The US Treasury Department has updated its FATCA website, reporting that Qatar has signed a Model 1 intergovernmental agreement (IGA) with the United States as of January 7. The text of the agreement is available. See, agreement.
Bureau of Internal Revenue Commissioner Kim S. Jacinto-Henares has been appointed by UN Secretary General Ban Ki Moon as a member of the UN Committee of Experts on International Cooperation in Tax Matters in accordance with Economic and Social Council (ECOSOC) Resolution 2004/69, according to a November 4 press release.
Hong Kong and South Africa have signed an agreement for the avoidance of double taxation and . . .
KPMG in India on Sept. 10 announced that Dinesh Kanabar will leave his post as Deputy CEO to start his own venture. Kanabar, a frequent speaker at international tax conferences, has been with KMPG for 4 years. release
China’s State Administration of Taxation has announced that a tax treaty and protocol signed by China and The Netherlands on May 31, 2013, will enter into force on August 31. Press release (Chinese).
Australia’s Inspector General of Taxation, Ali Noroozi, on June 2, released a comprehensive report on the Australian Taxation Office’s (ATO) management of transfer pricing matters. The document is dated December 2013. Report (PDF 2.9 MB)
Singapore’s agreement with Barbados for the avoidance of double taxation entered into force on 25 April 2014. Release
China and Germany signed a new income tax treaty and protocol on March 28, according to a report by EY.
Masao Yoshimura, an Associate Professor of Tax Law at Hitotsubashi University’s Graduate School of International Corporate Strategy, analyzes a July 17 decision of the Supreme Court of Japan concluding that Delaware limited partnerships should be classified as corporations for tax purposes . . .
Indian Finance Minister Arun Jaitley on April 26 said that his administration has no choice but to impose minimum alternative tax (MAT) on capital gains of foreign institutional investors, calling it a legacy from . . .
Responding to taxpayer requests, India’s Central Board of Taxation on March 31 announced an extension of the deadlines to apply for rollback of an advance pricing agreement (APA) for existing APAs and pending APA applications. June 30 is now the deadline to apply . . .
The Indian government intends to defer implementation of its general antiavoidance rules (GAAR) to avoid harming investor confidence, and will likely make an announcement to that effect in the 2015-16 budget, writes the Times of India in a February 14 article, quoting an unnamed source. See, Times of India, See also, Financial Express, The Economic Times.
The United Arab Emirates and Barbados, on Sept. 26, signed an agreement on the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The agreement emphasizes the desire of both countries to avoid double taxation on the income of individuals and companies, commercial sea and air transport, and on other similar taxes. Release
The United Arab Emirates and the United States, on June 10, agreed in substance to a Foreign Account Tax Compliance Act (FATCA) intergovernmental agreement (IGA), according to reports from the Abu Dhabi City Guide and the Khaleej Times.
The agreement was signed in Canberra on 28 April. U.S. Government Press Release
The Philippines Department of Finance is pressing for passage of the Tax Incentives Management and Transparency Act and the Fiscal Incentives Rationalization Reform Bill, stating that the bills would create a more transparent and accountable system for granting of tax incentives. The agency notes that tax incentives cost the government at least 1.5% of GDP in 2011 and that the International Monetary Fund supports the reform of the fiscal incentives structure.
Release
India has signed 11 more unilateral advance pricing agreements (APAs) with multinationals, bringing total APAs signed by the government so far this fiscal year to 22, the India’s Central Board . . .
Indian government on November 20 released more details of its plan, announced in Finance Minister Arun Jaitley’s budget speech, to reduce the corporate tax from 30 percent to 25 and to phase out deductions . . .
The European Commission on October 19 asked the Netherlands to amend the limitation on benefits clause in its tax treaty with . . .
Australia and Germany will soon begin negotiations to update their 1972 tax treaty, Australian Treasury announced June 16. The Australian government has requested stakeholder . . .
China’s State Administration of Taxation (SAT) on March 18 announced that it will no longer permit deductions for royalty fees paid to an overseas related party that did not contribute to the creation of the intangible asset or allow deductions for fees paid to an overseas related party for services that do not provide economic benefit to the subsidiary, writes Dezan Shira & Associates in the March 25 edition of the China Tax Briefing. In its guidance, . . .
Taiwan’s Ministry of Finance, on January 30, advised that deductions or losses from a profit-seeking enterprises’ interest expenditures will be restricted to amounts that are reasonable and necessary, and that loans are not necessary if the company has . . .
The Indian government will not appeal the Bombay High Court’s decision in Vodafone, accepting the Court’s conclusion that transfer pricing laws can not be used to tax an Indian subsidiary’s issuance of shares at a premium to its overseas parent. The decision was announced by Telecom minister Ravi Shankar Prasad during a January 28 press conference following a Union Cabinet meeting. Prasad noted that the Bombay High Court . . .
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UPDATE (1/29/2015): India to apply principles in Vodafone transfer pricing ruling to all cases: The Indian government on January 29 explicitly instructed tax officials to apply the rational behind the Bombay High Court’s decision in Vodafone to all tax cases. Tax officials must follow . . .
Singapore and France have signed a revised tax treaty, Singapore’s the Ministry of Finance and France’s Ministry for Finance and Public Accounts said in a joint statement January 16. The agreement lowers . . .
The National Taxation Bureau of Taipei, Ministry of Finance, (NTBT) on November 7 provided an English-language description of NTBT regulations on the process foreign businesses should use to apply to exempt profits from taxation pursuant to a tax treaty. Taiwan release.
Orders made by Hong Kong’s Chief Executive in Council under the Inland Revenue Ordinance, to implement Hong Kong’s tax treaty with Korea, signed July 2014, and its second protocol . . .
The Philippines has become the 68th signatory of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. The standard calls on governments to obtain detailed account information from their financial institutions and exchange that information automatically with other jurisdictions on an annual basis. The Convention must be ratified by The Philippines to enter into force. Release
China’s State Administration of Taxation (SAT) on August 27 announced revisions to the VAT exemption for cross-border services writes to Dezan Shira & Associates in a Sept. 8 post to the firm’s website. Changes include
. . .
An Australian law to give effect to the FATCA intergovernmental agreement between Australia and the United States received royal assent on June 30. For the text and history of the law, see: Tax Laws Amendment (Implementation of the FATCA Agreement) Bill 2014. For more analysis, see King & Wood Mallesons
The Indian tax authority may soon sign advance pricing agreements with Japan and India, reports Remya Nair of LiveMint.
The Indian government has published final transfer pricing rules that allow use of multiple year data for comparability purposes and introduce the use of a range to determine arm’s length . . .
India’s government will propose tax law amendments that clarify that foreign institutional and portfolio investors (FIIs/FPIs) are not subject to the minimum alternate tax (MAT) on their pre-April 1 income, Finance Minister Arun Jaitley told a news conference . . .
G7 leaders, in a joint declaration issued June 8, made a “commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment.” The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .
UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders’ expression of support for compulsory binding arbitration in multinational tax disputes “deeply troubling,” stating . . .
A high level committee constituted by India’s finance ministry has invited taxpayers, associations, and other stakeholders to set up meetings with the committee to discuss ways to clarify India’s tax laws. The . . .
Portugal, on March 5, ratified at tax treaty Georgia, signed December 12, 2012. An English-language version of the treaty is available
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