Americas
US and Israel sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Israel has signed a Model 1 intergovernmental agreement (IGA) with the United States as of June 30. Agreement
Asia-Pacific
Africa
Mauritius agrees to exchange financial information with India and to enhance substance of registering businesses
Mauritius Prime Minister, Dr Navin Ramgoolam and newly appointed Indian Prime Minister, Shri Narendra Modi, on May 28, announced . . .
Asia-Pacific
Australia sharing information about tech companies to combat tax avoidance – Financial Times
Australia has begun sharing “information and intelligence” about multinational technology companies with five countries in an effort to crack down on tax avoidance. See, Jamie Smyth, Financial Times.
Americas
Switzerland announces entry into force of tax treaties with Iceland and Cyprus and protocols with Estonia and Uzbekistan; signing of TIEA with Brazil
The Swiss government on November 24 announced that double tax agreements signed by Switzerland and Cyprus, Iceland, Estonia, and Uzbekistan have entered into force. The goverment also announced that Switzerland signed . . .
Asia-Pacific
Hong Kong and Romania sign tax treaty, text available
Hong Kong’s Inland Revenue Department has announced on its website that Hong Kong signed at tax treaty with Romania . . .
Americas
US Treasury official urges Senate committee to approve ratification of pending tax treaties
Witnesses testifying before the US Senate Committee on Foreign Relations on October 29 urged the committee to recommend ratification of eight pending US tax treaties and protocols, highlighting key aspects of the . . .
Asia-Pacific
New Zealand to extend GST to cross-border services and intangibles, will later address low-value imported goods
New Zealand’s government on August 18 released a discussion paper requesting feedback on a plan to extend the goods and services tax (GST) to cross-border services and intangibles supplied to its residents, such as e-books, music, videos, and software purchased. . .
Americas
Americas
US and Georgia sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Georgia has signed a Model 1 intergovernmental . . .
Asia-Pacific
Australia to target multinational tax avoidance, impose of GST on offshore digital suppliers
The Australian government on May 11 announced plans to beef up antiavoidance rules to tax multinational profits diverted from Australia and to propose laws to ensure that offshore suppliers of digital products and services pay goods and services tax (GST). The proposals will be unveiled in the government’s . . .
Asia-Pacific
Hong Kong and Germany complete second round of tax treaty negotiations
Hong Kong and Germany completed their second round of tax treaty negotiations on March 6, according to Hong Kong’s Inland Revenue Department. This would be the first comprehensive double . . .
Asia-Pacific
India’s budget defers GAAR, clarifies indirect transfers
India’s budget, released February 28, introduces several tax changes of interest to business, including a deferral of planned general antiavoidance rules (GAAR), clarification of rules on indirect transfers of Indian assets, and the introduction of proposals to cut the corporate tax rate and widen the corporate tax base. In a . . .
Asia-Pacific
Guidance suggests Australia will use transfer pricing reconstruction powers carefully
The Australian Taxation Office (ATO) on February 26 released guidance on procedures that must be followed before ATO personnel can advance the view that a transaction must be reconstructed for transfer pricing purposes using one of the exceptions. . .
Asia-Pacific
China releases APA statistics for 2013, details procedures to obtain APAs
China signed 19 advance pricing arrangements (APAs) — 11 unilateral APAs and 8 bilateral APAs — in 2013, according to the State Administration of Taxation’s (SAT) annual APA report. The report, released December 5, provides data on China’s APA program from 2005-2013, outlines the process for obtaining an APA in China, provides forms and schedules needed to apply for an APA, and provides
. . .
Americas
Asia-Pacific
India To pressure Switzerland on automatic information exchange
In a May 12 press release, the Indian Ministry of Finance has asserted that it will continue to urge Switzerland to ratify the OECD Multilateral Convention on Mutual Administrative Assistance on Tax Matters. See, Press Statement
Africa
TJN Africa’s challenge to “loophole-ridden” Kenya-Mauritius tax agreement to be heard in Kenya High Court
A legal challenge to the Kenya-Mauritius Double Taxation Agreement, brought by Tax Justice Network Africa (TJN-A) in the High Court of Kenya at Nairobi, is getting closer to resolution, as a hearing date for the matter will be set on December 9. The lawsuit, filed October 3, 2014, is the first of its kind in Africa and . . .
Americas
US and Cambodia sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Cambodia has. . .
Asia-Pacific
US and India sign Model 1 FATCA IGA
The US and India have signed a Model 1 intergovernmental agreement (IGA) the Indian goverment announced . . .
Asia-Pacific
China ratifies multilateral convention on tax avoidance – People’s Daily
China’s National People’s Congress Standing Committee on June 1 ratified the Multilateral Convention on Mutual Administrative Assistance in Tax Matters the People’s Daily reports. See, People’s Daily.
China
China releases English-language descriptions of SAT guidance on transfer pricing, combating tax avoidance, and improving the tax system
China’s State Administration of Taxation (SAT), on June 3, released English-language descriptions of SAT transfer pricing guidance, a circular reporting on the SAT’s efforts to curtail tax avoidance, and a paper outlining the changes required to transform China’s taxation system into one more truly governed by the rule of law. The SAT explained that its decision to release transfer pricing . . .
Asia-Pacific
India temporarily halts most MAT assessments against FFIs
India’s Central Board of Direct Taxes (CBDT) on May 11 instructed field officers to stop issuing new tax assessments against foreign companies, particularly foreign financial institutions, for minimum alternate tax (MAT), except in cases where the statue of limitations is about to expire. The government also . . .
UPDATE (5/21/2015): India establishes committee to consider imposition of MAT on FFIs prior to April 1. The Indian government on May 20 tasked a committee headed by Justice A.P. Shah, former Chief Justice of Delhi High Court and current Chairman of the Law Commission of India to look . . .
Asia-Pacific
Business incentives to continue under Singapore’s 2015 budget
Singapore’s Finance Minister and Deputy Prime Minister, Tharman Shanmugaratnam, released of the country’s Budget 2015 on February 23. Business will benefit from the budget’s extension of the 30% corporate income . . .
Asia-Pacific
Germany and Israel sign revised tax treaty
Germany and Israel, on August 21, signed a revised and modernized double taxation convention, updating their agreement which was last modified in 1977.
The agreement reduces withholding tax on interest and . . .
Asia-Pacific
Australia asks public for advice on its tax treaty negotiation program
Australia’s Treasury has invited stakeholders to comment on Australia’s tax treaty negotiation program, including which countries Australia should seek to negotiate with and what outcomes are desirable when negotiating tax treaties with other countries. Release
Asia-Pacific
Australia finalizes guidance on deductibility of support payments to foreign subsidiaries
The Australian Taxation Office, on June 4, released TD 2014/14, on the deductiblity of capital support payments made by an Australian parent company to its overseas subsidiary. TD 2014/14, For analysis, see report by EY
Asia-Pacific
Australian court rules Chevron’s intercompany loans were not arm’s length, imposes 25 percent tax penalty
Australia’s Federal Court has handed the Australian Taxation Office (ATO) an important victory, concluding that USD 2.5 billion of loans between Chevron’s Australian-resident company and its Delaware subsidiary made between 2004-2008 were not arm’s length and thus generated excessive interest . . .
Asia-Pacific
Australia transmits data on 30,000 accounts to US under FATCA
Australia has, for the first time, transmitted information to the US government on US-owned financial accounts under an arrangement designed to combat offshore tax . . .
Asia-Pacific
Scott Morrison appointed Australia’s Treasurer
Australia’s new Prime Minister Malcolm Turnbull announced his new ministry on Sunday, including the appointment of Scott Morrison as Treasurer. Morrison replaces Joe Hockey, who is . . .
Asia-Pacific
Drug companies to testify at Australian Senate hearing on tax avoidance
Representatives of nine multinational pharmaceutical companies will defend their companies’ tax practices before the Australian Senate’s Economics References Committee on July 1 as a part of the committee’s ongoing inquiry into tax avoidance and aggressive tax . . .
Asia-Pacific
Indian government releases more guidance on roll back of APAs
The Indian government, on June 11, released additional guidance on the availability of roll back for advance pricing agreements. The guidance, in a question and answer format, clarifies . . .
Asia-Pacific
India establishes committee to consider imposition of MAT on FFIs prior to April 1
The Indian government on May 20 tasked a committee headed by Justice A.P. Shah, former Chief Justice of Delhi High Court and current Chairman of the Law Commission of India to look into the issue of whether the government should impose minimum alternate tax (MAT) on foreign financial institutions prior to April 1. See, release.
Asia-Pacific
Hong Kong launches consultation on automatic exchange of financial account information
The Hong Kong government on April 24 announced a consultation on legislation to implement automatic exchange of financial account information (AEOI) in tax matters. The legislation is based on prevailing international standards but has . . .
Asia-Pacific
Asia-Pacific
Manchanayake appointed Sri Lanka IRD acting commissioner
Sri Lanka’s Ministry of Finance and Planning, on August 4, announced that R.M.R.W. Manchanayake has been appointed to the post of Acting Commissioner General of the Inland Revenue Department. Release
Asia-Pacific
India-Thailand tax treaty in effect in India, text available
The India government, in a notice dated December 1, announced that a tax treaty with Thailand . . .
Asia-Pacific
Japan-Qatar tax treaty to enter into force December 30
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 . . .
Asia-Pacific
Australian government issues guidance on multinational antiavoidance law, consults on laws to address hybrid mismatch arrangements
The Australian Taxation Office (ATO) on November 22 released guidance on a proposed antiavoidance law being considered by Parliament that is designed to combat the use of artificial or contrived arrangements by multinationals to avoid attribution of profits to Australian permanent establishments. Also, Australia’s Board of Taxation . . .
Asia-Pacific
Australia announces intent to begin tax treaty negotiations with Israel
Australia’s Treasurer Joe Hockey on September 17 announced that Australia intends to commence tax treaty negotiations . . .
