Indonesia: 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See MoreIndia: CBDT has withdrawn the guideline of profit-split method for transfer-pricing transactions, and amends the circular on contract R&D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of Taxation (DGT) on 30 May 2013 to provide guidelines for audits of taxpayers with related-party relationships and repealed the regulation KEP-01/PJ 07/1993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
See MoreAustralia: Practice statement on Transfer Pricing
The Australian Customs and Border Protection Service (Customs) has published Practice Statement B_IND08 “Valuation-Transfer Pricing Policy” and this new practice statement will replace Practice Statement PS 2009/21 on the subject. The
See MoreVietnam: Corporate tax reduced to 22% from 2014
The Ministry of Finance planning to cut corporate income tax rate 22% from the current 25% with effect from 1 January 2014 next year and the government wants to bring the rate down further to 20 percent in the 2016-2020 period. However, the new
See MoreNetherlands and China tax treaty is signed
A new China and Netherlands Income Tax Treaty was signed on 31 May 2013 in Beijing. Once in force, the new treaty will replace the current Income Tax Treaty of 1987. Neither treaty party can terminate this treaty before 30 June of the calendar year
See MoreIndonesia: A new value added tax (VAT) invoice process has been introduced
In order to help the tax authorities to enhance control over the legitimacy of VAT invoices a new value added tax (VAT) process has been introduced in Indonesia. The new provision which is effective from 1st April 2013, ensures that any VAT
See MoreAustralia: Budget 2013
The Australian government released its budget for 2013 on May 2013. It includes plans for a number of revenue / tax expenditure changes including measures to combat profit shifting. According to the budget, business entities will be eligible for
See MoreKorea: Foreign exchange profit taxable as dividend income
Korea’s high court has issued a judgment in a case where a taxpayer received an amount less than the principal investment on the sale of participations in Japanese funds, which was offset to some extent by foreign exchange gains from the strength
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