Vietnam: Amendments to Corporate Income Tax Law
The general tax rate in Vietnam will be reduced to 22% from 1 January 2014. Also from 1 January 2016 the tax rate will be 20%. This measure was approved by the National Assembly on 19 June 2013. The reduced tax rates are competitive with the
See MoreTreaty between Liechtenstein and Singapore signed
Singapore and Liechtenstein signed an Income Tax Treaty on 27 June 2013. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the calendar year
See MoreTreaty between Japan and Portugal enters into force
The governments of Japan and the Portuguese Republic signed an income tax treaty in December 2011. The mutual notifications of the completion of the necessary domestic procedures were completed on 28th June 2013 and in accordance with Article 28 of
See MoreTaiwan: Change to tax on gains from share transfer
Taiwan government passed the amendment to the Income Tax Act on 25 July 2013 about the taxation of gains arising from share transfers by individuals. Under this modification, no income tax will be obligatory on gains from share transfers even if the
See MorePakistan: Supreme Court rules against increase in sales tax
The Supreme Court (SC) ruled on 21 June 2013, that the government was not ratified to impose or increase sales tax from 16% to 17% on the value of taxable supplies by way of declaration under section 3 of the Provisional Collection of Taxes Act 1931
See MoreChina: VAT rate on coalbed methane, shale gas production
The State Administration of Taxation of China has issued guidance according to which oil and gas companies engaging in coalbed methane and shale gas production—or providing production services for coalbed methane and shale gas production are
See MoreIndonesia: Issued regulations on tax rates for Small and Medium Enterprises
The government of Indonesia issued Regulation No. 46/2013 on 12 June 2013 named as The Regulation for Taxation of Small and Medium Enterprises. This will be effective from 1 July 2013. As per the regulation issued a final tax rate of 1% will be
See MoreIndia: Internal TNMM will be given priority over external TNMM
The Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) recently it has been held that the transactional net margin method (TNMM) does not require a similarity of products and that internal TNMM analysis is acceptable for determining the
See MoreDTA between Ecuador and Singapore signed
Singapore and Ecuador signed an Agreement for the Avoidance of Double Taxation (DTA) on 27 June 2013. The provisions of the treaty will have effect from 1 January of the calendar year next following that in which the agreement enters into
See MoreTaiwan: Parliament Passes Revised Capital Gains Tax on Stocks
The Government amendment to the Income Tax Act on 26 June 2013, which would drop the plan for an 8,500-point TAIEX threshold that automatically triggers the capital gains tax for individual investors, a move expected to boost the stock market. Under
See MoreIndia: CBDT has withdrawn the guideline of profit-split method for transfer-pricing transactions, and amends the circular on contract R&D
The Central Board of Direct Taxes (CBDT) withdrew Circular No. 2/2013 on June 2013as it gives the impression that the profit split method is the preferred method in cases involving unique intangibles or in multiple interrelated international
See MoreHong Kong: Tax reduction bill
The Inland Revenue (Amendment) (No. 2) Bill 2013 was passed on 26 June 2013 by the Hong Kong Legislative Assembly to implement the tax reduction measures proposed in the 2013-14 Budget. The concessionary revenue measures highlight the following
See MoreDocumentation Considered in Malaysia’s First Transfer Pricing Case
The Special Commissioners of Income Tax in Malaysia delivered a landmark decision on February 2013 in the favour of the taxpayer in the first transfer pricing litigation in Malaysia. The case concerned assessments on a shipping and logistics
See MoreIndonesia: New Regulation on Transfer Pricing Audits
Regulation PER 22/PJ/2013 has been published by the Indonesia’s Directorate General of Taxation (DGT) on 30 May 2013 to provide guidelines for audits of taxpayers with related-party relationships and repealed the regulation KEP-01/PJ 07/1993
See MoreIndia: CUP method for benchmarking service contracts
In a recent decision of Income Tax Appellate Tribunal (“ITAT”) it was held that for benchmarking service contracts when comparable data for these contracts is available the comparable uncontrolled price (CUP) method is the most suitable method.
See MoreIndia: Transfer Pricing Reporting Requirements
Recently India’s Central Board of Direct Taxes issued guidance that expands the transfer pricing reporting requirements of certain international transactions and certain “specified domestic transactions.” To bring into line those reporting
See MoreIndia: Extensive Guidance Note on APA
Recently the Central Board of Direct Taxes (CBDT) of India published a comprehensive APA Guidance Booklet concerning India’s advance pricing agreement (APA) program, detailing the procedural aspects of unilateral, bilateral or multilateral APA
See MoreIndia: Listed price cannot be used under the Comparable Uncontrolled Price (CUP) method
In a recent decision, the Chennai Bench of the Income-tax Appellate Tribunal held that the list price on a manufacture’s website is only an “indicative price” and so the list price alone cannot be used to determine the arm’s length price of
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