India: High Court Rules on Use of Multiple Year Data and High-Profit Comparables
Recently, the High Court (HC) issued its decision in the transfer pricing case of Chrys Capital Investment Advisors (India) Pvt. Ltd v. DCIT (ITA No. 417 of 2014) on the usage of multiple year data and high-profit comparables on 27 April 2015. The
See MorePakistan: Compulsory Electronic tax return Filing for Individuals
The Federal Board of Revenue announced via Notification S.R.O. 791 (I) /2015 on 10 August 2015, that all individuals earning taxable salary income must file their income tax returns electronically. This will be effective from tax year 2015
See MoreKorea: Draft law for implementing BEPS-related transfer pricing requirements
The Ministry of Strategy and Finance of South Korea has released draft legislation for amending existing provisions of Korean law. The draft legislation generally follows Action 13 of the OECD/ G20 project on base erosion and profit shifting
See MoreIndia: Interest on tax refund taxable as business income under the India-UK tax treaty
Recently, the High Court in the case of B.J. Services Company Middle East Limited held that the interest earned on an income tax refund is taxable as business income under the India-UK tax treaty where the debt claim in respect of which interest
See MoreVietnam: Publishes Guidance on Tax Administration
Circular 110/2015/TT-BTC was issued on 28 July 2015 and provides guidance on tax administration and compliance by electronic means. The Circular replaces earlier Circulars 35/2013/TT-BTC and 180/2010/TT-BTC, and includes guidance on tax
See MoreChina: Tax incentives for small and low-profit enterprises
On August 19, State Council of China decided to improve the tax breaks available for small and low-profit enterprises. Small and low-profit enterprises can pay their income taxes at the rate of 20% with following conditions: any industrial
See MoreAustralian Taxation Office releases GAAR guidelines
The Australian Taxation Office released for comment a draft practice statement PS LA 2005/24 which deals with the application of the general anti-avoidance rules (GAAR) in Part-IVA of the Income Tax Assessment Act 1936 on 13 August 2015. This Draft
See MoreKazakhstan: Tax treatment liabilities provided by non-resident’s head office
The State Revenue Committee of Kazakhstan has issued a Letter No. КГД-07-3-ЮЛ-Е-14-КГД-14754 on 15th July 2015 regarding tax treatment of bad debts provided by a non-resident company's head office to its Kazakh branch. In accordance with
See MoreKorea- Tax Amendments of 2015 with incentives for foreign investment
The Ministry of Strategy and Finance of Korea announced on 6 August 2015 its proposed tax law amendments for 2015. The proposed tax law amendments of 2015 limit the eligibility for tax reductions for foreign investments. The proposed law excludes
See MoreSingapore: Corporate Tax Filing for 2015
The Inland Revenue of Singapore (IRAS) has reminded all companies to file their income tax returns for the 2015 assessment year by 30 November 2015. This is the first year that all companies in Singapore have the e-filing facility. All companies are
See MoreHong Kong-Italy income tax treaty enters into force
The income tax treaty between Hong Kong SAR and Italy entered into force on 10 August 2015. The treaty was signed on 14 January 2013. The agreement generally applies from 1 January 2016 for Italy and from 1 April 2016 for Hong
See MoreSingapore Publishes e-Tax guide to Mergers and Acquisitions Scheme
The Inland Revenue Authority of Singapore (IRAS) issued a revised e-Tax guide on 13 July 2015 to provide more details on the refinements to the mergers and acquisitions (M&A) scheme as recently stated in the Budget 2015. The complete e-Tax guide
See MoreRussia: Authorization for signature to tax agreement with Hong Kong
The Government of Russia has authorized the Finance Ministry to sign the draft text of the tax agreement between Hong Kong and Russia and it was released on 6th August 2015 for public
See MoreJapan: Introduction of Tax Identification System from 2016
The National Tax Agency (NTA) of Japan has announced that a new tax identification number system ("My Number") will be introduced for both individuals and corporations in October 2015. The NTA will provide the 12-digit number to all relevant
See MoreThailand-Tax incentive for the expenditures of research and development (R&D) of technology and innovation
The cabinet of Thailand has passed a tax incentive for the expenditures occurred in the R&D sector of technology and innovation. The tax incentive has become effective as from 1 January 2015 to 31 December 2019. Accordingly a tax deduction of up
See MoreAustralia: Stronger penalties to fight against multinational tax avoidance
The Government of Australia announced double the maximum administrative penalties that can be applied by the Commissioner of Taxation to large companies that enter into tax avoidance and profit shifting schemes. The increased penalties, under
See MoreCanada-India: Social Security Agreement entered into force
A Social Security Agreement between Canada and India enter into force from 1st August 2015 that was signed on 6th November 2012. It also effects from the same date of entry into
See MoreAustralia: New transfer pricing documentation standards
On 6 August 2015, the Australian Treasury released exposure draft law to implement reporting requirements for large multinational businesses in line with recommendations by the OECD and G20. In the 2015-16 Budget, the Australian government announced
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