Dutch authorities have provided details on the steps employers must take when pay for a highly skilled migrant drops below the required salary minimum because the migrant is on leave or participating in a strike.

In the Netherlands, Highly Skilled Migrant permit holders can drop below required salary minimums without adverse impacts to their immigration status if they make use of statutory leave, or their right to strike, on the condition that the employer provides notice of the drop in salary in time to the Immigration and Naturalisation Service (IND).

In its recent newsletter, the IND confirmed that this applies to the following types of leave that are specified in the Dutch Work and Care Act (Wet Arbeid en Zorg or WAZO):

  • Maternity leave.
  • Parental leave.
  • Adoption and foster care leave.
  • Additional maternity / paternity leave.
  • Short- or long-term care leave

The conditions that must be met when an employee makes use of one of the leaves listed above are:

  • The employer must notify the IND of the statutory paid or unpaid leave. The employer must include information about the impact the leave will have on the highly skilled migrant’s pay.
  • The employer must notify the IND using the IND’s business portal or by the notification form for employment-related residence purposes (recognized sponsor).
  • The IND must receive this notice no more than four weeks from the start of the leave or the strike.

In addition, for leave under the Dutch Work and Care Act, the highly skilled migrant and employer must be able to demonstrate that the migrant is entitled to paid or unpaid leave. In cases involving care leave, the employer and/or migrant must be able to show that the care is necessary. Employers must document the employee’s leave, keep this documentation in their records and be able to produce the records if requested by the IND.

The IND also confirmed in its newsletter that pay for highly skilled migrants can drop below the required salary minimum if the highly skilled migrant exercises his or her right to strike. In such cases, there will be no adverse impacts on residence status on the condition that the employer provides notice of participation in the strike and the impact on the employee’s salary within four weeks. This notice must be provided through the business portal or the required notification form.

Analysis & Comments: Employers should be sure they have the internal procedures in place to meet the conditions listed above. Employers must be sure to document highly skilled migrants’ leave properly and provide records if requested. Deloitte is able to assist employers as needed.

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. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

The Netherlands has imposed additional COVID-19 restrictions, including a ban on travel from certain countries and new testing requirements.

Key Points:

  • On Jan. 23, flights from Cabo Verde, the Dominican Republic, South Africa, the United Kingdom and several South American countries were suspended. Travelers from the United Kingdom are also banned from entering the country through water ports of entry.
  • Travelers are required to present certain declarations and negative test results.
    • The declarations that must be presented are (1) a Health Declaration Form before departure for all individuals traveling by plane and (2) a Negative Test Declaration for non-EU/non-Schengen Area nationals traveling from a high-risk non-EU/non-Schengen Area country.
    • Travelers from high-risk countries who are not subject to the flight ban must present (1) a negative PCR COVID-19 test that was taken no more than 72 hours before the traveler’s arrival and (2) a negative rapid test result which must be no older than four hours at the time of boarding. The PCR test results must be in Dutch, English, French, German or Spanish. The rapid test result may also be presented in Italian or Portuguese.
  • Business travelers, short-term Highly Skilled Migrants and students staying 90 days or less are no longer exempt from the EU travel ban and cannot enter the Netherlands at this time. An exemption exists for those who can show proof of a work permit, proof of school admission or a note verbale for business travelers, issued before Jan. 23, 2021.

Additional Information: Travelers from safe countries, children under the age of 13 and cross-border workers are not subject to the COVID-19 testing requirement and declaration requirement for entry. The flight ban will in principle apply until Feb. 23, 2021.

Analysis & Comments: The new restrictions are meant to slow the spread of COVID-19 variants and may further complicate business travel to the Netherlands at this time. 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. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

 

IMPACT – HIGH

Beginning Dec. 15 at 6 p.m. CEST, travelers arriving from countries not on the European Union’s list of safe countries will have to have negative COVID-19 test results in order to gain entry to the Netherlands.

Key Points:

  • Negative test results from a COVID-19 PCR test will be required for entry for passengers coming from countries that are not on the EU safe countries list and who qualify for an exception to travel to the Netherlands.
  • The test result must be shown in hard-copy, must have been taken no more than 72 hours before entry and must include the name of the traveler, lab information and the date and time of the test. This information must be in Dutch, English, French, German or Spanish.
  • Travelers must also submit a signed Negative Test Declaration and a Health Declaration Form.
  • Tests are not required from anyone traveling within the EU/Schengen Area. Nor are they required from travelers under the age of 13.
  • Dutch citizens, residents and their family members are exempt from the testing requirements. So are cross-border workers, travelers transiting through the Netherlands and a limited number of others. A complete list of exemptions is available here.
  • The list of countries on the EU’s safe list is subject to change, but currently includes Australia, Japan, New Zealand, Rwanda, Singapore, South Korea, Thailand and Uruguay. The ban on travel from China will be lifted once China allows entry to EU nationals.

Analysis & Comments: Travelers who have not taken a test before their arrival to the Netherlands will not be allowed entry into the country. Employers and workers should make arrangements to meet entry requirements. 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? The Dutch government has set 2021 salary thresholds for high-skilled foreign workers.

What does the change mean? Beginning Jan. 1, the minimum monthly salaries will be as follows:

  • Highly skilled migrants 30 years or older: €4,752.
  • Highly skilled migrants younger than 30 years: €3,484.
  • Highly skilled migrants (recently graduated): €2,497.
  • European Blue Card Holders: €5,567.

Background: The salary thresholds are indexed annually. The minimums set for 2021 represent an increase of about 3 percent over current thresholds in each category. In order to meet the salary threshold, employers may include monthly salary components that are gross, guaranteed, and paid directly into the bank account of the employee. In-kind benefits or wages that are not guaranteed, such as performance bonuses, cannot be included to meet the monthly salary threshold.

Analysis & Comments: The new salary thresholds apply to applications filed after Dec. 31. For applications submitted in 2020, the current salary thresholds will apply.

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.

 

 

IMPACT – HIGH

Nationals of the United Kingdom who qualify as frontier workers can now submit an online application with the Dutch Immigration Authorities (IND) to obtain a Frontier Worker’s Document. The Frontier Worker’s Document proves workers have the right to continue to working in the Netherlands beyond Dec. 31, 2020, the end of the Brexit transition period.

Key Points:

  • U.K. nationals employed by an employer in the Netherlands, and registered self-employed U.K. frontier workers legally residing outside the Netherlands may be eligible for a Frontier Worker’s Document.
  • All other U.K. national non-residents of the Netherlands (e.g., individuals working in the Netherlands on an assignment basis, posted employees or business visitors) will require a separate work permit to be authorized to work in the Netherlands as of Jan. 1, 2021.
  • As from Jan. 1, 2021, U.K. nationals will require a Dutch residence permit to stay in the Netherlands for more than 90 days. The Frontier Worker’s Document is not a residence permit. Therefore, U.K. nationals can only stay maximum 90 days within 180-day period in the Netherlands (and all other Schengen Area member states).

Background: Under the Withdrawal Agreement, frontier workers secured the right to work in the Netherlands after Brexit. The Netherlands opted to make the application for a work authorization document obligatory for cross-border commuters.

The online application is currently free of charge. The IND requires U.K. nationals to register as a non-resident in the Dutch Civic Register (RNI) as a BSN is required for the application. Once the application is submitted, the IND will take a decision as soon as possible. The IND requires the U.K. nationals’ biometric data in order to create the Frontier Worker’s Document.

The document will be valid for five years and authorizes U.K. nationals to enter and leave and work in the Netherlands. It should be noted that the Frontier Worker’s Document does not authorize U.K. nationals to work in another country.

U.K. nationals not qualifying for a Frontier Worker’s Document, such as U.K. nationals working in the Netherlands while employed by a U.K. employer, require another type of Dutch work authorization. Acquiring a work permit may take three to five weeks after submission of a complete application with the Dutch labor authorities; the Dutch labor market is protected, as a consequence U.K. nationals must meet the applicable salary threshold (2020 figures). Additional work permit conditions apply.

Analysis & Comments: U.K. nationals who are eligible for a Frontier Worker’s Document are urged to submit the application with the IND as soon as possible. Employers should store a copy of the Frontier Worker’s Document in the personnel file. Please contact your Deloitte Immigration professional to determine how to secure work authorization for your U.K. population.

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 Dutch government has added a new category to its list of travel ban exemptions. Effective, Sept. 21, a limited number of non-EU business travelers are exempt from COVID-19 entry restrictions. Travelers must be in possession of a ‘Note Verbale’ issued by a Dutch Embassy in order to travel under this exemption. In order to qualify, the following high-level conditions must be met:

  • Travelers must have a confirmed appointment with a registered company in the Netherlands or with the Netherlands Foreign Investment Agency (NFIA).
  • The appointment must be considered urgent, and the traveler must show a reason why the meeting must take place in person.
  • The appointment must meet at least one of the following conditions:
    • The meeting would result in the creation of at least five new jobs or a minimum investment of €500,000.
    • The visit could result in a foreign investment to add to the Dutch innovation capacity or further digitization of the Dutch economy.
    • The Dutch organization the foreign national is visiting (1) has at least 10 FTE employees and/or €2 million in annual turnover, and (2) the visit is important to the continuation of daily operations, maintenance, the creation of jobs or growth in the company’s annual turnover.

Additional Information: Travelers who meet this exemption are subject to all other Dutch visa and COVID-19 entry rules and regulations.

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. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

Employers that offer “pick-and-mix” reward structures are reminded that residence permit holders must receive gross wages (not net compensation) that meet applicable minimum salary requirements.

Key Points:

  • Dutch employers often use a pick-and-mix reward scheme that allows employees to exchange gross salary for net benefits or a provision. In principle, the tax liability will be reduced by substituting a portion of their wages with other forms of compensation. For example, an employee may be able to exchange a year-end bonus (which is taxable) for a fitness subscription.
  • While these reward structures have tax benefits, they can pose problems for employees on residence permits that have a minimum salary requirement. For these employees, gross wages must meet applicable salary minimums. Those whose gross wages do not meet the salary minimum could have their immigration status jeopardized, regardless of their net compensation after non-wage benefits are considered.
  • Among the foreign nationals who could be affected are those holding Highly Skilled Migrant permits, EU Blue cards, ICT directive permits, combined permits for residence and work (GVVA permits) and any other residence permit that requires a minimum salary.

Analysis & Comments: It is important that any foreign nationals holding one of the residence permits listed above meet the applicable minimum salary threshold before any form of compensation other than gross wages is considered. HR departments should keep this in mind before approving pick-and-mix requests from affected employees. Not meeting the applicable salary threshold will be a ground for the revocation of the residence permit, and employers are encouraged to work with Deloitte to ensure they are satisfying the requirements.

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 – MEDIUM

What is the change? The Immigration and Naturalisation Service (IND) has clarified that the immigration status of residence permit holders will not be jeopardized if they drop below the normal pay threshold while on leave after their partner gives birth.

What does the change mean? The minimum threshold can drop to 70% of the normally required pay for people who take leave because their partner has given birth. This is consistent with a new partner birth leave policy that took effect July 1 that provides for five weeks of additional pay, with compensation set at 70% of the normal salary.

  • Effective date: July 1, 2020.
  • Visas/permits affected: Highly Skilled Migrant permits, EU Blue cards, ICT directive permits and combined permits for residence and work (GVVA permits) and any other residence permit that requires a minimum salary.
  • Who is affected: Employers and foreign nationals who hold a residence permit that requires a minimum salary.
  • Next steps: Employers should be sure they have protocols in place to notify the IND in cases where residence permit holders’ compensation drops below the normal minimum because they are taking partner birth leave.

Background: The Netherlands implemented an expanded partner birth leave policy on July 1. Up until this date, partners were afforded one week at full pay (paid by the employers) after their partner gave birth to a child. Partners can now take an additional five weeks of leave during the first six months after the child’s birth and will be compensated 70% of their normal pay (capped at 70% of the standard maximum wage and paid by the Employee Insurance Agency, rather than the employer). Additional information is available here.

Analysis & Comments: The IND recently clarified that partner leave is a legal right, and that residence permits would not be jeopardized in cases where pay fell below the normal minimums for partners on leave. That said, the IND will require employers to notify them when a residence permit holder’s pay does drop below the normal minimum because they are on partner birth leave. Failure to provide proper notice may lead to a warning and, after multiple violations, fines.

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

The Department of Home Affairs has updated travel restrictions for citizens, permanent residents and foreign nationals in certain situations.

Key Points:

  • Foreign nationals who have traveled via or are from high-risk countries continue to be restricted from entry. According to a notice published by the Minister of Home Affairs on July 3, foreign nationals who are barred from entry may apply for an exemption in writing to the Minister demonstrating exceptional circumstances. The request must include a copy of their passport and temporary residence visa (unless they are visa exempt or their visa was withdrawn under the COVID-19 directive). Those allowed entry will be subject to appropriate screening and quarantine.
  • International travel is now allowed for South African citizens or permanent residents whose place of work, residence or study is outside the country.
  • South African citizens planning to leave the country must provide the following documents to the Department of Home Affairs at least five working days in advance of the intended date of travel:
    • A copy of their valid South African passport.
    • A letter of confirmation of admissibility or the validity of the visa or permit, issued by the relevant diplomatic or consular mission or authority of the receiving country.
    • If transiting through another country, proof of permission to transit.
    • Proof of the means of travel and the intended date of departure.
  • South African citizens and permanent residents who are out of the country and wish to return will be subject to screening and examination.

Background: South Africa began relaxing lockdown restrictions last month in a phased approach.

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.

The Netherlands has closed the consular departments of its embassies worldwide in response to the COVID-19 pandemic.

Key Points:

  • Consular services are canceled until at least April 6.
  • The government has imposed a 30-day travel ban.
  • Exemptions to this ban apply to (1) EU nationals, EEA nationals, U.K. nationals, and Swiss nationals and their family members; (2) third-country nationals holding a residence card (including a Highly Skilled Migrant residence permit) or a residence permit in accordance with Directive 2003/109/EC (LTR Directive); (3) third-country nationals who derive their right of residence from other European Directives (e.g., EU Blue Card, ICT Directive residence permit) or from the national law of a member state; (4) holders of a long-stay visa, including persons with a temporary residence permit (MVV) (the MVV exemption is under discussion with the relevant authorities); and essential staff.

Full travel bans apply to flights departing from: China (including Hong Kong), Iran, Italy and South Korea.

Background: The Netherlands’ decision to enforce the travel ban follows the European Union’s recent agreement to halt most travel to the EU for 30 days.

Analysis & Comments: Employers must be prepared for significant disruptions to employee mobility and should anticipate further restrictions. The response to the COVID-19 pandemic continues to develop, and Deloitte will provide additional updates as information becomes available.

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.