Asia-Pacific
China
Asia-Pacific
China to provide tax breaks for equipment and R&D
China’s central government on Sept. 25 announced it will offer tax breaks to encourage enterprises to upgrade equipment and increase research and development (R&D) in an effort to improve the manufacturing . . .
Asia-Pacific
China and Monaco sign agreement to prepare for automatic exchange of information
China and Monaco have signed the multilateral competent authority agreement, moving the countries one step closer to adopting automatic exchange of financial account information for tax purposes . . .
Asia-Pacific
China proposes sweeping changes to transfer pricing and antiavoidance rules – KPMG
A discussion draft released by China’s State Administration of Taxation on September 17 “is a highly significant document, clarifying the Chinese approach to TP investigations and analysis, introducing new TP methodologies, and significantly expanding TP documentation requirements,” writes KPMG. The new guidance also amends special and general antiavoidance rules. See: KPMG. More: Deloitte, DLA Piper, EY.
Asia-Pacific
China/Hong Kong protocol clarifies tax treatment of investment funds
China and Hong Kong tax officials on April 1 signed the fourth protocol to their tax arrangement, clarifying the conditions under which an investment fund would be qualified for Hong Kong resident status, Hong Kong’s Inland Revenue Department. . .
Asia-Pacific
China scrutinizing related-party royalties and service fees
China’s State Administration of Taxation has instructed tax bureaus across China to survey companies regarding service fees and royalties paid to related parties between 2004 and 2013, to report back to the SAT on their findings, and to initiate audits of companies that have made suspicious payments, KPMG writes in an August tax alert. For details, see, KPMG. See also, EY.
Americas
US Treasury official urges Senate committee to approve ratification of pending tax treaties
Witnesses testifying before the US Senate Committee on Foreign Relations on October 29 urged the committee to recommend ratification of eight pending US tax treaties and protocols, highlighting key aspects of the . . .
Asia-Pacific
China releases APA statistics for 2013, details procedures to obtain APAs
China signed 19 advance pricing arrangements (APAs) — 11 unilateral APAs and 8 bilateral APAs — in 2013, according to the State Administration of Taxation’s (SAT) annual APA report. The report, released December 5, provides data on China’s APA program from 2005-2013, outlines the process for obtaining an APA in China, provides forms and schedules needed to apply for an APA, and provides
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Americas
Asia-Pacific
China ratifies multilateral convention on tax avoidance – People’s Daily
China’s National People’s Congress Standing Committee on June 1 ratified the Multilateral Convention on Mutual Administrative Assistance in Tax Matters the People’s Daily reports. See, People’s Daily.
China
China releases English-language descriptions of SAT guidance on transfer pricing, combating tax avoidance, and improving the tax system
China’s State Administration of Taxation (SAT), on June 3, released English-language descriptions of SAT transfer pricing guidance, a circular reporting on the SAT’s efforts to curtail tax avoidance, and a paper outlining the changes required to transform China’s taxation system into one more truly governed by the rule of law. The SAT explained that its decision to release transfer pricing . . .
Asia-Pacific
China’s SAT issues guidance on application of GAAR to indirect transfers of assets
The Chinese government has released guidance on the application of its general antiabuse rule (GAAR) to indirect transfers of Chinese assets, the State Administration of Taxation (SAT) announced February 6. The guidance seeks to . . .
Asia-Pacific
China SAT outlines tax guidance for nonresident transportation businesses
China’s General Office of the State Administration of Taxation (SAT) highlighted recently issued tax guidance, “Interim Measures for the Tax Management of Non-resident Enterprises Engaged in International Transportation Business,” in a Sept 15 English-language news release. . .
Asia-Pacific
China announces signing of tax arrangement with Taiwan
China’s State Administration of Taxation on November 3 announced the August 25 signing of a tax arrangement between China and Taiwan . . .
Asia-Pacific
Americas
China signs tax treaty with Chile, protocol with Russia
China has signed a tax treaty with Chile and a protocol to its tax treaty with Russia, China’s State Administration of Taxation said in July 3 English-language releases. The treaty with Chile, signed May 25, is is the 100th treaty signed by China, the government . . .
Asia-Pacific
China SAT says approval no longer required for some cross-border tax administration issues, outlines new procedures
China’s State Administration of Taxation in a June 23 English-language release described follow up procedures implementing the SAT’s decision no longer require tax administration approval . . .
Asia-Pacific
Hong Kong releases forms to apply for resident status for tax treaties
Hong Kong’s Inland Revenue Department, on January 29, released revised forms for companies, partnership, trusts, and other entities to apply for a certificate of resident status for purposes of claiming tax treaty . . .
Americas
New Zealand discloses plans for 2015 tax treaty negotiations
New Zealand expects in 2015 to negotiate tax treaties or protocols with Korea, Australia, Norway, Slovak Republic, China . . .
Asia-Pacific
China SAT notes new guidance on overseas investment reporting
China’s General Office of the State Administration of Taxation (SAT) in a Sept 15 English-language news release described the contents of a recently issued SAT Announcement “Reporting of Information on Overseas Investments and Income by Tax-resident Enterprises.”
The Announcement . . .
Africa
OECD statistics show many unresolved MAP cases in Germany, US, Belgium, and France
Germany had the greatest number of unresolved mutual agreement procedure (MAP) cases among OECD countries during the 2014 reporting period, according to OECD statistics . . .
Asia-Pacific
China/Indonesia revise tax treaty
The Chinese government on June 3 announced that China and Indonesia signed a tax treaty protocol that stipulates that the two nations will exempt from VAT aviation enterprises engaged in international transportation with each other. The parties also signed a memorandum of understanding that lists the wholly-owned financial institutions of the two governments which are tax exempt under the treaty. Both agreements were signed on March 26. See, Release.
Asia-Pacific
OECD holds Asia-Pacific regional meeting on BEPS
Tax officials from 21 Asia Pacific countries and organizations attended an OECD regional network meeting on base erosion and profit shifting (BEPS) designed to give more nations a voice in the development of OECD/G20 base erosion profiting shifting (BEPS) plan output. The meeting, held February 12–13 in Seoul, also . . .
Asia-Pacific
China finalizes GAAR implementing guidance
The Chinese government has finalized administrative measures implementing its general antiabuse rule (GAAR), the State Administration of Taxation (SAT) announced December 12. The guidance implements GAAR rules introduced in 2008, addressing the law’s scope, judging criteria, adjustment methods, working procedures, and dispute resolutions, the SAT said in . . .
Asia-Pacific
Asia-Pacific
China’s SAT outlines policy on tax-free mergers and reorgs
China’s State Administration of Taxation (SAT) on July 22 released an English-language translation of a June 3 announcement describing new policies . . .
Asia-Pacific
China to monitor MNE profit levels and coordinate with other nations to fight BEPS
“China will comprehensively monitor the profit levels of foreign companies to make sure there is no base erosion and profit shifting,” Zhang Zhiyong, deputy director of the State Administration of Taxation (SAT) said December 1, the government’s news agency, Xinhua, has reported. Zhang also said that China intends to . . .
Africa
OECD publishes MAP statistics of member countries
The OECD on November 25 released 2013 statistics on the mutual agreement procedure (MAP) caseload of OECD member counties and partner economies of Argentina, China, Latvia, and South Africa. According to an accompanying OECD . . .
Asia-Pacific
China and South Korea sign bilateral APA
China and South Korea have signed a bilateral advance pricing agreement, the Chinese goverment announced in a June 23 English-language release. The signing took place during a Sino-South Korea tax commissioners meeting . . .
Asia-Pacific
China-Netherlands treaty to enter into force
China’s State Administration of Taxation has announced that a tax treaty and protocol signed by China and The Netherlands on May 31, 2013, will enter into force on August 31. Press release (Chinese).
Asia-Pacific
China takes tough stance on transfer pricing for royalty and service payments
China’s State Administration of Taxation (SAT) on March 18 announced that it will no longer permit deductions for royalty fees paid to an overseas related party that did not contribute to the creation of the intangible asset or allow deductions for fees paid to an overseas related party for services that do not provide economic benefit to the subsidiary, writes Dezan Shira & Associates in the March 25 edition of the China Tax Briefing. In its guidance, . . .
Asia-Pacific
China SAT revises VAT exemption for cross-border services
China’s State Administration of Taxation (SAT) on August 27 announced revisions to the VAT exemption for cross-border services writes to Dezan Shira & Associates in a Sept. 8 post to the firm’s website. Changes include
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