Asia-Pacific

Israel planning tax changes in response to US reform, seeks updated US tax treaty, considers digital firm taxation: Shoshanna Solomonnad / The Times of Israel→

February 5, 2018

Asia-Pacific

Australia consults on gas transfer pricing arrangements, submissions due June 14: Australian Treasury→

April 10, 2019

Asia-Pacific

China to cut company tax and fees, reform VAT, finance minister says: Reuters→

January 22, 2019

Asia-Pacific

Bangladesh tax authority’s transfer pricing unit begins operations: Jasim Uddin / New Age→

December 13, 2018

Asia-Pacific

New Japan-Spain tax treaty signed

October 17, 2018

Japan and Spain have signed a new tax treaty, the . . .

Asia-Pacific

Cambodia changes transfer pricing rules for related party loans

September 23, 2018

Sujeet Karkala of Sciaroni & Associates discusses the Cambodia tax authority’s new transfer pricing instruction, issued August 21, which addresses the interest rates to be applied to related-party loans . . .

Asia-Pacific

Proposed India profit attribution rules reject OECD approach, add “sales” and “users” as apportionment factors

April 24, 2019

Madhan N of PricewaterhouseCoopers Private Limited, India, discusses the Indian government’s controversial proposal for new rules for attributing profits to Indian permanent establishments . . .

Asia-Pacific

Hong Kong extends CbCR deadline

March 25, 2019

The Hong Kong government has extended the deadline for Hong Kong entities . . .

Americas

MNEs asked to assess tax treaty MAP in Guernsey, Isle of Man, Jersey, Monaco, San Marino, Serbia, Brunei, Curaçao

February 19, 2019

The OECD today asked multinational taxpayers and their advisors to provide information about their experiences with the tax treaty . . .

Asia-Pacific

Israeli transfer pricing guidance addresses low-interest loans

October 4, 2018

Jacky Houlie and Shlomo Hubscher of JH & Co. Law Office, Tel Aviv-Yafo, Israel, discuss a new circular produced by the Israeli tax authorities addressing transfer pricing aspects of low-interest domestic loans . . .

Asia-Pacific

New Zealand government report advocates no reduction in corporate rates, consideration of digital firm equalization levy: Tax Working Group→

September 23, 2018

Asia-Pacific

Indian advance pricing agreement uses customs value as arm’s length price

March 30, 2018

Mumbai advisor Ajit Jain writes that India’s Central Board of Direct Taxes has recently entered into an advance pricing agreement where customs values was accepted as arm’s length price for transfer pricing purposes . . . .

Asia-Pacific

India hits the 200 APA milestone, signs first pact on advertising, promotional expense

March 5, 2018

Transfer pricing and tax litigator Ajit Jain discusses India’s recent progress signing advance pricing agreements with multinationals and notes that the first unilateral APA dealing with the controversial topic of advertisement marketing, and promotional expenses has been concluded . . .

Asia-Pacific

Israel weighs lowering 6% corporate tax rate to compete with US tax reform, Netanyahu says: Lilach Baumer / CTech→

February 19, 2018

Asia-Pacific

Israeli court uses flawed logic in key transfer pricing decision

June 29, 2017

Professor Rifat Azam, Radzyner School of Law, Herzliya discusses the Israeli District Court’s decision in Getko Ltd vs. Kfar Saba Assessing Officer, which strives to develop transfer pricing principles and guidelines in the Israeli tax law context . . .

Asia-Pacific

Australian government introduces bill extending GST to imported low value goods→

February 27, 2017

See: Draft bill. See also: Draft Law Companion Guideline LCG 2017/D2.

Asia-Pacific

India stays operation of circular on taxation of indirect transfers of assets

January 17, 2017

India’s finance ministry on January 17 announced that it will suspend the operation of a circular issued last month concerning the taxation in India of indirect transfers of Indian assets through offshore . . .

Americas

Saudi Arabia FATCA IGA signed with US

November 16, 2016

The US Treasury Department has today updated its FATCA website, reporting that Saudi Arabia has signed a Model 1 intergovernmental agreement (IGA) with . . .

Americas

Panama, Bahrain, Lebanon, Nauru, Vanuatu pledge to combat tax evasion through automatic information exchange

May 11, 2016

Panama was among five countries that this week pledged to share financial account information automatically with other countries, the OECD . . .

Asia-Pacific

UAE, Finland sign tax information exchange agreement

March 29, 2016

The United Arab Emirates and Finland on March 27 signed an agreement on the exchange of information . . .

Africa

Brazil signs tax treaty with UAE potentially ending blacklisting, approves South Africa pact

November 14, 2018

Francisco Lisboa Moreira of Bichara Advogados, São Paulo, discusses the latest tax treaty developments in Brazil . . .

Asia-Pacific

Hong Kong gazettes R&D tax incentive

November 2, 2018

The Hong Kong government today published in the official gazette a new law increasing the tax deduction for . . .

Asia-Pacific

Bangladesh establishes new tax office to deal with foreign companies: Jasim Uddin / New Age→

October 3, 2018

Asia-Pacific

Indonesia to impose up to 10% import tariffs: The Jakarta Post→

September 23, 2018

Asia-Pacific

US, Austria sign agreement to exchange country-by-country reports on multinationals

August 24, 2018

The US and Austria have signed a competent authority agreement to exchange country-by-country reports on multinationals operating in their countries, US Treasury . . .

Asia-Pacific

UAE joins “Inclusive Framework on BEPS”

May 16, 2018

The OECD today announced that the United Arab Emirates has become the 116th jurisdiction to join the . . .

Asia-Pacific

India-Kuwait tax treaty protocol enters into force

May 7, 2018

India’s Central Board of Direct Taxes on May 7 announced that a protocol amending the 2006 India-Kuwait double tax treaty . . .

Bahamas, US Virgin Islands, Saint Kitts to be added to EU tax blacklist, leaked document says

March 9, 2018

The Bahamas, US Virgin Islands, and Saint Kitts and Nevis will be added to the EU’s blacklist of non-cooperative third-country tax havens on March 13 during an EU finance ministers meeting, Reuters has reported, citing a leaked EU document dated March 8. This latest leak follows a widely-reported earlier leak that . . .

Asia-Pacific

Vietnam can’t collect contested tax from Uber because the company has no bank accounts there: VN Express→

February 5, 2018

Americas

Brazil removes Costa Rica, Madeira, Singapore from tax haven list, but adds regimes to “privileged”list: KPMG→

January 17, 2018

Asia-Pacific

Cognizant’s Indian subsidiary hit with Rs 2,500 crore (USD 375 million) tax bill from transfer pricing adjustment: Hemamalini Venkatraman / DT Next→

January 9, 2018

Asia-Pacific

UAE confident of removal from EU blacklist after tax reform, outstanding issues is implementing BEPS: Gulf News General→

December 7, 2017

Asia-Pacific

Oman joins the “Inclusive Framework on BEPS” to fight multinational tax avoidance

October 23, 2017

Oman has joined the “Inclusive Framework on BEPS,” becoming the 103 country to join, the OECD announced October 20. The framework is aimed at curtailing multinational group tax avoidance and improving resolution of tax disputes between nations. By joining the . . .

Asia-Pacific

Japan, Estonia sign tax treaty

August 30, 2017

The governments of Japan and Estonia today signed a tax treaty, Japan’s Ministry of Finance has reported. The new treaty . . .

Americas

Ecuador adds Hong Kong to tax haven blacklist: EY→

August 28, 2017

Asia-Pacific

UK and Australia’s different PE profit attribution approach yields double taxation and nontaxation: Celeste Black / SSRN→

June 28, 2017

Asia-Pacific

McDonald’s could run afoul of Australia’s diverted profits tax: Nassim Khadem / The Sydney Morning Herald→

June 1, 2017

Americas

US, Saudi Arabia FATCA agreement enters into force

March 29, 2017

The US Treasury Department has updated its FATCA website, reporting that a Model 1 intergovernmental. . .

Asia-Pacific

India, Austria tax treaty protocol signed

February 7, 2017

Indian and Austrian government officials on February 6 signed a protocol to their 1999 tax treaty that would broaden the scope of the countries’ existing framework of exchange of tax. . . .

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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