Vietnam clarifies the tax implications of interest income
On 24 October 2019, the Tax Authority issued an official letter (No. 80503 / CT-TTHT) explaining the tax implications of interest income on term loans. The letter clarifies that loan interest earned in Vietnam is subject to withholding tax. The
See MoreNew Zealand: Inland Revenue clarifies about BEPS disclosure requirement
Recently, the New Zealand's Inland Revenue has introduced the Base Erosion and Profit Shifting (BEPS) disclosure requirement to support the new BEPS rules, including the expanded information collection powers applying to large multinational groups.
See MoreHong Kong publishes an order to implement the tax agreement with Estonia
On 9 October 2019, the Hong Kong’s Chief Executive in Council made an order under the Inland Revenue Ordinance (Cap. 112) to implement the Comprehensive Avoidance of Double Taxation Agreement with Estonia (Estonia CDTA) that was signed on 25
See MoreHong Kong publishes an order to implement protocol with Mainland (China)
On 2 October 2019, the Hong Kong’s Chief Executive in Council made an order under the Inland Revenue Ordinance (Cap. 112) to implement the Fifth Protocol to the Comprehensive Avoidance of Double Taxation Arrangement with the Mainland (Mainland
See MoreHong Kong publishes an order to implement the tax agreement with Cambodia
On 2 October 2019, the Hong Kong’s Chief Executive in Council made an order under the Inland Revenue Ordinance (Cap. 112) to implement the Comprehensive Avoidance of Double Taxation Agreement with Cambodia (Cambodia CDTA) that was signed on 26
See MoreMalaysia: IRBM issues income tax penalties for late return
On 16 October 2019, the Inland Revenue Board of Malaysia issued Operational Guideline No. 5/2019, which sets out the penalties for taxpayers who fail to file the tax returns within the prescribed timelines under the Income Tax Act 1967, the
See MoreTaiwan: MOF issues tax ruling on Taiwan-sourced income of foreign entities
On 26 September 2019, Taiwan’s Ministry of Finance (MOF) released a tax ruling regarding the new method of calculating income source from Taiwan originating from foreign entities amending article 15-1 in accordance with Article 8 of the Income
See MoreMalaysia: Finance Minister presents the budget for 2020
Malaysia's Minister of Finance tabled in parliament the Budget for 2020. The budget provides the following tax measures: The SME income tax rate for Chargeable Income up to the first RM500,000 was reduced by 1% to 17% in 2019. To further
See MoreIndia: CBDT amends rules to calculate interest income relating to Secondary Adjustments
On 30 September 2019, the Central Board of Direct Taxes (CBDT) has amended rule 10CB which provide for computation of interest income relating to secondary adjustments. The changes remove anomalies and clarify the compliance and computational
See MoreHong Kong: IRD revises practice notes on deduction of foreign taxes
In the middle of August 2019, the Hong Kong Inland Revenue Department (IRD) revised Departmental Interpretation and Practice Notes No. 28 regarding Deduction of Foreign Taxes (“DIPN 28”). The updated version replaced the one issued on 19 July
See MoreIndia: MLI enters into force
On 1 October 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force with respect of India. On 25 June 2019, India has deposited its instrument of ratification
See MoreIndia: ITAT ruled that the Liaison Office of Hitachi constitutes a PE
On 17 September 2019, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of: Hitachi High Technologies Singapore Pte Ltd vs. DCIT , held that a Liaison Office (LO) of Hitachi Technologies Singapore Pte Limited constituted a
See MoreHong Kong and Estonia sign new tax treaty
On 25 September 2019, the Secretary for Financial Services and the Treasury of Hong Kong and the Minister of Finance of Estonia signed a comprehensive avoidance of double taxation agreement (CDTA) in Tallinn, Estonia. The agreement sets out the
See MoreMalaysia withdraws withholding tax exemptions available to MSC Malaysia status companies
Malaysia Digital Economy Corporation Sdn Bhd (MDEC) has recently announced on its website that the withholding tax (WHT) exemption on certain types of income received by a non-resident company from an approved Multimedia Super Corridor (MSC)
See MoreThailand: BOI approves Thailand Plus incentive package
On 20 September 2019, Thailand Board of Investment (BOI) approved a set of new incentive measures aimed at attracting foreign business to relocate and expedite large-scale investment as well as strengthening workforce development. These new
See MorePhilippines: BIR issues guidelines for transfer pricing audits
The Bureau of Internal Revenue (BIR) has issued Transfer Pricing Audit Guidelines under Revenue Audit Memorandum Order (RAMO) No. 1-2019 on 20 August 2019, which provides standardized audit procedures and techniques in auditing taxpayers with
See MoreIndia cuts corporate tax rate for domestic companies
On 20 September 2019, the Government of India introduced the Taxation Laws (Amendment) Ordinance, 2019. According to the Ordinance, the government makes certain changes to the Income Tax Act of 1961 and the Finance Act (No 2) of 2019. The main
See MoreAustralia updates guideline for simplified transfer pricing record keeping options
On 11 September 2019, the Australian Taxation Office (ATO) released an updated version of Practical Compliance Guideline (PCG) 2017/2 concerning the eligibility criteria for applying simplified transfer pricing record keeping options for
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