Asia-Pacific
India’s final transfer pricing master file rules retain unique flavor
Jitendra Jain, Executive Director, PricewaterhouseCoopers, discusses final Indian rules for multinational taxpayers, released October 31, on the implementation of the transfer pricing master file and country-by-country report, noting that important changes were made to the earlier, draft version of the guidance. . .
Australia budget 2017 hits hybrid regulatory capital tax abuse, extends MAAL
In a further effort to curtail tax avoidance by multinationals, Australia will introduce hybrid mismatch provisions applicable to banks and insurance companies and tighten . . .
Draft Australia diverted profits tax legislation released for public comment
The Australian government today released draft diverted profits tax legislation, designed to stop large multinational businesses from artificially . . .
Portugal must grant company at least partial tax deduction for dividends received from Tunisian or Lebanese subsidiaries, EU court rules
Davide Anghileri, a lecturer at the University of Lausanne, discusses a Court of Justice of the European Union decision which concludes that Portugal’s current practice of denying Portuguese companies a deduction for intercompany dividends received from Tunisian or Lebanese subsidiaries violates EU law . . .
Singapore issues country-by-country reporting guide assist MNEs
Singapore’s tax authority has prepared a tax guide addressing how large multinationals can fulfill the obligation to prepare and submit country-by-county reports . . .
India and Slovenia sign protocol to tax treaty
India and Slovenia have signed a protocol to their tax treaty, agreeing to expand the scope of information exchange between tax authorities. . .
Despite progress, problems loom for India’s APA program
Mumbai chartered accountant, Ajit Jain, discusses progress and problems with India’s advance pricing agreement (APA) program . . .
Indian tax authority signs APAs at a quick pace but backlog grows, report shows
Indian tax officials signed a record number of advance pricing agreements (APAs) in fiscal year 2016–17; nonetheless, India’s backlog of unresolved APA cases increased during the . . .
New Zealand issues withholding tax rules for interest paid to related foreign lenders
New Zealand’s Inland Revenue on April 11 issued a special report providing guidance on new withholding tax rules for interest paid to related-party foreign lenders. Changes to these rules were made in the . . .
Hong Kong’s budget 2017–2018 tax proposals: more of the same, reheated
Stefano Mariani and Calvin Ng of Deacons provide a comprehensive analysis of the tax proposals in Hong Kong’s budget 2017–2018, released today, which the authors argue do little to promote Hong-Kong’s long-term competitiveness . . .
India, Kazakhstan tax treaty protocol signed
India and Kazakhstan have signed a protocol to amend their 1996 tax treaty, the
Indian government announced today. The new protocol . . .
Macau, Mauritius, Ukraine join the ‘inclusive framework on BEPS’ to combat multinational tax avoidance
Macau, Mauritius, and Ukraine have joined the ‘inclusive framework on BEPS,’ a group of countries that have pledged to promote the implementation of measures to combat . . .
Singapore-Laos tax treaty enters into force
A new tax treaty between Singapore and Laos entered into force on November 11, Singapore’s Inland Revenue . . .
Hong Kong, Belarus negotiating tax treaty
Hong Kong’s Inland Revenue Department has announced that Hong Kong and Belarus have commenced . . .
Indian tax official sees expanded role for BEPS inclusive framework, addresses transfer pricing local file
The countries that have joined the inclusive framework established to carry out the work of the OECD/G20 base erosion profit shifting (BEPS) project are likely to eventually take on international tax work outside of the BEPS . . .
Japan and Panama to negotiate tax information exchange agreement
The Japanese government has today announced that it will begin negotiations with Panama for a new. . .
New protocol allows India to tax capital gains from sales by Mauritius residents of Indian company stock
India and Mauritius today signed a protocol to their 1983 tax treaty, revising the tax treatment of capital gains on sales by Mauritius residents of . . .
UPDATE: Text of the India/Mauritius protocol published: The text of the new protocl has been published on the Mauritius goverment website. See: Protocol.
Australia’s tax office warns MNEs that particular transactions will be examined for tax avoidance
The Australian Taxation office (ATO) has today released four alerts, warning multinationals that specified transactions will be heavily scrutinized for tax . . .