Asia-Pacific
Australia: related party financing faces heightened tax scrutiny
Zara Ritchie and Natalya Marenina of BDO discuss the implications of May 16 Australian Taxation Office (ATO) guidance setting out the ATO’s risk assessment framework for cross-border related party financing . . .
Hong Kong, Korea tax treaty enters into force
Hong Kong’s tax authority today announced that a tax treaty between Hong Kong and Korea entered . . .
Pakistan signs multilateral agreement to fight tax evasion and avoidance
Pakistan today became the 104th signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the . . .
Hong Kong law granting tax concessions to corporate treasury centers enters into effect
The Hong Kong government on June 3 gazetted Inland Revenue (Amendment) (No. 2) Ordinance 2016, which provides a concessionary profits tax rate of 8.25 percent for qualifying corporate treasury centers and more generous rules for . . .
Japan enacts tax reform
Professor Masao Yoshimura of Hitotsubashi University provides an overview of the corporate tax and transfer pricing changes in Japan’s tax reform 2016, enacted on March 29. . .
EU finance ministers adjust tax haven blacklist, approve tax transparency scheme for intermediaries
Davide Anghileri of the University of Lausanne discusses today’s proceedings at the European Union’s Economic and Financial Affairs Council, where the EU’s blacklist of non-cooperative jurisdictions in taxation matters was updated and the ministers voted to approve a Commission proposal requiring mandatory reporting by intermediaries involved with potentially aggressive tax planning schemes . . .
Israel’s new deemed distribution rules – a trap for the unwary multinational taxpayer
Yuval Navot and Ronen Avner of Herzog Fox & Neeman, Tel Aviv, analyze a tax department circular, published August 23, which interprets new Israeli deemed distribution rules in a draconian manner, making it required reading for multinational taxpayers operating in Israel that extend intercompany loans or guarantees . . .
Thailand becomes 98th country to join ‘Inclusive Framework on BEPS’ to combat multinational tax avoidance
The OECD today announced that Thailand has joined countries that have pledged to implement the OECD/G20 base erosion profit shifting (BEPS) plan minimum . . .
Australia: draft tax ruling addresses central management and control test for tax residency
The Australian Taxation Office (ATO) has released a draft taxation ruling setting out the ATO’s view on when a foreign incorporated company is considered an Australian tax resident under the central management and control test, writes Davide Anghileri. . . .
Singapore, Uruguay tax treaty to enter into force
Singapore’s Inland Revenue Authority (IRAS) has announced that a new treaty signed with Uruguay will enter into force on March 14. The tax treaty, signed January 15, 2015, clarifies . . .