager level. This is because these companies are eligible to use the expedited process at the One Stop Service Center (OSSC). It will also not affect applicants under OSSC-eligible companies that hold manager-level positions or above.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

What is the change? The Immigration Office at the One Stop Service Center (OSSC) and Immigration Bureau at Chaengwattana has announced new requirements for visa applicants.

What does the change mean? Employers submitting initial visa extension and visa renewal applications must submit original receipts from the relevant authorities, confirming that they have requested all supporting documents, paid all government fees and that the documents have been officially certified.

  • Effective date: The change took effect Oct. 17.
  • Documents affected: Certified corporate and tax documents required for submitting visa extension applications through OSSC and the Immigration Bureau at Chaengwattana.
  • Who is affected: Companies filing visa extension applications through OSSC and the Immigration Bureau at Chaengwattana.

Background: Previously, original receipts showing payment of government fees were required to certify a company’s monthly salary withholding tax return (P.N.D.1). The change requires that companies submit the original receipts showing payment of government fees for certification of all the following supporting tax documents. Upon completion of the visa extension process, the immigration officers will return the original receipts to the company. The following documents require an original receipt:

  • Company’s affidavit certified within the last six months by the Ministry of Commerce;
  • List of company’s shareholders certified within the last six months by the Ministry of Commerce;
  • Copy of the previous fiscal year-end audited financial statement, certified by the Ministry of Commerce or Revenue Department;
  • Copy of form for submission of the previous fiscal year-end financial statement to the Ministry of Commerce (Sor.Bor.Chor. 3), certified by the Ministry of Commerce;
  • Copy of the previous fiscal year-end corporate income tax return form (P.N.D.50), certified by the Revenue Department;
  • Copy of the form and tax receipt of monthly salary withholding tax for all Thai and foreign employees (P.N.D. 1) for the most recent months, certified by the Revenue Department;
  • Copy of the form and tax receipt of monthly value added tax return (Por. Por. 30) for the most recent months, certified by the Revenue Department;
  • Copy of the form and tax receipt of monthly special business tax return (Por.Tor.40) for the most recent months, certified by the Revenue Department;
  • Copy of the form and tax receipt of the applicant’s personal income tax return (P.N.D.91/90) for the previous calendar year, certified by the Revenue Department.

Analysis and Comments: Immigration authorities are requiring these original receipts of government fees to verify that the relevant authorities issued the certified documents. The rule does not impact companies that are filing visa applications under Board of Investment (BOI) or the Industrial Estate Authority of Thailand (IEAT) or the Department of Minerals and Fuels (DMF).

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.