Singapore: Non-resident individual tax rates to increase from 2017
The Inland Revenue Authority (IRAS) announced on 12 June 2015 that tax rates for non-resident individuals will be increased from the year of assessment 2017 to maintain parity between the tax rates of non-resident individuals and the top marginal
See MoreIndia: Delhi Tribunal allows use of multiple-year data for purposes of determining arm’s length price
In the case of DCIT v. Innodata Isogen India Pvt. Ltd. , the Delhi Bench of the Income Tax Appellate Tribunal upheld a decision of the Commissioner of Income Tax (Appeals) to allow the taxpayer to use multiple-year data in determining the arm’s
See MoreIndia: Transfer Pricing Adjustment For Interest-Free Loan to Related Party
Recently, the Income-tax Appellate Tribunal upheld an interest adjustment on a loan that the taxpayer advanced to a related entity In the case of: Soma Textile & Industries Ltd. v. ACIT. Here the tribunal found that the comparable uncontrolled
See MoreSri Lanka: Commissioner General of Inland Revenue publishes gazette on Transfer Pricing Regulations
The Commissioner General of Inland Revenue has published gazette no. 1907/26 dated 25 March 2015 on Transfer Pricing Regulations. It was made available on the Government Printer’s website on 27 May 2015. The gazette requires the taxpayer to
See MoreNew guidance on Advance Pricing Agreements issued by Australian Taxation Office
The Australian Taxation Office released its revised policies and procedures for the Advance Pricing Agreements program on 23 July 2015. The updated guidance has been provided in the form of Practice Statement Law Administration PSLA 2015/4, which
See MoreFATCA Agreement Signed between United States and Philippines
The Philippines and the United States have signed a Foreign Account Tax Compliance Act (FATCA) agreement on 13 July 2015. This is a Model 1 Agreement. Under this reciprocal agreement, the Philippines will report the information required under FATCA
See MoreIncome Tax Treaty Signed between Luxembourg and Brunei
Luxembourg and Brunei have signed an Income Tax Treaty on 14 July 2015. The purpose of the agreement between the two countries is to enable the tax administrations to eliminate double taxation and prevention of fiscal
See MoreHong Kong: Exemption for offshore funds
The Hong Kong government has Gazetted the Inland Revenue (Amendment) (No.2) Ordinance 2015, which seeks to extend the profits tax exemption for offshore funds to private equity funds. With the implementation of the Amendment Ordinance, transactions
See MoreWorld Bank and IMF announce further support for developing country tax administrations
The World Bank and the IMF announced on 10 July 2015 that they are launching an initiative to support developing countries in strengthening their tax administrations. Research has suggested that there is potential for lower income countries to
See MoreCanada: Tax treaty, TIEA updates
The Finance Ministry has announced that the Double Tax Treaty (DTA) between Canada and New Zealand entered into force on 26th June 2015, and that agents of the governments of Canada and the Cook Islands signed a tax information exchange agreement
See MoreFATCA Agreement Signed between United States and India
India and the United States have signed a Foreign Account Tax Compliance Act (FATCA) agreement on 09 July 2015. This is a Model 1 Agreement. Under this reciprocal agreement, financial institutions in India will report the information required under
See MoreIndia: High Court affirms that comparables must be functionally similar
In the case of: CIT-I v. DSM Anti Infectives India Ltd. ITA No. 116 of 2014 the Punjab and Haryana High Court confirmed a judgment of a tax appellate tribunal that certain companies selected in a search for comparables in a transfer pricing analysis
See MorePakistan: Budget for 2015/16
The Budget for the fiscal year 2015/16 (tax year 2016) was presented on 5 June 2015. The Budget proposals will basically take effect from 1 July. The proposed measures are summarized below: Corporate Tax: The corporate income tax rate is to be
See MoreNegotiations for DTA between Australia and UAE
Following a recent meeting, negotiations for a double tax agreement (DTA) between Australia and the United Arab Emirates are
See MoreHong Kong: Notes exchanged with Japan in relation to tax treaty in force
The agreement constituted by the exchange of notes between Hong Kong and Japan regarding the Exchange of Information Article of the Comprehensive Avoidance of Double Taxation Agreement between the two jurisdictions has entered into force on July 6,
See MoreDTA between Hong Kong and UAE ratified by Hong Kong
The Income Tax Treaty (2014) between Hong Kong and United Arab Emirates has been ratified by Hong Kong on 3rd July
See MoreChile and China sign DTA
The Double Tax Agreement (DTA) between Chile and China was signed on 25th May 2015. The treaty follows OECD guidelines. Article 5 of the treaty defines a permanent establishment and article 10, 11, 12 and 13 allocate taxing rights for dividends,
See MoreIndia: Delhi High Court Expresses Its View on Marketing Intangibles
Recently, the Delhi High Court issued its much anticipated ruling on marketing intangibles in the Sony Ericsson Mobile Communications India Pvt. Ltd. case. The High Court ruling is partially in favor of the taxpayers engaged in the import,
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