Japan’s ruling coalition on December 30 agreed to policies for a 2015 tax reform bill, which include a reduction in the corporate tax rate to 23.9% percent beginning April 1, restrictions on net operating losses, modifications to research and development tax credits, and limitations on the 95 percent participation exemption, writes EY in a January 7 report. For discussion, see EY.
In a surprising development, the US Senate Committee on Foreign Relations on November 10 approved without amendment proposed income tax treaties with Chile, Hungary, and Poland; proposed tax protocols with Japan, Luxembourg, Spain, and Switzerland; and a proposed protocol amending the multilateral mutual administrative assistance treaty. . .
Japan’s Ministry of Finance has advised that on November 30 Japan and Qatar exchanged diplomatic for the entry into force of the Japan-Qatar tax treaty, signed . . .
Japan and Hong Kong on December 10 exchanged notes confirming the understanding that information concerning additional taxes will be exchanged, Japan’s Ministry of Finance has announced. The additional taxes are the Japanese inheritance tax, gift tax, consumption tax; and any similar taxes later imposed. See, Japan Ministry of Finance release.
Japan’s Ministry of Finance announced on December 5 that it will begin negotiations with Qatar for a tax agreement between the counties. The first round of negotiations will begin December 8, in Tokyo. Release.
The requirements for the entry into force of the protocol between Japan and Sweden, signed December 5, 2013, were met on Sept. 16 and the treaty will enter into force on October 12, Japan’s Ministry of Finance has announced.
The protocol sets a zero rate of withholding on interest and royalties. The withholding rate for dividends is zero for corporate shareholders that hold at least 10 percent voting power, and is 10 percent in other cases.
The protocol also adds measures to prevent abuse of the treaty, introduces an arbitration proceeding to the mutual agreement procedure, and expands exchange of information. Release, Protocol (66KB).
G7 finance ministers and central bank governors agreed at a meeting in Dresden held May 27–29 that the mechanisms used to settle tax disputes between nations need to be improved, German Finance Minister Wolfgang Schaeuble said. Schaeuble told a press conference following . . .
Japan and Qatar on February 20 signed a tax treaty in Tokyo, the Japanese Ministry of Finance has announced. Under the agreement, taxation in the source country on dividends is reduced to 5 percent for corporate shareholders that hold at least a 10 percent interest, and is 10 percent in other cases. Taxation . . .
Japan and Chile have agreed in principle on a tax treaty, Japan’s Ministry of Finance announced . . .
India signed its first bilateral advance pricing agreement (APA) on December 19, agreeing with Japan and a Japanese company to aspects of the company’s transfer pricing for five year term, according to a Central Board of Direct Taxes release. The CBDT said that the APA was finalized in about 18 months, and noted that this is a shorter period than most governments take to finalize an APA. See, release.
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 . . .
A tax treaty between the United Arab Emirates and Japan signed on May 2, 2013, will enter into force on December 24 , Japan’s Ministry of Finance announced on November 25. The treaty will apply to taxes withheld at source, income taxes, and other taxes beginning January 1, 2014
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Japan’s Ministry of Finance has announced that the “Agreement between the Government of Japan and the Government of the Sultanate of Oman for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income”, signed January 9, will enter into force on September 1.
The agreement reduces withholding taxes on dividends to 10 percent . . .
India and Japan have signed a protocol to their 1989 tax treaty, India’s Central Board of Direct . . .
International law firm, Withers, has hired Eric Roose, formerly of Morrison & Foerster, to head its international corporate tax practice, the firm announced on June 8. Withers also launched . . .
Japan closed 174 mutual agreement procedure (MAP) cases during the fiscal year ending June 30, 2014, a record high, Japan’s National Tax Agency (NTA) said in an . . .
Masao Yoshimura, an Associate Professor of Tax Law at Hitotsubashi University’s Graduate School of International Corporate Strategy, analyzes a Japanese government proposal passed by the Lower House March 13 which would impose consumption tax on the supply of digital services by foreign providers. . .
Japan and the UK have exchanged notes on a new article on business profits under the Japan-UK tax treaty, the Japanese government announced July 22. New Article 7 introduces provisions concerning . . .
A protocol and exchange of notes between the UK and Japan, signed December 17, 2013, will enter into force on December 12, the UK government announced November 12.The protocol . . .
India and Japan are poised to resolve about 15 transfer pricing disputes under the mutual agreement procedure involving the automobile industry and large trading houses, writes Jayshree P Upadhyay of the Business Standard in a May 27 article. India also expects to soon resolve transfer pricing disputes involving the UK and France. See, Business Standard.
Masao Yoshimura, an Associate Professor of Tax Law at Hitotsubashi University’s Graduate School of International Corporate Strategy, analyzes a July 17 decision of the Supreme Court of Japan concluding that Delaware limited partnerships should be classified as corporations for tax purposes . . .
The European Commission on October 19 asked the Netherlands to amend the limitation on benefits clause in its tax treaty with . . .
G7 leaders, in a joint declaration issued June 8, made a “commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment.” The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .
UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders’ expression of support for compulsory binding arbitration in multinational tax disputes “deeply troubling,” stating . . .
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