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Japan

Americas

Japan, Peru begin tax treaty negotiation

May 16, 2018

The government of Japan has announced the commencement of tax treaty negotiations with . . .

Americas

Eight countries launch ICAP pilot to jointly assess multinational firm tax positions, handbook released

January 24, 2018

Tax officials from eight countries — Australia, Canada, Italy, Japan, the Netherlands, Spain, UK, and US — on January 23 launched in Washington, DC, a pilot program to jointly assess the tax and transfer pricing positions of multinational . . .

Asia-Pacific

Apple sub pays Japan ¥12 bil (USD 1.8 bil) for failure to withhold on amounts paid Irish sub deemed royalties for software use: Yomiuri Shimbun / The Japan News→

September 21, 2016

See: The Japan News.

Americas

 Ecuador, Japan agree to terms of tax treaty

September 5, 2018

The Japanese government today announced that it has agreed in principle with the Ecuadorean government . . .

Asia-Pacific

Japan to extend R&D tax credit to service businesses: Nikkei Asian Review→

November 17, 2016

See: Nikkei Asian Review.

Americas

Japan and Panama to negotiate tax information exchange agreement

May 18, 2016

The Japanese government has today announced that it will begin negotiations with Panama for a new. . .

Asia-Pacific

Japan, Austria tax treaty signed

January 31, 2017

Japan and Austria signed a new tax treaty on January 30 to update their 1963 agreement, Japan’s . . .

Asia-Pacific

Japan and Estonia to negotiate tax treaty

August 8, 2016

Japan and Estonia will begin negotiations for a tax treaty, Japan’s Ministry of Finance announced . . .

Asia-Pacific

Japan to sign tax treaties with Denmark and Estonia

May 15, 2017

Japan’s Ministry of Finance today announced that it has reached agreements in principle for tax treaties . . .

Asia-Pacific

Japan, Belgium sign tax treaty

October 12, 2016

Japan and Belgium today signed a new tax treaty, Japan’s Ministry of Finance . . .

Asia-Pacific

Japan’s tax treaties with Estonia and Lithuania enter into force

August 31, 2018

Japan’s Ministry of Finance today announced the entry into force of tax treaties signed with Estonia and Lithuania as . . .

Americas

Japan, Argentina negotiating tax treaty

January 9, 2018

Japan’s Ministry of Finance today announced that the governments of Japan and Argentina will commence negotiations . . .

Americas

IRS signed fewer APAs in 2016, statistics show

March 27, 2017

The US IRS today released its annual statistics on the performance of its Advance Pricing Mutual Agreement (APMA) program, revealing that the tax agency signed . . . 

Americas

Japan, Bahamas initial change to tax treaty

February 2, 2017

Japan and the Bahamas have agreed in principle to partially modify their 2011 tax treaty, Japan’s Ministry . . .

Asia-Pacific

Japan to impose corporate tax on “dummy” subsidiaries located in low tax countries: The Japan Times→

September 28, 2016

See: The Japan Times.

Australia

31 nations sign agreement on exchange of country-by-country transfer pricing reports

January 27, 2016

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .

Africa

Australia releases draft law adopting BEPS MLI, seeks to amend 30 bilateral tax treaties 

February 8, 2018

The Australian government on February 8 released for public comment a draft law that would give the force of law to a multilateral tax treaty designed to amend about 30 of Australia’s tax treaties with other . . .

Asia-Pacific

Japan and Lavia sign first tax treaty, text available

January 18, 2017

The governments of Japan and Latvia today signed a their first tax treaty, Japan’s Ministry of Finance has announced. The agreement, signed in Tokyo, would exempt royalties . . .

Asia-Pacific

Japan, Lithuania initial draft tax treaty

January 6, 2017

Japan and Lithuania have agreed in principle to a tax treaty, Japan’s Ministry of Finance . . .

Asia-Pacific

Denmark-Japan double tax treaty enters into force 

January 3, 2019

Michael Vorndran, a principal with Nord Advisory AS, Oslo, Norway, notes that a new tax treaty between Denmark and Japan has entered into force . . .

Asia-Pacific

Japan enacts tax bill changing PE definition, restricting R&D credit: EY→

April 9, 2018
Asia-Pacific

Japan, Croatia to begin tax treaty negotiations

March 7, 2018

Japan’s Ministry of Finance today announced that it will enter into tax treaty . . .

Asia-Pacific

Japan, Russia negotiate tax treaty

March 27, 2017

Japan and Russia have begun negotiations to amend their tax treaty, Japan’s Ministry of Finance has announced. The . . .

Asia-Pacific

Japan, Russia sign new tax treaty

September 7, 2017

Japan and Russia today signed a new tax treaty that would wholly replace the countries’ existing 1986 tax treaty. The new treaty reduces . . .

Americas

Japan, Bahamas agree to automatic exchange of financial information for tax purposes

February 16, 2017

Japan and the Bahamas on February 9 signed a protocol to their tax information exchange agreement (TIEA), agreeing to upgrade the agreement by providing for automatic exchange . . .

Americas

Japan and Chile sign first tax treaty

January 26, 2016

Japan and Chile signed a tax treaty on January 22, the first such agreement between the nations, Japan’s . . .

Asia-Pacific

MLI amends Japan, Singapore tax treaty

January 13, 2019

Japan’s Ministry of Finance has announced that, as both Japan and Singapore have . . .

Americas

Japan, Peru to negotiate tax treaty

May 10, 2018

Japan’s Ministry of Finance has announced that it is commencing . . .

Asia-Pacific

Japan, Croatia agree to terms of tax treaty

March 20, 2018

Japan and Croatia have agreed in principle to a tax treaty, the government of Japan announced . . .

Asia-Pacific

Japan and Belgium agree to terms of new tax treaty

May 11, 2016

Japan and Belgium have agreed to the terms of new tax treaty, Japan’s Ministry of Finance announced . . .

Americas

Japan, Panama tax information exchange agreement to enter into force

February 16, 2017

A tax information exchange agreement between Japan and Panama, signed August 25, 2016, will enter into force on March 12, Japan’s Ministry . . .

Asia-Pacific

Japan negotiating tax treaty with Slovenia

January 19, 2016

The Ministry of Finance of Japan has announced Japan and Slovenia will begin their first round of negotiations . . .

Asia-Pacific

Japan and Germany sign tax treaty

December 18, 2015

Japan and Germany on December 17 signed a tax treaty, wholly amending the . . .

Asia-Pacific

Japan and Germany agree to terms of new tax treaty

July 17, 2015

Japan and Germany have reached an agreement in principle on a new tax treaty, Japan’s Ministry of Finance announced July 16. The new treaty will include an arbitration clause . . .

Asia-Pacific

Asia-Pacific tax administrators form task force to address BEPS

December 1, 2014

Tax commissioners attending the annual Study Group on Asian Tax Administration and Research (SGATAR) meeting on November 27 agreed to form a permanent, ongoing, task force to collaborate on tax issues, including base erosion and profit shifting and tax transparency. The task force will relay . . .

Africa

Hong Kong gazettes orders on tax treaties with South Africa, UAE, and Japan

May 15, 2015

Hong Kong on May 15 announced that orders were gazetted to implement tax treaties signed with South Africa and the United Arab Emirates and notes exchanged with Japan regarding interpretation of the 2010 Japan/Hong Kong treaty. The tax treaty with South Africa, signed October 2014, reduce. . . 

Asia-Pacific

Japan and Qatar agree in principle to tax treaty

December 17, 2014

Japan and Qatar have agreed in principle to the terms of a tax treaty, the Japanese government announced on December 17. Under the agreement, taxation in the source country on dividends is reduced to 5 percent for corporate shareholders . . .

Asia-Pacific

Notes on tax information exchange between Japan and Hong Kong enter into force

July 14, 2015

Notes exchanged between Japan and Hong Kong confirming the understanding that information concerning additional . . .

Asia-Pacific

Japan releases English-language forms and instructions for consumption tax on cross-border supply of digital services

August 17, 2015

Japan’s National Tax Agency has released English-language information, forms, and instructions to be used by foreign businesses subject to a new law that imposes consumption tax on the overseas supply of digital . . .

Posts navigation

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What’s Next

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RECENT COMMENTS
  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
    April 6, 2022

Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • UN releases updated model tax treaty adding new technical services fees article by Julie Martin | posted on May 22, 2018

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