India: Tax Court rules on selection of comparables
In determining transfer prices between a taxpayer and related parties one of the permitted methods is the transactional net margin method (TNMM). This compares profit margins to an appropriate base such as sales, assets or costs realized from a
See MoreTaiwan: Pilot free trade zones to be established
Taiwan has revealed that pilot free trade zones are to be established to liberalize the island’s economy and upgrade the industrial structure. The Council for Economic Planning and Development (CEPD) aims to attract high value-added industries
See MoreAustralia: Publication of changes in Pension Taxation
The Australian government has published a plan for the tax exemption on pension earnings in superannuation accounts to be capped at $100,000, with any amounts above that threshold to be taxed at 15%. Currently a 15% tax applies to earnings from
See MoreKorea: Update on rules for application of arm’s length standard to head office–branch transactions
Korea’s Ministry of Strategy and Finance has issued new regulations to clarify the method for calculating domestic-source income from intra-company transactions between a foreign head office and its Korean branch. This follows the passing of the
See MoreChina: Non-resident enterprises – tax collection in 2012
A report on statistics compiled by China’s State Administration of Taxation (SAT) indicates that the tax paid in 2012 by non-resident enterprises in China showed a slight increase, following a sharper rise in the previous year, and amounted to
See MoreIndia: Guidelines for application of the profit split method
India’s Central Board of Direct Taxes (CBDT) has issued Circular No. 2 of 2013, setting out guidelines for application of the Profit Split Method (PSM) in international transactions. The profit split method is one of the permitted methods for
See MoreTreaty between Serbia and Vietnam signed
Serbia and Vietnam signed a Double Tax Treaty in Hanoi on 1 March
See MoreSingapore: Budget for 2013
The Budget for 2013 was presented to Parliament by the Finance Minister on 25 February 2012. The Budget aims at increasing productivity and growth. Major changes include income tax rebates and restructuring of the Progressive Property Tax Regime
See MoreUK: Protocol to the double tax agreement with China
A protocol to the treaty between the UK and China was signed on 27 February 2013. This protocol amends the dividend article of the 2011 tax treaty between the UK and China which is not yet in force. Both the treaty and protocol will enter into force
See MoreIndia: Budget for 2013
According to the Indian Budget 2013, the Government is considering for following major tax initiatives: the introduction of a Direct Tax Code (DTC), a goods and services tax (GST) and General Anti-Avoidance Rules (GAAR). The main changes are
See MoreJapan: For 2013 tax reform proposals
The Tax Commission of Japan has submitted 2013 tax reform proposal on January 29, 2013 upon approval by the Cabinet. The suggested reform will be submitted to the Diet during February 2013 for consideration. The proposed main changes are summarized
See MoreAustralia: New Transfer Pricing Legislation
On 13 February 2013, the Federal Government introduced legislation on 13 February containing new Australian Transfer Pricing Laws. These are largely consistent with the Exposure Draft (ED), released in November 2012. The new enactment adjusts
See MorePhilippines: New Transfer Pricing Regulations
The Philippines’ Secretary of Finance issued Revenue Regulations (RR) No. 02-2013 – the transfer pricing regulations – on 23 January 2013, which became effective from 9 February 2013. The new regulations provide guidance in applying the
See MoreKorean government releases revised tax reforms enforcement ordinance
The Ministry of Strategy and Finance (MOSF) on 17 January 2013 announced that the revised tax reforms enforcement decree would be released in mid-February. This decree will provide for the enforcement of amendments made to a number of tax laws,
See MoreIndia: General Anti-Avoidance Rule For 2014
The General Anti –Avoidance Rule (GAAR) of India had been scheduled to be implemented from April 2014. After further consultation the provisions will however now come into effect from April 1, 2016 and these provisions would be used to target only
See MoreAzerbaijan: Exemption of interest from individual income tax on savings deposits
The Parliament of Azerbaijan approved Law No. 542-IVD on 28 December 2012. According to this law interest paid on saving deposits of individuals in banks and other credit institutions is exempt from individual income tax for the period of one year.
See MorePhilippines: Transfer Pricing Regulations
On 23 January 2013, the Philippines Secretary of Finance issued transfer pricing regulations (Revenue Regulation (RR) No. 02-2013). The regulations provide guidance for applying the arm’s length principle for pricing in related-party transactions
See MoreTax treaty between Hong Kong and Italy has been signed
Hong Kong has signed an agreement on 14 January 2013 with Italy for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. The agreement generally follows the provisions of the OECD Model and has
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