The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .
Chau Huy Quang and Cao Dang Duy of Rajah & Tann LCT Lawyers, Hanoi, discuss a new Vietnam draft law which would establish uniform transfer pricing rules, including an expansive definition of “related party transactions,” and impose new conditions on the deductibility of common expenses arising between related parties, such as interest and service fees . . .
The US is considering changes to draft US Model Income Tax Convention provisions released last May, including several changes to provisions that deny tax treaty benefits to related party payments that are subject to a special tax regime (STR) . . .
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 . . .
The second protocol to the agreement between Hong Kong and Vietnam for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income has entered into force, Hong Kong’s Inland Revue Department (IRD) announced February 23. The protocol came into . . .
Vietnam’s campaign against transfer pricing abuse has yielded positive results, the Ministry of Finance said on Sept. 23.
At least 870 Vietnamese enterprises with foreign direct investment have been placed on a “black list” by tax inspectors . . .
Tax officials from 21 Asia Pacific countries and organizations attended an OECD regional network meeting on base erosion and profit shifting (BEPS) designed to give more nations a voice in the development of OECD/G20 base erosion profiting shifting (BEPS) plan output. The meeting, held February 12–13 in Seoul, also . . .