China-Rules on advance pricing agreements updated
The State Administration of Taxation of China issued an announcement updating the rules on advance pricing agreements (APAs) (SAT Gong Gao No. 64) on 11 October 2016. The announcement seeks to improve APA management and implement the tax treaties
See MoreAustralia: Draft taxation ruling on timing for PE
On 12 October 2016, the Australian Taxation Office (ATO) released for comment Draft Taxation Ruling TR 2016/D2 that provides guidance on applying the participation test in Subdivision 768-A when working out whether an equity distribution received by
See MoreSingapore: Publishes Guidance on CbC Reporting
The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory on 10 October 2016, which sets out entities are obliged to report and
See MoreHong Kong: The Inland Revenue Department clarifies the guidance on corporate treasury centre rules
The Inland Revenue Department issued the Departmental Interpretation and Practice Notes No. 52 (“Taxation of Corporate Treasury Activity”) which sets out the Department’s interpretation and practice in relation to the relevant provisions in
See MoreVietnam: Publishes Circular on tax incentives
The Ministry of Finance (MoF) on 17 June 2016, issued Circular No. 83/2016/TT-BTC which provided guidance on the implementation of investment tax incentives with regard to corporate income tax, import tax and non-agricultural land use tax. The key
See MoreChina: New changes of TP regulations
SAT Bulletin No. 42 published on July 13, 2016 has replaced the existing transfer pricing documentation regulations in Circular Guoshuifa No. 2, known as Circular 2. As per Bulletin 42, two parties will be considered related if they have “other
See MoreG20 leaders comment on tax policy
The final communiqué from the G20 summit held in Hangzhou, China on 4 and 5 September 2016 began by noting that although the global economy is recovering from the crisis growth is still relatively weak. New sources for growth are emerging but
See MoreNew Zealand: Implementation of BEPS Action 2-hybrid mismatch
The government of New Zealand released a consultative discussion document on 6 September 2016 containing proposals for addressing hybrid mismatch arrangements. The document proposes that New Zealand adopts the 2015 OECD recommendations on hybrid
See MoreIsrael: CbC reporting, transfer pricing documentation in budget plan
The Ministry of Finance’s budget plan for 2017-2018 has been approved by the Israeli government on 12th August 2016 that includes tax legislative measures. This budget plan covers: CbC reporting requirement: General rule: The Israeli budget plan
See MoreIsrael: Tax provisions in proposed budget plan for 2017-2018
The budget plan proposal for 2017-2018 announces significant changes in accordance with international taxation, and would be appropriate for individuals, multinational corporations operating in Israel and Israeli corporations operating abroad. The
See MorePhilippines: Presents budget for 2017
The National Budget 2017 was submitted to the House of Representatives on 15 August 2016. According to the budget proposal the income tax rates will be decrease at rate: for corporations: from the current maximum amount of 30% to 25%; for
See MorePakistan: Changes capital gains tax and immovable property
The President of Pakistan has circulated the Income Tax (Amendment) Ordinance, 2016 to further amend the provisions regarding valuation of immovable properties under the Income Tax Ordinance 2001 (the Ordinance). Main features of the Amendment
See MoreIsrael: Tax benefits in draft Budget Law
The Finance Ministry has declared a draft proposals as part of the proposed Economic Arrangements Law 2017–2018 on 31st July 2016 that includes an expansion of tax benefits for hi-tech companies, at the same time further aligning Israel's tax
See MorePakistan: Government has decides to apply 0% sales tax on five export sectors
The government has decided to zero-rate for the local suppliers of textile, leather, carpets, surgical and sports sectors from 2016-17. According to the meeting between textile sector and Finance Minister, Five Export Sectors'' Associations,
See MoreIndia: The tribunal held the Comparable Uncontrolled Price is the most appropriate method
The Delhi Bench of the Income-tax Appellate Tribunal upheld the decision in the case of: Liugong India Private Ltd. v. ACIT (ITA No. 1482/Del/2015) and decided that when comparable are available, the CUP method is the best method to use in
See MoreDTA between Czech Republic and Iran enters into force
The Income Tax Treaty (2015) between Czech Republic and Iran has been entered into force on 4th August 2016 and it generally applies from 1st January
See MoreChina issued new rules on TP documentation requirement
China issued Bulletin 42 to introduce a requirement for a master file for MNC group resident in China if their annual inter-company transaction amount exceeds RMB 1 billion. The master file requirement is effective from fiscal year 2016. A master
See MoreKorea: Revised draft legislation on transfer pricing and country-by-country reporting
The South Korean Ministry of Strategy and Finance has recently released a draft legislation which would amend the existing provisions of Article 11 of the Korean Law which is known as the “Law for the Coordination of International Tax Affairs”
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