Global Immigration Quarterly Newsletter January/February 2016 PricewaterhouseCoopers Legal LLP

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Global Immigration
Quarterly Newsletter
January/February 2016
PricewaterhouseCoopers Legal LLP
Global
Global
Immigration:
Immigration:
Quarterly
Quarterly
Newsletter
Newsletter
Introduction
In this, the first edition of our global newsletter for 2016, we bring you the latest global immigration
updates from across our global network from over the last months of 2015.
Immigration continues to remain a particularly hot topic, centred on current trends both here in
the UK and in mainland Europe. Much is around the tightening of immigration policies with the
possibility of further restrictions and tightening up by governments as they deal with concerns over
local workforce. This is particularly in light of the European migrant crisis which dominated the
headlines over the summer of 2015.
Our ‘Quarterly Focus’ section looks at the migrant crisis, with specific attention to the effects on the
corporate immigration world and how this may impact you and your organisation in being able to
quickly mobilise your workforce across Europe. We also provide an overview and summary of the
European reaction to the attacks in Paris in November 2015.
Whilst this newsletter provides you with an overview of all updates around the globe, please do see
page 21 for a snapshot of the various regional newsletters that are in circulation across our network
and the relevant contacts should you wish to sign up to any of these.
We hope, as always, you enjoy reading through the various updates and please do not hesitate to get
in contact should you have any queries at all or require further information on any of the matters
raised.
Regards,
PwC Legal
Global Immigration Team
Contacts
Julia Onslow-Cole
Partner and Head of Global Immigration
+44 (0)20 7804 7252
[email protected]
Katrina Cooper
Director
+44 (0)20 7804 7715
[email protected]
Frédérique Montalti
Senior Manager
+44 (0)20 7212 4340
[email protected]
Stephan Judge
Senior Manager
+44 (0)20 7212 1094
[email protected]
Claire Pepper
Senior Manager
+44 (0)20 7212 5762
[email protected]
September Weinberger
Senior Manager
+44 (0)20 7804 4772
[email protected]
Stephanie Odumosu
Manager
+44 (0)20 7212 7916
[email protected]
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Global Immigration: Quarterly Newsletter
Quarterly focus
The effect of the migrant crisis on corporate immigration
Amidst debates about humanitarian implications
and political costs, the flow of desperate migrants
which have made their way to Europe from across
the Mediterranean represents a major challenge
to the EU’s immigration policies. Recent statistics
reveal that over 1 million migrants have entered
Europe since January 2015, with other half of
these being Syrians fleeing an intensifying civil
war in their home country.
The United Nations has described this as the
greatest refugee crisis in the last quarter of a
century and it is the largest movement of people
Europe has seen since 1945. This critical situation
has divided EU countries on how to share the
refugee burden, especially in light of an uneasy
economic climate.
We will continue to monitor the situation in all
other European countries and provide further
updates, however please do get in contact should
you have any upcoming moves to Europe which
may now be affected.
Germany
Denmark
Due to the rising number of asylum
seeker applications given the recent
refugee crisis, many immigration
authorities are reporting a several monthlong wait for appointments to apply for a
residence permit.
From 4 January 2016, Sweden have imposed identity
checks on people travelling to Sweden from Denmark and
those travelling by train, bus or ferry will now be required to
present a valid photo ID, to enter. Those who fail to present
the correct documentation will be turned away.
Third country nationals who do not
require an entry visa to enter Germany
for stays over 90 days must apply for a
residence permit before they are able to
commence work. As there are significant
delays in securing appointments, we
recommend that though not required by
law, these nationals obtain an entry visa
from the German Consulate in their home
country.
This entry visa will allow applicants to
commence working in Germany from the
date of arrival and they can then obtain
the residence permit at a later date,
within the validity of the visa.
Denmark have also increased controls at its German border
to try and restrict the number of refugees entering the area.
These controls are expected to be in place for 10 days,
though it is possible that the controls will be extended after
this period.
Long queues are expected at the borders and so travel
should be planned accordingly.
Belgium
Belgium are in the process of introducing a new law which
will reduce the current waiting time between a request for
asylum and access to a Belgium work permit. The current
processing time is 6 months, however the new legislation
will reduce this processing time to 4 months.
From a relocation perspective, there have also
been signs of potential delays in clearing goods
or transiting through some locations throughout
South East and Central Europe as a result of the
increased burden.
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Global Immigration: Quarterly Newsletter
Quarterly focus
Reaction to the Paris attacks in November 2015
Following an emergency meeting in
Brussels on 20 November 2015 between
European Union ministers, stricter border
security measures have been confirmed,
ensuring “systematic controls” on all
individuals entering the Schengen area.
Previously, EU nationals were subject to
minimal identification procedures when
entering the Schengen area. The new
security measures will enforce verification
of biometric information and systematic
document checks against criminal and
security databases. These measures apply
to both EU and Non-EU citizens entering
the Schengen area and biometric data
collection and a personal appearance
will now be a mandatory part of the visa
application process for Germany, Italy,
Portugal and Netherlands.
The process will be similar to what is
already in place for visas to France, Spain
and Switzerland.
Since the Paris attacks, checkpoints have
also been implemented on major routes
between France and Belgium, where
individuals are subject to passport checks.
This comes after Germany, Austria,
Sweden and Hungary reinstated internal
border controls in order to control the
influx of migrants this summer.
The European Commission has agreed
to reform the Schengen border code in
the coming weeks to allow checks at
all external borders, for all travellers
(including EU nationals). It is anticipated,
however, that the reform may take months
to finalise. Currently, Police are allowed
to make targeted ‘security’ checks on the
border and emergency border controls can
be imposed for up to 30 days only.
The European Commission have now
formally submitted their proposal for draft
legislative measures to help manage the
European Union’s external borders. The
proposed measures include the creation
of a European Border and Coast Guard
agency and also the introduction of
systematic checks against all travellers
entering or exiting the Schengen Area.
The European Border and Coast Guard
would establish an agency that will
monitor and analyse immigration into the
European Union (EU) and it would also
establish a border guard’s reserve that
can be deployed, if and when required.
There would be an introduction of the
mandatory systematic checks of EU
nationals to ensure that those entering the
Schengen Area do not present a threat.
At present, only seven of the 26 Schengen
states have re-introduced temporary
controls at their internal borders since
September 2015. These are Austria,
France, Germany, Denmark, Malta,
Norway, Slovenia and Sweden. This
may be set to change depending on the
outcome of discussions between EU
officials in the coming weeks and months.
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Global Immigration: Quarterly Newsletter
Countries
ÆÆ Argentina
ÆÆ Australia
ÆÆ Azerbaijan
ÆÆ Belgium
ÆÆ Brazil
ÆÆ Canada
ÆÆ China
ÆÆ Colombia
ÆÆ Republic of Congo
(Congo-Brazzaville)
ÆÆ Czech Republic
ÆÆ Finland
ÆÆ Germany
ÆÆ Greece
ÆÆ Hong-Kong
ÆÆ India
ÆÆ Ireland
ÆÆ Israel
ÆÆ Malaysia
ÆÆ Mexico
ÆÆ Netherlands
ÆÆ New Zealand
ÆÆ Norway
ÆÆ Poland
ÆÆ Russia
ÆÆ Saudi Arabia
ÆÆ Singapore
ÆÆ Spain
ÆÆ Switzerland
ÆÆ Turkey
ÆÆ UAE
ÆÆ UK
ÆÆ USA
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Global Immigration: Quarterly Newsletter
Your country information
Argentina
Where a foreign national is not currently
residing in their country of birth, the
Immigration Authority is now requiring
that a police certificate issued by all
countries where the individual has resided
over the last three years is submitted with
their work visa application.
What does this mean for you as an
employer?
For those affected by this, we will need
to ensure that assignments are planned
well in advance to allow sufficient time to
secure this additional documentation.
Australia
The Australian Taxation Office (ATO)
has commenced a data matching review,
focused on temporary visa subclasses,
as a means of checking individual and
employer compliance with taxation
obligations. The data matching will
primarily cover subclass 457, 400 and
417 working holiday visas, and will check
records for visa holders and sponsors from
the financial year 2013-14, to the financial
year 2016-17. Where an issue of noncompliance with taxation obligations is
identified, the ATO will have an obligation
to report these findings to the Department
of Immigration as ‘adverse information’
which may impact on an employer’s ability
to continue accessing the temporary and
permanent visa programs.
A recent amendment to the Migration
Regulations has introduced an exemption
to the six month employment restriction
for au pairs and also in other limited
circumstances. As a result of these
changes, a total 12 month employment
period may be approved for au pairs who
can demonstrate they have worked for a
family with young children for at least six
months.
In September 2015, China was added to
the list of eligible countries for the Work
and Holiday (462) visa. To be eligible to
participate in the program, the applicant
must be 18 to 30 years of age and hold a
valid passport from the People’s Republic
of China. Chinese passport holders will not
be eligible for electronic processing and
will be required to lodge their applications
in person.
Further, also in September 2015, the
Australian Department of Immigration
will no longer issue visa labels except in
limited circumstances. In lieu of this, an
individual’s visa status and work rights
can be checked online through the Visa
Entitlement Verification Online (VEVO)
system
The Australian Government has also
recently introduced a further measure
designed to help protect temporary visa
holders from exploitation or unsavoury
employment practices. This has included
providing clearer information in visa grant
notices as well as launching a new ‘Pay
and Conditions Tool’ (PACT) which will
allow all Australian workers to check that
their pay rates meet industry/occupation
standards.
What does this mean for you as an
employer?
With the tax authorities and
immigration authorities now formally in
communication, maintaining compliance
on both these fronts will be more
important than ever. There is also now
greater flexibility for foreign au pairs
working abroad
Azerbaijan
Following a recent change to the rules,
upon arrival to Azerbaijan, all foreign
citizens who intend to stay in country
for more than 10 days are required to be
registered at their place of stay in the State
Migration Service (SMS).
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Global Immigration: Quarterly Newsletter
Though all EEA nationals are, in principle
exempt from the obligation to hold a work
permit in order to legally work in Belgium,
for some of the newer EEA countries, such
as Croatia, transitional measures were in
place. These transitional measures ended
in July 2015 and so a work permit is no
longer required.
Previously, foreign nationals were
permitted to stay in Azerbaijan without
registering for up to 3 days. Now hotel
or apartment owners should submit the
registration to the SMS either online or in
person. Foreign nationals can also do this
themselves.
There is a penalty of approximately USD
400-500 for anyone who fails to register
within the permitted time frame and the
fine is enforced at the airport. If a foreign
citizen leaves Azerbaijan without paying a
penalty, SMS will put a “Stop” sign against
the name of the foreign citizen in the
unified customer system, and during the
next arrival the foreign national may be
refused entry to Azerbaijan.
Business travellers coming to Azerbaijan
will now be exempt from obtaining a work
permit if the cumulative period of stay is
no more than 90 days in a 12 month period
and whether they are working in any of
the following industries. The mining
industry, the processing industry, the
electricity, gas, steam and air conditioning
supply industry, the information and
communication industry, the finance
and insurance industry, the education
industry, the transport industry or in the
proliferation of contaminated water and
emissions industry.
What does this mean for you as an
employer?
Short-term business travellers to
Azerbaijan should be forewarned of this
this new limit for registering to avoid
any penalties. They now have greater
flexibility on the permitted activities that
they can carry out under business visitor
status provided they are working in the
aforementioned industries and their stay is
more than 90 days in a 12 month period.
Please do reach out to your usual PwC
Legal contact for further details on this if
you have any business travellers who may
fall into this category.
Belgium
From July 2015, Croatian nationals no
longer required a work permit to legally
work in Belgium.
Any non-EU national who has obtained
long term residence status in another
European Union country and has come
to Belgium to occupy certain professions
(limited list of professions drafted by
the regional authorities) will now be
able to obtain a work permit (B type)
within 5 days. They will not need to
comply with the conditions for highly
qualified employees and further labour
market research will not be required to be
undertaken. An authorisation to employ
will be delivered to the employer, which
authorises the individuals to start working
immediately. This is a great example
of collaboration between EU Member
States to create a more unified working
environment for foreign nationals with
work permission in other Member States.
In addition, after 12 months of having
worked in Belgium on this basis, the
individuals are exempt from the obligation
to further hold a Belgium work permit.
What does this mean for you as an
employer?
It will now be much easier to deploy nonEU talent to Belgium in instances where
they have been working in another EU
member state and so this should be taken
into account when reviewing and planning
rotations
Brazil
The long-awaited Brazilian legislative
immigration bill is currently being drafted
by the Legislative Authorities.
Our local team are following the progress
closely and are participating regularly
in discussions around the Bill with the
President of the Bill Commission and the
Rapporteur. This is in particular around
the treatment of dependants/spouses
of temporary workers and the proposal
to grant them automatic work rights in
Brazil upon entry with their spouse (main
temporary work visa holder)
We are also in contact with the members
of the Confederation of the National
Industries– CNI, an influential lobbying
group in Brazil.
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Global Immigration: Quarterly Newsletter
Travel Authorization (eTA). These foreign
nationals must obtain an eTA prior
to entering Canada, unless otherwise
exempted.
An eTA application can be made online
through the Citizenship and Immigration
Canada website (www.cic.gc.ca). Basic
personal information, such as full name,
passport number and email address will
be requested. There will be a CAD$7 fee
associated with this requirement.
What does this mean for you as an
employer?
We will continue to monitor the progress
being made with this Bill and together
with the CNI.
It is anticipated that the Government
will be pressured to act quickly to address
problems caused by the shrinking economy
and rising unemployment in Brazil. As
such, we may see increased scrutiny of all
applications for visa or audits of existing
visas.
Canada
From 15 March 2016, all visa-exempt
foreign nationals (except US citizens) who
fly to or transit through Canada by air
will be required to apply for an Electronic
Once the application is submitted, an eTA
will be issued within a few minutes, in
most cases. The eTA is electronically linked
to the foreign national's passport and is
valid for five years, or until the passport
expires (whichever comes first).
If the application requires further
processing, the applicant will be notified
within 72 hours and provided instructions
on next steps to be taken.
It is important to note that the Canadian
government has the authority to cancel an
eTA at any point in time based on public
policy considerations and inadmissibility
factors. Fraud and misrepresentation on
any application, including when applying
for an eTA, are sufficient grounds for
inadmissibility.
What does this mean for you as an
employer?
Short-term business travellers should be
reminded to factor this new process, and
additionally the cost, into the planning
stages of their trip to ensure that it is
completed ahead of time.
China
The Ministry of Public Security in
Shanghai has recently announced 12 new
exit-entry policies aimed at providing:
•more flexible immigration
arrangements,
•the best residence status for overseas
talent, and
•the most efficient immigration services
This is all in a bid to ensure that top
talent, innovators, and entrepreneurs
are attracted into Shanghai. These new
policies became effective on July 1,
2015. The Exit-Entry Administration
Bureau of the Shanghai Public Security
Bureau also issued details to facilitate the
implementation.
These changes include a simplified
renewal process which means that
following two one year residence permit
renewals, the applicant is then eligible to
renew their permits for upto five years to
avoid yearly renewals. They also include
foreign nationals now being able to apply
for a Z work visa at the port of entry in
Shanghai. If they have already arrived
in Shanghai under another immigration
status, they are now able to apply for
residence permits from within Shanghai.
The process for obtaining Permanent
Residence has also been streamlined and
average processing time is now 6 months.
What does this mean for you as an
employer?
Given the shortage of talent is becoming a
growing concern for many countries and
businesses, it is encouraging that Shanghai
has taken this important milestone to relax
and simplify the immigration process in
many respects.
Though the relevant officers have an
element of discretion over applications,
this is a very welcome move. We would
also advise that careful consideration is
given to corporate tax, individual tax,
foreign exchange, employment law and
other regulatory areas; many pitfalls can
be avoided with careful planning and
consideration at the outset.
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Global Immigration: Quarterly Newsletter
Colombia
Colombian Immigration authorities
(Migración Colombia) have recently
launched the “System of Information for
the Report of Foreigners” (SIRE), a new
online system used to notify and register
information on foreign nationals employed
in Colombia. New hires and terminations
of contracts with foreign nationals should
be mandatorily reported through the SIRE
and reporting through any other method
will not be considered valid.
The SIRE-establishing resolution
additionally sets forth a new obligation
for employers and sponsors to report
all foreigners entering Colombia with a
visa and/or a temporary permit allowing
them to engage in activities that benefit
a Colombian entity. The visa categories
included under this provision include NE-2
and NE-3 and temporary permits (PIP6PTP6 and PIP7-PTP7.)
What does this mean for you as an
employer?
This new change will now need to
be incorporated into the end to end
immigration and/or human resources
processes within your organisation to
ensure compliance with the authorities on
this new requirement
Republic of Congo (CongoBrazzaville)
To fight against illegal immigration and
help reduce the crime rate in the country,
the Republic of Congo has launched a
sovereignty operation, with a national
aim, called in “lingala” (one of the national
languages): ‘Mbata ya bakolo’, which
means ‘the slap of elders’.
In accordance with the relevant
regulations around the conditions of
entry, stay and exit of all foreigners, this
operation consists of checking the identity
of foreigners of all nationalities.
Following some recent audits by the
Congolese immigration services, it has
been identified that certain groups of
foreign workers are obtaining multiple
entry visas instead of full work visas.
These entry visas (multiple or single
entry) do not allow foreign nationals
to work in the Republic of Congo and
instead employees should ensure that they
are obtaining full work visas to remain
compliant. Immigration compliance is
currently being strictly monitored.
dual documents - i.e. residence and work
permit in one) and the main benefit
lies in a much faster lodging procedure
at the embassy and in being able to
avoid the required advanced booking of
appointment at the embassy via electronic
system.
The eligible applicant should have
completed university education (in certain
professions, a high school diploma may
suffice). The program seeks to attract
Czech Republic specialists with specific
What does this mean for you as an
employer?
After Brazzaville, the operation is now
taking place in Pointe-Noire where
identification checks were launched in
public places, as well as in private houses
and in professional places (offices/
companies’ seats, enterprises).
We highly recommend that all foreign
employees are made aware of the need to
have on their person at any given time, all
identification and residence documents
(originals or copies certified by the
consulate).
Any individual who has been checked
and who does not have any supporting
documents justifying or establishing their
identity and compliant stay in Republic of
Congo, will immediately be imprisoned.
Their release will be secured only
following the provision and verification
of the missing/requested administrative
documents. Foreigners found to be
residing illegally will be deported to their
country of nationality.
Czech Republic
A new project has been launched to help
facilitate the visa process for specialists
from Ukraine who have expertise in the
field of production, services or public
sector. In the first phase the project should
cover 500 applicants from Ukraine.
Successful applicants would obtain an
Employee Card or Blue Card (both are
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Global Immigration: Quarterly Newsletter
knowledge or skill sets where high
qualifications are crucial for the job. The
main areas being targeted are the IT and
technology sectors.
In order for the applicant to be able to
utilise the program, the Czech employer
must first be enrolled to the programme
by applying at the Ministry of Industry and
Trade of the Czech Republic. The employer
must:
•Be recommended by one of the Business
bodies
•Be tax resident and registered at least
two years in the Czech Republic with
no debts registered at the relevant
authorities (Financial Office, Social
Security Office, Health Insurance
Companies),
•Be registered as payer of social security
and health insurance,
•Have not have been fined for illegal
employment of foreigners in the last two
years,
•Have employed at least 5 people in the
last two years.
There has been no change to the labour
market requirements and the position
must be first offered to the Czech job
market for Czech and EU citizens (for 30
days). It is only after that it can be offered
to specialists from Ukraine.
What does this mean for you as an
employer?
For those working in these sectors, this
will greatly speed up and make the overall
application process much more efficient
and less labour intensive on the applicant.
This is a great example of measures being
taken to attract highly-skilled and qualified
talent to the country.
Finland
‘Enter Finland’ has been designed in
collaboration with the customers of
the Finnish Immigration Service to try
to ensure that it is as user-friendly as
possible. Enter Finland can be used to pay
the application fee, provide additional
information for submitted applications,
monitor status updates and receive
notifications on an application’s final
outcome.
Individuals applying through Enter
Finland will still be required to attend
a personal appointment at the Finnish
Embassy or Police station. This is a
mandatory step which is necessary to be
able to verify the applicant’s identity and
to submit original copies of the required
documents.
Enter Finland is not yet available for
dependants’ applications, however, there
are plans to further develop the e-service
to extend the online application service.
What does this mean for you as an
employer?
This new move will greatly speed up
the Finnish immigration process and
facilitate and improve the overall assignee
experience.
The Finnish Immigration Service has
recently launched a new online system
(www.enterfinland.fi) for residence permit
applications. The e-service was initially
launched in 2012 for individuals applying
for their first student residence permit
and has since expanded to cover all workrelated residence permit applications,
citizenship application and the registration
of EU nationals.
The minimum gross salary must be 38,529
CZK (approx. 1.430 EUR) per month for
these employees.
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Global Immigration: Quarterly Newsletter
Germany
German immigration authorities are
reporting that significant delays are to be
expected the processing of all immigration
law matters in general, due to the rising
number of asylum seeker applications
given the current refugee crisis.
Immigration authorities are reporting a
several month-long wait for appointments
to apply for a residence permit.
Non-visa nationals who do not require an
entry visa to enter Germany for stays of
over 90 days are typically required to apply
for a residence permit before they are able
to commence work in Germany.
Given the current delays, it is now proving
difficult to get an appointment within a
reasonable timeframe so we would advise
that in urgent cases, the responsible
German Embassy abroad is contacted in
order to apply for a national entry visa for
Germany prior to travelling. This entry
visa will then allow the holder to begin
working in Germany right away.
From November 2015, a new federal
registration law has been implemented
which introduces additional requirements
for residence registration and deregistration.
Anybody moving into a residence in
Germany is required to register their
address at the local town hall within
7-14 days of moving in. According to the
new law, a tenant is now also required to
present a written confirmation from the
landlord/owner which states the name
and address of the landlord/owner, the
name of the tenant, the address of the
apartment being rented and the move-in
or move-out date.
as possible and before the employees’
arrival in Germany to avoid any delays.
Also, to reduce the delay in the start-date
for non-visa nationals, they should obtain
an entry visa from the German consulate
in their home country. This would allow
them to begin working immediately upon
arrival and have 3 months (the standard
validity period of an entry visa) to search
for accommodation and complete the post
arrival steps.
Individuals could face difficulties if their
landlord does not live in Germany and
there is a delay in obtaining the original
confirmation.
Please do not hesitate to reach out to your
usual PwC Legal contact for further details
Due to the delays being caused with the
migrant crisis and also with the new
additional registration requirements, we
could see delays around the completion of
the post arrival process.
If non-visa nationals do not have a rental
contract with the confirmation from the
landlord (or at least a hotel confirmation
and the letter signed by the hotel), they
will not be able to register and complete
the steps necessary to begin working until
this has been completed.
What does this mean for you as an
employer?
Greece
There have been changes to the
requirements for the issuance of residence
permits to those employed by a Greek
company to carry out the role of a Board
of Director/administrator, shareholder/
partner, legal representative and 'highrank' executive (general director, director).
In order to qualify, the Greek company will
now need to employ at least 25 employees.
The above restriction does not apply to
those carrying out these roles in subsidiary
companies or branches of foreign
companies in Greece.
We would recommend that employers
begin the accommodation search as early
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Global Immigration: Quarterly Newsletter
What does this mean for you as an
employer?
We would advise on reviewing the
corporate set up and current headcount
should there be a business need to bring in
foreign nationals to carry out senior roles,
such as the aforementioned, to ensure that
the entity meets this new requirement.
Hong-Kong
From May 2015, the duration of stay
pattern has been relaxed from 1-2-23 years to 2-3-3 years, subject to the
duration of employment contract. For
top-tier entrants, a 6-year extension of stay
will be granted upon approval.
Top-tier entrants are deemed to be those
who are employed as a professional under
the GEP/ ASMTP for no less than 2 years
and have assessable income for salaries
tax of no less than HK$2 million in the
previous year.
For those already admitted, upon approval
of their applications, a 3-year extension
of stay will be granted (or in line with
duration of employment contract). If
applicants fulfil the top-tier entrant
requirements, a 6-year extension of stay
on time limitation only without other
conditions of stay will be granted.
For applicants who do not meet the top
tier entrant requirements upon the instant
extension of stay application, they can
apply for a 6-year of stay at any time at
the point at which they meet the top tier
entrant requirements.
The application form for extension of
stay (form ID91) has been updated and
released by ImmD with immediate effect
on 4 May 2015. Applicants should use the
application with the new form and the
other required documents to the ImmD.
appointment are asked to only attend at
the agreed time with INIS committed to
dealing with such applicants in as speedy
a manner as possible. Those without an
appointment will not be seen at all as the
current visa ticketing system at the public
office will no longer be in operation.
time by way of enhanced systems and
booking facilities.
Appointments are divided into the
following categories:
•Individual appointment: One person
only
What does this mean for you as an
employer?
•Family appointment: Parents and
dependent children
This will mean reduced bureaucracy
given that that extensions of immigration
permission will only be required after
greater time intervals than previously.
•Emergency appointment*: One person
only. (Emergency appointments will
incur an additional €100 administrative
fee on top of the standard visa filing fee.)
Ireland
A new on-line appointments system is now
available for those seeking Irish re-entry
visas. Applicants will no longer be seen
in person at the Irish Naturalisation &
Immigration Service (INIS) in Burgh Quay,
Dublin, without first having booked an
appointment in advance.
The on-line booking facility is open with
immediate effect. Those who make an
The option for postal re-entry visa
applications remains in place and INIS are
requesting that this be considered as the
preferred route if possible.
What does this mean for you as an
employer?
This is another example of immigration
processes becoming more streamlined and
efficient by requiring less of the applicants
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Global Immigration: Quarterly Newsletter
India
delays to any travel.
From January 2016, the High Commission
of India in London will start to issue
Business, Tourist and Entry visas with a
validity of up to five years. Please note
that these five year visitor visas will only
be available for British nationals and
in addition, applicants who have not
previously held an Indian visa are unlikely
to be issued with a visa valid for more than
one year.
Israel
Currently, the processing times for
applications for five years visas are up to
10 working days and there are slightly
increased visa fees for these longer validity
visas. There has also been an additional
change whereby, with immediate effect,
any applications made to the Indian High
Commission on handwritten or nonmachine readable passports will no longer
be accepted.
In the coming months, a dedicated
committee will be established who will
determine the relevant regulations. The
authorities will invite local companies that
wish to serve as one of the pre-approved
technology companies.
What does this mean for you as an
employer?
This change will be beneficial for those
eligible and who have frequent business
travel to India going forward.
Further, we would advise that you advise
any upcoming business travellers to India
from the UK that they ensure that they
have a machine-readable passport to avoid
On 20 October 2015, the Israeli authorities
announced that a new Entrepreneur HighTech visa is to be introduced. This new visa
category will be available to individuals
who wish to work at one of twelve preapproved technology companies. The visa
will be valid for a two year period with an
option to extend if certain criteria are met.
What does this mean for you as an
employer?
For those qualify and who are in the
Technology sector, this could help
streamline your immigration programme
given these permits will be valid for a
longer period than the usual B-1 work
permit allowing cost savings and greater
efficiencies
Malaysia
Companies that are successfully registered
with headquarters of the Malaysian
Immigration Department, the Expatriate
Services Division (“ESD”), are now
able to apply for permission to allow
international students to undertake shortterm placements on a Social Visit Pass in
Malaysia under mobility programs. The
types of mobility programs covered by
this facility include student exchange,
industrial or practical training, internships
and mentorships.
Previously, foreign students were not
permitted to undertake any short-term
assignments with companies in Malaysia
under the Social Visit Pass. Companies had
to obtain an approval for a Professional
Visit Pass (i.e. a short-term work pass)
from the Malaysian Immigration
Department.
Foreign students will now be able to
commence a short-term mobility program
immediately after their arrival in Malaysia.
The annual projection of expected
foreigners’ process for 2016 is now open
for eligible companies. The projection is
the anticipated number of foreigners the
companies intends to hire or continue to
hire in 2016.
What does this mean for you as an
employer?
As any unused approved visas for 2015
will not be able to be carried forward for
use in 2016, we would encourage you to
plan ahead to avoid any delay in obtaining
approvals for foreigners’ Employment Pass
applications.
Please do not hesitate to reach out to
your usual PwC Legal contact for further
details.
Mexico
From September 2015, non-visa nationals
planning to enter Mexico by land through
the state of Baja California, Sonora,
Chihuahua, Coahuila, Nuevo Leon and
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Global Immigration: Quarterly Newsletter
Tamaulipas can complete an online form
prior to travel which will facilitate entry.
The individuals can complete the Multiple
Migratory Form (FMM) online and make
the payment of MXN $332 USD (€305.70
EUR) by credit or debit card. They must
print the form and the issued receipt and
carry this with them when travelling.
Once the application is submitted, the
individual must enter Mexico within 30
days and they may be issued entry with a
stay valid for a period of up to 180 days.
What does this mean for you as an
employer?
This new process will benefit frequent
travellers as those who complete the
FMM form online prior to travel will avoid
queuing at the border.
Please note that this process is only
available to non-visa nationals who are
travelling from the United States via land.
Please do not hesitate to reach out to
your usual PwC Legal contact for further
details.
Netherlands
The timeframe during which foreign
nationals are allowed to conduct business
visits in the Netherlands has been
amended. Now, foreign nationals may stay
in the Netherlands for 13 weeks in a 12
month period without requiring a work
permit.
As a result of this change, fewer work
permits will be utilised for those coming
to the Netherlands for more than 4 weeks
to participate in business trips. Though it
is important that the activities are limited
to business meetings and concluding
contracts.
Activities linked to the primary production
process or core business of the company
will fall outside the scope of the waiver
provision and a work permit will still be
required.
What does this mean for you as an
employer?
There is now much greater flexibility for
longer-term business travellers needing to
be in the Netherlands for longer periods of
time. It is important to still ensure that the
nature of the activities being performed on
the trips remain within the scope of those
permitted as a business visitor.
Please do contact your usual PwC Contact
should you require further information on
this.
limited number of long-term migrants on
temporary work visas in the South Island.
New Zealand
The Government is also considering a new
Global Impact Visa to attract high-impact
entrepreneurs, investors and start-up
teams to launch global ventures from New
Zealand. Encouraging entrepreneurs to
also set up in the regions is a step in this
direction.
Immigration into New Zealand continues
at a record high and Statistics New
Zealand reported a record net inbound,
seasonally adjusted permanent and long
term migration of 5,700 migrants in July
2015, surpassing the previous record of
5,400 in January 2015.
Given that a large proportion of inbound
migrants settle in Auckland, this places
additional pressure on an already heated
housing market and so the Government
is proposing to make it more attractive
for certain migrants to settle outside of
Auckland.
Skilled migrants and entrepreneurs will
be awarded additional points in their
applications from November 2015 if they
intend to settle outside of Auckland.
Applicants will be expected to spend a
minimum amount of time in the region
after arrival i.e. this should not be seen as
a 'backdoor' route into Auckland for those
who potentially wouldn't be eligible for a
visa otherwise.
Due to the continuing demand in the
investor category, it remains to be seen
whether the government will seek to
increase the number of spaces available
to capitalise on the foreign investment
available.
What does this mean for you as an
employer?
Given the government is aiming to
encourage skilled migrants to move to
the regions to promote growth outside
Auckland, we would advise reviewing
operations in the regions given the
incentives available to those basing
themselves outside Auckland.
Norway
There are minimum salary requirements in
In addition, from mid-2016 a pathway
to residence will be provided for a
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Global Immigration: Quarterly Newsletter
place in order to qualify for a Norwegian
work permission for a skilled worker:
From 01 May 2015, the new minimum
gross salary amounts are as follows:
•For individuals holding a Bachelor’s
degree: NOK 381,000 (USD 42,756.97)
•For individuals holding a Master’s
degree: NOK 410,500 (USD 46,067.55)
What does this mean for you as an
employer?
When applying for a renewal of a residence
permit, the immigration authorities will
require documentation of the salary paid
for the previous three months and the
salary paid in these months should reflect
the new adjusted salary levels.
Please do not hesitate to reach out to your
usual PwC Legal contact should you have
more questions on the same.
Poland
At present, the processing times for
the issuance of permits for temporary
residency and residency cards to foreign
nationals has been extended from three to
five months.
Therefore, any foreign nationals, who are
not entitled to move within the Schengen
area without a valid visa, should not
leave Poland until the completion of
the procedure of granting a residency
card. Leaving Poland may result in their
expulsion from the Schengen territory and
no possibility of returning to Poland (and
the Schengen area).
What does this mean for you as an
employer?
We recommend that the process of
obtaining a Polish residence permit should
be initiated at least 5 months in advance
to avoid any situations where a foreign
national may not be able to travel outside
of Poland’s territory due to the process not
having been completed
Please do not hesitate to reach out to
your usual PwC Legal contact for further
details.
Russia
A Russian law implementing a new
simplified visa procedure for foreign
nationals travelling to Vladivostok came
into force on October 2015. The procedure
will apply to individuals entering Russia
through the border checkpoints situated
on the territory of the Vladivostok Free
Port Area.
Full details are yet to be determined;
however, it has already been confirmed
that visas issued through this process will
be valid for a maximum of eight days.
•Prohibition from submitting applications
to the Ministry of Labour (covering
recruitment services, job title changes,
employee transfers etc.);
What does this mean for you as an
employer?
•Cessation of processing of any
applications already submitted;
It is expected that this will greatly help in
speeding up the process for any travellers
coming to Vladivostok for short-term
visits.
•Financial penalties;
The authorities are expected to start
implementing the new simplified
procedure early 2016 once all the
respective subordinate acts are adopted.
Saudi Arabia
Since November 2015, Saudi employers
who employ over 100 people are required
to implement the Wages Protection System
(WPS). A grace period of 2 months is
afforded, this effectively gives companies
until the end of December 2015 to conform
to the regulations.
The effect on Immigration is indirect but
potentially severe in the case of noncompliance. If the requisite employee
salary details have not been provided to
the Ministry of Labour by the end of the
2 months, companies will face various
penalties including but not limited to:
Continued contravention of the
regulations could result in more severe
penalties including complete suspension
of all Ministry of Labour services for the
company, and the freedom for employees
of the company to transfer to a different
employer without first seeking their
employer’s permission.
WPS registration has not yet become
mandatory for companies with less than
100 employees but it is expected to by the
middle of 2016.
What does this mean for you as an
employer?
You will need to ensure that you have
registered with the Qawaem online
and ensure that its Financial Statement
and Director and Auditor report have
been uploaded. All employees’ salary
information must be submitted to the
Ministry of Labour, WPS registration
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Global Immigration: Quarterly Newsletter
completed, and local bank accounts should
be opened for each employee.
Singapore
Employment Pass (EP) applications will
now be rejected if the accompanying job
advertisements posted on the Jobs Bank
does not include a published salary range
or if the advertisement has a too wide
salary range.
To facilitate this transition, the salary
range declared in job advertisements
on Jobs Bank has been published
automatically since August 2015. In order
to satisfy the advertising requirement
under the Fair Consideration Framework
(FCF), the Ministry of Manpower (MOM)
may not accept job advertisements if the
salary range is too wide. Generally, the
maximum salary should not be more
than 1.5 to 2 times the minimum salary
indicated in the job advertisement.
Employers will need to re-advertise for at
least 14 calendar days if an EP application
is rejected.
The MOM will also increase scrutiny
on companies with fewer Singaporean
employees at the Professional, Managerial
and Executive (PME) level as compared to
industry norms. The identified companies
will be asked to provide additional
details on whether Singaporeans were
considered fairly. Companies found to
have shortcomings in their HR or hiring
practices will be required to adopt a plan
to address these shortcomings and to
reduce their reliance of foreign PMEs.
Further action will be taken against
uncooperative or unresponsive companies,
including longer processing time for EP
applications, curtailment or work pass
privileges.
The Ministry of Manpower (MOM) has
recently updated the provisions under
the Work Pass Exempt Activities (WPEA)
scheme, to refine and tighten the coverage
and scope.
Foreign nationals can now perform Work
Pass Exempt Activities for the duration
of the Short Term Visit Pass (STVP) or
for up to 60 days, whichever is shorter,
up to a cumulative total of 90 days in a
calendar year. A work pass will be required
if a foreigner wishes to perform Work
Pass Exempt Activities beyond 90 days.
Previously, foreigners could perform Work
Pass Exempt Activities for the duration
of their STVP subject to a maximum
of 60 days, with no clarification on the
cumulative period allowed in a year.
Further clarification which has been
issued on the Work Pass Exempt Activities
include:
• Exhibitor in an exhibition
• Organising or conducting a seminar,
conference, workshop, gathering or
talk
• Provision of specialised services
related to a new plant / operations /
equipment
What does this mean for you as an
employer?
We would advise that there are robust
processes in place for the advertising
requirements needed for obtaining
Employment Passes given the increased
scrutiny on this aspect of the process
to ensure the fair treatment and
consideration of local workers.
With regards to the changes to the Work
Pass Exempt Activities, we would advise
that you make yourself familiar with all
the requirements under the WPEA scheme
as beyond these specific activities, a work
pass will be required.
Please do not hesitate to reach out to
your usual PwC Legal contact for further
details.
Spain
In June 2015, the Spanish Parliament
passed a law to grant the Spanish
citizenship to Sephardic Jews who are
able to evidence that their ancestors were
originally from Spain. The exact number of
people able to utilise this new measure has
not been specified, however it is estimated
to be between 500,000 to 3.5 million
individuals. Any Sephardic applicant will
be able to obtain Spanish citizenship by
naturalisation.
As part of the process, every applicant will
have to evidence that they are of Sephardic
origin, that they have a special link with
Spain, and also being tested on Spanish
culture and language.
It should also be noted that all Sephardics
granted Spanish nationality will not
need to expressly refuse they previous
nationality. The deadline to submit
citizenship applications under this route
expires in June 2018.
There has been a new law implemented
which has brought out the below main
changes to the immigration landscape in
Spain:
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Global Immigration: Quarterly Newsletter
1.Residence permit for Intracompany
Transfers EU (ICT EU). These are designed
for Managers, Specialists and Trainees
from a company established outside of
the EU to a company from the same group
established in Spain. The length of the
assignment will be 3 years for managers
and specialists, and 1 year for trainees.
Companies established in other EU States
may assign any foreign nationals that have
been cleared for ICT EU permission in that
State previously and a notification will
need to be made to the Spanish Migration
Authorities in advance of the assignment.
The length of the assignment will be the
same one as that granted by the home
company's EU state authorities.
2. National Intra Company Transfers. This
migration authorisation will apply for
assigned employees who do not qualify
as Managers, Specialists and Trainees, or
when the maximum allowed length of the
assignment for each category has been
reached.
3. Intra Company Transfers for Group
of professionals. Company groups who
meet certain criteria may request a
collective application for Intra Company
Transfers for a number of their employees
simultaneously. In order to apply through
this route, they will need to register before
the Migration Authorities. The registration
will last for 3 years which may be renewed
if the company group still meets the
requirements. Registered company groups
will be exempt from providing evidence of:
a.The existence of an actual commercial
activity
b.High education qualification or 3 years
of professional experience, for the
assignees
c.The existence of a previous and
continuous Labour Relationship for at
least 3 months with one or various of
the companies that form the Group of
companies.
What does this mean for you as an
employer?
The new changes brought about the
new law mean a much more mobile EU
population and should make it easier to
mobilise and move foreign talent around
the EU.
Please do not hesitate to reach out to
your usual PwC Legal contact for further
details.
the upcoming year 2016, although the
numbers are 30% lower than in 2014:
•Non-EU : 4’000 L permits & 2’500 B
permits
•EU/EFTA assignees: 2’000 L permits &
250 B permits
is reached, quotas shall be introduced.
These quotas will limit the issuance
of new permits to EU/EFTA nationals
arriving in Switzerland in the following
year. If the threshold is not exceeded, no
restrictions will apply.
In February 2014, voters in Switzerland
approved a new constitutional provision
which will implement thresholds and
quotas limiting the number of permits
issued to foreigners. Such quotas will have
to be set in such a way that they reflect
Switzerland's overall economic interests,
while businesses will be required to
prioritise the domestic workforce in their
hiring decisions.
•Quotas: After consultation with the
immigration commission, the Federal
Government will decide on the
exact quotas per year. Quotas will be
assigned for each canton (the Swiss
administrative regions), taking into
account the cantons’ specific needs.
In principle, all permits valid for more
than four months shall be limited
by quota, except those for EU/EFTA
nationals, which will be limited only if
the threshold of the safeguard clause is
exceeded.
The new regulations are expected to be
implemented in 2017 and the final draft of
the regulations will be sent to Parliament
by March 2016.
•Prioritisation of the domestic work
force: A foreign national may be hired in
Switzerland only if no suitable candidate
is found locally.
The possible changes include the below:
•Specialised labour force: To date, only
(highly) specialised employees from
non-EU countries are granted admission
to the Swiss labour market and this
remains unchanged. For EU/EFTA
local hire, non-specialised employees
may continue to apply for Swiss work
permits.
Background
Switzerland
•Dual immigration concept: Maintaining
different systems for EU/EFTA nationals
and for non-EU nationals.
The Swiss Government has decided to
keep the quota levels unchanged for
•Safeguard clause: Once a certain
annual threshold of EU/EFTA permits
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Global Immigration: Quarterly Newsletter
•Further restrictions: Some further
restrictions may be imposed concerning
the immigration of family members,
unemployed persons and asylum
seekers.
The elements outlined above are part of
the implementation concept. However, the
final FNA draft will likely contain further –
as yet unknown – elements.
On 18 December 2015, Switzerland also
announced that additional measures
will be taken to protect the Swiss Labour
market and employees. For example, there
will be increased penalties of up to CHF
30’000 (instead of currently CHF 5’000)
for infringements of Swiss minimal salary
and working conditions when assigning
employees to Switzerland. Furthermore,
the Federal Council foresees enhanced
controls in order to prevent illegal
working.
What does this mean for you as an
employer?
We do not expect major changes in the
practice of the cantonal and the federal
authorities compared to 2015, however
to maximise the success of applications
in all Swiss cantons, we would advise you
to submit strongly drafted and complete
applications in addition to ensuring that
the salaries paid to foreign employees are
in line with Swiss local salary levels
What does this mean for you as an
employer?
•30 day short visit visa
PwC is closing monitoring the situation
and actively discussing any updates with
the Swiss authorities. We will keep you
updated on any new changes.
We would advise you to ensure that
any foreign nationals that may be being
relocated to Istanbul and who will
dependant residence permits to begin the
process as soon as possible and schedule
their travel plans accordingly.
•Entry permits for medical treatment
Turkey
Since May 2015, residence permit
applications are processed by civil
authorities at the Migration Directorate
rather than by local police officers. Under
this new scheme, foreign nationals
applying for residence permits are
required to prepare their applications
online with the new Migration Directorate
and schedule appointments using an
online system
The transition has not gone smoothly with
difficulties such as significant delays to
residence permit, technical issues with the
database, and inconsistent documentary
requirements being experienced.
There have also been growing backlogs
in the appointment system, as many local
offices which previously adjudicated
residence permits are now consolidated
into one office.
The above does not affect renewals
as these applications can be filed by
post, however the authorities do retain
the discretion to request additional
information or data following the
submission of the application.
UAE
The General Directorate of Residency and
Foreigners Affairs under Resolution 377
of 2014 has announced that holders of all
visa categories can now modify their entry
status and residence permits from within
the UAE. This was not previously the case
for certain visa types and so holders of
these visa types were required to first exit
the UAE in order to change their status.
The following visa and permit holders
are now permitted to change status incountry:
•Transit entry
•90 day long visit visa
•Entry permits for study
•Entry permits for exhibitions and
conferences
•Tourist visas
•GCC resident entry permit
•Work related entry permit for 14 days
•Work related entry permit for 90 days
•Work related multiple-entry permit
•Entry permit for work or residency
What does this mean for you as an
employer?
This change in the law will reduce the
burden of the holders having to travel
outside of the UAE for those who have
entered the UAE on a visitor or tourist visa,
when their employment entry permit is
issued.
Please do not hesitate to reach out to
your usual PwC Legal contact for further
details.
United Kingdom
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Global Immigration: Quarterly Newsletter
On 20 January 2016, the Migration
Advisory Committee (MAC) released its
report on the Tier 2 Review consultation.
The report is in response to the
Government's request for the MAC to
carry out a wide-ranging review of Tier 2
with a view to making recommendations
that would restrict inflows under the
Tier 2 route. Further, the MAC's response
acknowledges the Government's intention
to improve the training of British
workers through the formulation of its
recommendations. The MAC was requested to make
recommendations on five specific issues,
namely:
•How applications can be prioritised
under the Tier 2 route to ensure
maximum benefit for the UK;
•applying a skills levy (immigration skills
charge) to businesses employing nonEEA migrants;
•how to tighten the intra-company
transfer route;
•whether jobs should be automatically
removed from the Shortage Occupation
List; and
•whether dependants' access to the UK
labour market should be restricted.
As a result of some of the
recommendations that have been made by
the MAC, there will be increased minimum
salary levels particularly for companies
who offer third party contracts such as
those in the IT or Engineering sectors.
Increased costs are also to be expected
around NHS fees in addition to the
immigration skills charge and other new
initiatives.
There is the possible introduction of an
in-country cap which will restrict the
numbers of individuals who can switch
into the Tier 2 immigration. The majority
of individuals who switch into Tier 2
on an in-country basis are international
students . Other possible changes to the
Tier 2 visa category is the extension of the
duration from 12 months to 24 months for
individuals wishing to apply under the Tier
2 Intra-Company Transfer category.
What does this mean for you as an
employer?
We would advise that all assignments
into the UK are planned for as much in
advance as possible and also that there are
robust processes in place around budget
management given the imminent increase
to costs.
PwC Legal are closely monitoring the
situation and further updates will be
provided
USA
In December 2015, President Obama
signed the Visa Waiver Program
Improvement and Terrorist Travel
Prevention Act of 2015 into law. Part of
the broader Consolidated Appropriations
Act, this new legislation significantly
tightens the VWP by enhancing passport
requirements and restricting eligibility.
The Act mandates that the ESTA system
be enhanced to collect information on
an applicant’s additional or previous
countries of citizenship and directs
the Secretary of Homeland Security to
research and incorporate technology to
detect and prevent fraud and deception.
Individuals must possess a tamperresistant, machine readable passport when
making an application for admission at a
US port of entry. As of 1 April 2016, the
passport must also be electronic.
It is otherwise unclear how Customs and
Border Protection and other affected
agencies will actually implement the new
statutory scheme and how the changes will
apply to individuals who currently have
ESTA authorisation.
What is more, and effective immediately,
the following individuals are excluded
from the VWP:
•Those who have been present in Iraq,
Syria, Iran or Sudan at any time on or
after 1 March 2011. This restriction
also applies to other countries which
may later be designated as repeatedly
supporting terrorism or “of concern.”
•Those who, although citizens of a visa
waiver country, are also nationals of
Iraq, Syria, Iran, or Sudan. Once again,
this exclusion applies to any other
countries which may subsequently
be deemed as repeatedly supporting
terrorism or “of concern.”
In addition to these individual restrictions,
the Act also imposes further requirements
on participating program countries and
provides termination provisions for
What does this mean for you as an
employer?
We would advise that you ensure that
anyone travelling to Iran, Iraq, Syria and
Sudan going forward are aware of the
implications this will have on their ability
to participate in the ESTA program going
forward and that anyone who may have
travelled to those locations since March
2011 are no longer eligible to participate in
the ESTA program.
We would also advise that you notify
travellers who may hold nationality of
Iran, Iraq, Syria and Sudan that they are
no longer eligible for the ESTA program
even if they also hold other citizenship
which they are planning on travelling on.
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Permits Foundation
Permits Foundation has worked hard over recent years to ensure the EU Directive would facilitate
accompanying family members of a foreign assignee being able to work. Permits Foundation is an
independent organisation that promotes the best practice of an ‘open’ work permit or authorisation
process for legally resident expatriate partners which gives them immediate access to the
employment market for the same duration as the main work permit holder, once they have obtained
their accompanying family member residence status.
The organisation is for dependent accompanying family members to be able to apply for jobs freely
and take temporary project work or part-time work, without the uncertainty and time-consuming
bureaucracy of a work permit application.
Julia Onslow-Cole, partner and head of Global Immigration of PwC Legal LLP UK, has worked very
closely with Permits Foundation; working passionately with them on a number of the key issues that
they raise.
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Global Immigration: Quarterly Newsletter
Regional Newsletters
Due to the expansive size of our network, many of our regional firms
circulate newsletters which focus in more depth on immigration updates
and issues relevant to their regions. Should you have an interest in any of
these, please reach out to the relevant contact to arrange.
Asia Pacific Newsletter
Africa Newsletter
Brazil Newsletter
UK Newsletter
Jenny Lee, Senior Manager, Singapore
[email protected]
Kimona Chetty, Manager, South Africa
[email protected]
Eduardo Depassier, Senior Associate, Brazil
[email protected]
Andrea Als, Manager, UK
[email protected]
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Global Immigration: Quarterly Newsletter
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This publication has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice.
No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, PricewaterhouseCoopers Legal LLP, its members, employees and
agents do not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision
based on it.
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legal entity.
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