The Guideline for Tax Risk Management of Fees paid to Overseas Related Parties, issued June 30, interprets Announcement 16, released in March, writes EY. See: EY
India, Australia, Canada, on June 3 signed the OECD common reporting standard multilateral competent authority agreement, paving the way for automatic exchange of information by the countries’ tax administration, according to press releases issued by the countries’s governments. Costa Rica, Indonesia, and New Zealand . . .
Taiwan’s Ministry of Finance has announced it will modify transfer pricing rules for business restructuring, the profit split method, and reporting for companies merged or dissolved, writes PwC in a March 19 report. Amendments also revise advance pricing agreement requirements and introduce reverse calculation of revenue using the profit standard of the same trade. See, PwC.
Hong Kong’s Inland Revenue Department (IRD) on March 3 advised that it will accept 2014-15 profits tax returns in which assessable profits are computed on a fair value basis while the government continues to consider its response to the decision in Nice Cheer Investment Limited v CIR. . . .
The Australian Taxation Office (ATO) has been scrutinizing the tax affairs of more than 200 multinational corporations for the past 18 months, and expects to litigate tax disputes arising from this activity beginning the second half of 2015, Andrew Mills . . .
China and Russia on October 13 signed an agreement for the avoidance of double taxation. The agreement would replace a tax treaty signed by the countries in May 1994. Under the new agreement, dividends . . .
Gireesh Chandra Prasad of the Financial Express, in an August 23 article, has quoted unnamed India Finance Ministry officials as stating that India’s tax authority will permit rollback of advance pricing agreements (APAs) to prior tax years only with adjustments for inflation. See, Financial Express
The Australian Taxation Office (ATO) on December 10 said it is reviewing arrangements where an Australian resident multinational establishes a controlled foreign . . .
The National Taxation Bureau of Taipei, Ministry of Finance, on November 23 released guidance on the tax treatment of payments made by profit seeking . . .
The UAE Ministry of Finance’s (MoF) said August 18 that while Gulf Cooperation Council (GCC) countries have agreed to simultaneously launch a value added tax (VAT), the countries have yet to settle. . .
“The Senate standing committee on economics will this week write to Uber and room-sharing service Airbnb inviting them to make a written submission to the inquiry into the use of offshore tax havens by multinational companies. The next step will be to invite company representatives to appear at hearings as “guests” of the inquiry,” writes Fleur Anderson of Financial Review.
Pieter de Ridder has joined Mayer Brown’s tax, transactions, and consulting practice in Singapore as a partner, the firm announced February 16. De Ridder has over 20 years of experience advising multinational companies and institutions that operate in Asia, most recently as partner and head of Loyens & Loeff’s Singapore office. Prior to arriving Singapore in 1996, he was based in Jakarta . . .
China’s central government on Sept. 25 announced it will offer tax breaks to encourage enterprises to upgrade equipment and increase research and development (R&D) in an effort to improve the manufacturing . . .
Singapore’s Ministry of Finance announced, on August 27, that it will modify portions of the draft Goods and Services Tax (Amendment) Bill 2014 and related subsidiary legislation in response to suggestions lodged pursuant to a public consultation. Press release, Annex (summary of GST consultation and responses)
India’s tax income tax department is considering requiring taxpayers to report indirect transfers abroad of assets located in India and may extend the reporting requirement to prior tax years, writes Gireesh Chandra Prasad of the Financial Express, quoting an unnamed tax official. For more details, see Financial Express.
Azerbaijan and Saudi Arabia, on May 13, signed an agreement for the avoidance of double taxation and an agreement to prevent tax evasion, the Azerbaijani Foreign Ministry announced on its website. Press Release.
The Australian Taxation Office announced December 7 that it will fulfill its obligation to publicly report tax information of corporate entities pursuant to new tax transparency . . .
Singapore’s Ministry of Finance (MOF) published on November 17 a summary of its responses to a public consultation on the Draft Income Tax (Amendment) Bill 2016, indicating which commentator suggestions have been accepted and rejected. See: Summary of Responses.
The Indian government has announced that it has settled 35 transfer pricing disputes with the US in the information technology services and information technology enabled services industries thanks to a framework agreement signed . . .
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. . .
India’s Lok Sabha on March 30 passed through a voice vote Finance Bill 2015, which contains the government’s tax proposals. The bill was passed after Finance Minister Arun Jaitley offered several amendments, including one that provides that foreign firms will be exempt . . .
Switzerland and Australia have signed a joint declaration expressing their intent to begin automatically exchanging information on tax matters using internationally agreed standards beginning in 2018, the Swiss government announced March 3. Collection of the data will begin in 2017. The agreement, signed in Canberra, is the first declaration on automatic exchange of information. . .
G20 finance ministers have agreed to a plan to create a multilateral instrument to implement tax treaty-related measures under OECD/G20 the base erosion and profit shifting (BEPS) plan, the ministers said in a communique following their February 9-10 meeting in Istanbul . . .
India’s Bombay High Court on October 10 ruled in favor of Vodafone in a transfer pricing dispute, potentially resolving about two dozen other Indian tax disputes involving whether the transfer or issuance of undervalued shares by an Indian company to an overseas related party . . .
Update: For the Bombay High Court decision, see Vodafone
India is attempting to renegotiate tax treaties with Germany, France, Singapore, Italy, and South Korea to add corresponding adjustment provisions so that India can sign bilateral advance pricing agreements (APAs) involving these nations, writes Vrishti Beniwal in an August 26 Business Standard article, quoting unnamed Finance Ministry officials. See, Business Standard
The cabinet of Prime Minister Shinzo Abe of Japan, on June 24, endorsed economic reforms, including a phased-in cut to Japan’s corporate tax rate. The rate would drop from 35.64 percent to below 30 percent beginning in 2015. Read more, at The Japan Times, The New York Times.
Singapore’s Inland Revenue Authority, on May 16, published a guide for the pharmaceutical manufacturing industry that outlines the tax treatment of research and development and intellectual property-related expenditures. See, Guide
China and Monaco have signed the multilateral competent authority agreement, moving the countries one step closer to adopting automatic exchange of financial account information for tax purposes . . .
India’s Central Board of Direct Taxes announced September 24 that it will not impose minimum alternative tax (MAT) on companies that do not have have a permanent establishment or . . .
Ireland and Pakistan signed a tax treaty on April 16, Irish Revenue and Customs has announced. The agreement . . .
Australia and the UK have asked G20 nations to join them in an effort to stop the diversion of profits by multinational enterprises, in an initiative designed to go “further and faster” than the OECD’s base erosion and profit shifting (BEPS) plan, Australia’s . . .
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 . . .
Taiwan’s tax authority has announced that if a foreigner stays in Taiwan for more than 90 days during a taxable year, remuneration received outside Taiwan for services rendered within Taiwan is deemed . . .
Taiwan’s National Taxation Bureau of Central Area (NTBCA), in a Sept. 10 press release, said that it denied a company a deduction for a capital loss arising from the company’s ownership of a non-operating overseas holding company which held a lower tier investee company that had operating losses. . . .
The VietNamNet Bridge, in a June 24 report, quotes Bui Van Nam, General Director of Vietnam’s General Department of Taxation (GDT), as stating that the GDT intends to investigate the transfer pricing practices of automobile manufacturers as well as the behavior of international accounting firms . . .
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