Asia-Pacific
Ashish Dave joins Quantera Global, Sydney
Ashish Dave has joined Quantera Global as a Director in the firm’s Sydney, Australia, office. Release
Asia-Pacific
Asia-Pacific
India and Japan sign protocol to tax treaty, text available
India and Japan have signed a protocol to their 1989 tax treaty, India’s Central Board of Direct . . .
Americas
Armenia and US to discuss tax treaty update
US and Armenian officials will discuss the possibility of entering into negotiations to update their 1973 double tax treaty during the annual US-Armenia Economic Task Force meeting scheduled for . . .
Asia-Pacific
India’s competent authority interviewed on BEPS project – Moneycontrol
India’s Competent Authority Akhilesh Ranjan discusses mandatory arbitration, country-by-country reporting, other BEPS topics with Mukesh Bhutani of BMR Advisors and Arun Giri of Taxsutra in a report published in The Firm on September 7. See: The Firm.
Asia-Pacific
China’s SAT outlines policy on tax-free mergers and reorgs
China’s State Administration of Taxation (SAT) on July 22 released an English-language translation of a June 3 announcement describing new policies . . .
Asia-Pacific
Withers hires Roose to head Asian tax practice, establishes office in Tokyo
International law firm, Withers, has hired Eric Roose, formerly of Morrison & Foerster, to head its international corporate tax practice, the firm announced on June 8. Withers also launched . . .
Asia-Pacific
India committee seeks comments on whether foreign firms should be subject to minimum tax
ndia’s Committee on Direct Taxes on May 26 requested that stakeholders submit written comments on the issue of whether the government should impose minimum alternate tax (MAT) on gains of foreign financial institutions (FFIs) that arose prior to April 1. The committee, headed by Justice A.P. Shah, former. . .
Asia-Pacific
Hong Kong consults on measures to implement automatic exchange of information
Hong Kong’s Treasury Branch on April 24 launched a consultation on the legislative regime and operational framework for implementing automatic exchange . . .
Asia-Pacific
Hong Kong budget includes tax benefits for corporate treasury centers and private equity funds
Tax measures in the Hong Kong government’s 2015-16 budget, released February 25, include tax reductions for corporate treasury centers and an extension of the profits tax exemption for offshore funds to private equity funds.. . .
Asia-Pacific
Indian government introduces consitutional amendement for goods and services tax
The Indian government on December 19 introduced a constitutional amendment in the Lok Sabha, India’s lower house of parliament, to pave the way for the introduction of a goods and services (GST) tax. The GST would be a simplification measure, replacing numerous taxes levied by individual states, including VAT, entertainment tax, octroi, entry tax, luxury tax, and purchase tax on goods and services. See, Economic Times, The Indian Express, The Times of India, Tax Guru.
Asia-Pacific
Hong Kong and UAE sign tax treaty
Hong Kong and the United Arab Emirates on December 11 signed an agreement for the avoidance of double taxation, Hong Kong’s Inland Revenue Department has announced. Under the agreement, tax paid in Hong Kong by UAE residents will be allowed as a credit against tax . . .
Asia-Pacific
Malaysia 2015 budget expands incentives for business, lowers rates
Malaysia’s 2015 budget, announced October 10, includes a reduction to the corporate tax rate, an expansion of the list of items not subject to GST, corporate tax incentives, an extension of the statue of limitations for transfer pricing adjustments, and increased withholding for real property gains tax writes EY in an October 16 report. For details, see EY.
Asia-Pacific
Japan’s tax agency closes record number of MAP cases
Japan closed 174 mutual agreement procedure (MAP) cases during the fiscal year ending June 30, 2014, a record high, Japan’s National Tax Agency (NTA) said in an . . .
Asia-Pacific
Australian draft law imposes withholding tax on foreign resident property sales
The Australian goverment on July 7 launched a consultation on proposed legislation that would impose a 10 percent withholding tax on the disposal of Australian property by foreign residents. The tax is designed to . . .
Asia-Pacific
Israeli draft guidance imposes corporate tax and VAT on foreign Internet companies
Yuval Navot, a partner with Herzog, Fox & Neeman, Tel Aviv, analyzes draft guidance released by the Israel Tax Authority on April 2 which specifies when a foreign Internet firm has a permanent establishment in Israel giving rise to corporate taxation and has business activity in Israel requiring VAT registration.
Asia-Pacific
Japan moves forward with consumption tax on cross-border supply of digital services
Masao Yoshimura, an Associate Professor of Tax Law at Hitotsubashi University’s Graduate School of International Corporate Strategy, analyzes a Japanese government proposal passed by the Lower House March 13 which would impose consumption tax on the supply of digital services by foreign providers. . .
Asia-Pacific
BDO Australia snags ten tax specialists from Pitcher Partners, including Ball and Townsend
Chris Ball, Adele Townsend, and eight other tax specialists left Pitcher Partners to join BDO’s tax team in Brisbane on February 2, BDO has announced. Ball and Townsend join . . .
Americas
US–Kazakhstan competent authority agreement published
The US has released the text of an agreement signed by competent authorities of the US and Kazakhstan which concerns the eligibility of entities that are treated as fiscally transparent under a double tax agreement signed by the countries
. . .
Asia-Pacific
Australia releases guidance on transfer pricing documentation and penalties
The Australian Taxation Office (ATO) on December 17 released a final ruling and two practice statements dealing with transfer pricing documentation and penalties. Final ruling TR 2014/8 outlines . . .
Asia-Pacific
Australia Senate committee to hold hearings on corporate tax avoidance
Australia’s Senate on Oct 2 voted to conduct hearings on aggressive tax minimization by corporations registered in Australia and by multinational corporations operating . . .
Asia-Pacific
Macau to adopt new standard for automatic exchange of financial information
Macau’s Financial Services Bureau on Sept. 26 announced its support for the common reporting standard for automatic exchange of financial account information. Procedures will be initiated to amend Macua’s laws to ensure timely compliance with the new standard, the agency said. Release.
Asia-Pacific
Asia-Pacific
Hong Kong and South Korea sign double tax agreement, text available
Hong Kong and Korea, on July 8, signed an agreement for the avoidance of double tax and fiscal evasion with respect to taxes on income .
Under the agreement, the Korean withholding tax on interest
. . .
Asia-Pacific
ATO rules that companies with substantial equipment PEs are not deemed to carry on business for purposes of determining non-assessable non-exempt income
The Australian Taxation Office (ATO), in TR 2014/3 released June 11, has ruled that a company
. . .
Asia-Pacific
Australia releases draft legislation to implement revised tax treaty with Switzerland, requests comments
The Australian Government, on May 4, released draft legislation that would give the revised Australia-Swiss tax treaty and accompanying protocol, signed . . .
Americas
Australian official says six nations jointly investigating e-commerce firms; reviews ATO work on BEPS
An Australian Taxation Office (ATO) official, on May 22, confirmed that Australia and five other nations are collaborating to investigate the global tax planning of multinationals operating in the e-commerce industry.
Mark Konza, ATO Deputy Commissioner, International, said that Australia was “currently involved in a cooperative compliance approach” with five other nations. The collaboration led to the production of an
Asia-Pacific
New Zealand government to move forward proposal allowing tax-free cancellation of related party debt
Revenue Minister Todd McClay on September 3 announced that the New Zealand goverment will introduce tax legislation early next year providing that there will be no income to a debtor upon the cancellation of a debt owed to a . . .
Americas
Japan and UK exchange notes on new business profits article for tax treaty
Japan and the UK have exchanged notes on a new article on business profits under the Japan-UK tax treaty, the Japanese government announced July 22. New Article 7 introduces provisions concerning . . .
Asia-Pacific
Asia-Pacific
Singapore worries BEPS work will be used to justify protectionist laws
The OECD/G20 base erosion profit shifting (BEPS) project work should not be used to adopt protectionist measures, Josephine Teo, Singapore Minister of State for Finance and Transport . . .
Asia-Pacific
OECD BEPS Eurasia regional meeting draws tax officials from only six nations
Tax officials that attended an OECD Eurasia regional meeting on base erosion and profit shifting (BEPS) welcomed the OECD’s effort to involve developing nations in the BEPS project, but said that barriers prevent nations in the region from participating, according to a report released March 10. These barriers were apparent as representatives of only six nations attended the regional meeting, held in Ankara, Turkey, on March 5-6.. . .
Asia-Pacific
China to monitor MNE profit levels and coordinate with other nations to fight BEPS
“China will comprehensively monitor the profit levels of foreign companies to make sure there is no base erosion and profit shifting,” Zhang Zhiyong, deputy director of the State Administration of Taxation (SAT) said December 1, the government’s news agency, Xinhua, has reported. Zhang also said that China intends to . . .
Africa
OECD publishes MAP statistics of member countries
The OECD on November 25 released 2013 statistics on the mutual agreement procedure (MAP) caseload of OECD member counties and partner economies of Argentina, China, Latvia, and South Africa. According to an accompanying OECD . . .
Asia-Pacific
UK/Japan protocol and exchange of notes enters into force
A protocol and exchange of notes between the UK and Japan, signed December 17, 2013, will enter into force on December 12, the UK government announced November 12.The protocol . . .
Asia-Pacific
Singapore and Sri Lanka sign new tax treaty
Singapore and Sri Lanka signed a revised income tax treaty on April 3. Among other changes, the treaty lowers withholding tax rates for dividends and royalties and modifies provisions for determining permanent establishments. The treaty will enter into force after ratification by both countries. Treaty
Asia-Pacific
Asia-Pacific
Australia releases draft law to implement common reporting standard
Australia on September 18 released draft legislation to implement the OECD’s Common Reporting Standard for the automatic exchange of financial account . . .
Asia-Pacific
China and South Korea sign bilateral APA
China and South Korea have signed a bilateral advance pricing agreement, the Chinese goverment announced in a June 23 English-language release. The signing took place during a Sino-South Korea tax commissioners meeting . . .
Asia-Pacific
India, Japan to settle transfer pricing disputes under MAP
India and Japan are poised to resolve about 15 transfer pricing disputes under the mutual agreement procedure involving the automobile industry and large trading houses, writes Jayshree P Upadhyay of the Business Standard in a May 27 article. India also expects to soon resolve transfer pricing disputes involving the UK and France. See, Business Standard.
