Category: Japan

The Implications for International Tax Planning From the Looming Fiscal Crisis

The international financial sector faces a perilous future. Major challenges loom over an uncertain global economy, while a decidedly negative political climate poses an existential threat to the offshore financial community. With each passing year, thanks to demographic changes and poorly designed fiscal policies, politicians from high-tax nations will be… – Continue reading

Taiwan, Japan deal on double taxation avoidance close: official

Taipei, Aug. 27 (CNA) Taiwan and Japan have nearly completed negotiations on a bilateral agreement to avoid double taxation, a Taiwanese official said Thursday. The date of its signing is still being discussed, the official said. The negotiations on the agreement have almost been concluded, Chou Shyue-yow (周學佑), deputy director-general… – Continue reading

Transfer pricing: Encouraging developments on APA and MAP

A recent Central Board of Direct Taxes (‘CBDT’) press release of August 6, 2015 announced signing of 2 unilateral APAs, including one with a rollback provision, and this has raised hopes of many MNCs, that hope to witness expeditious and reasonable closures. n July 2012, with a view to providing… – Continue reading

India Seeking To Resolve International Tax Disputes

India will soon settle international tax disputes with close to 120 American companies as well as entities from Japan and other such countries, according to the nation’s Revenue Secretary Shaktikanta Das. Earlier this month, India announced a Framework Agreement under the mutual agreement procedure provision of the India-US tax treaty… – Continue reading

British banks’ offshore banking activities ‘the greatest threat to national solvency’

A new paper shows that British banks engaged in more offshore banking than any other financial centre. Researchers examining the resilience of the world’s financial centres after the global economic crisis conclude that the future stability of the UK is perhaps the most uncertain of all. The paper concludes that… – Continue reading

Ireland making ‘little or no’ effort to curb corruption – report

Ireland has made “little or no” effort over the past four years to create a corruption-free playing field for global trade, violating its “obligation to combat cross-border bribery”, reports the Irish Times. The Transparency International Exporting Corruption report, released on Thursday, found that Ireland, along with countries such as Russia,… – Continue reading

Asian economies need to increase tax revenues, OECD says

The governments of emerging Asian economies need to look at new revenue streams to make their economies more competitive and boost living standards, the OECD said in a new report, reports Tax News. The report, Revenue Statistics in Asian Countries: Trends in Indonesia, Malaysia, and the Philippines, notes these countries’… – Continue reading

Increasing tax revenues is crucial to development in emerging Asian economies

19/08/2015 – Increasing tax revenues and ensuring sustainable domestic resource mobilisation will be critical as emerging Asian economies seek to boost the provision of public goods and services and improve economic growth and living standards. Revenue Statistics in Asian Countries: Trends in Indonesia, Malaysia and the Philippines shows that the… – Continue reading

International Tax Alert (US): Offshore e-Commerce Service Providers: Changes to Japan’s Consumption Tax Act are Going into Effect

Offshore e-commerce service providers should make themselves aware of changes to Japanese law that affect their operations. Pursuant to a recent amendment of the Consumption Tax Act, a new Registration of Foreign Business Operator system has been in effect since July 1, 2015. Many affected businesses have not yet registered… – Continue reading

OECD Tracks Tax Admin Changes In 56 Countries

The Organisation for Economic Cooperation and Development (OECD) said in a recent report that improving taxpayer services, while making non-compliance harder, is helping revenue bodies increase their efficiency and allowing governments to finance important programs that will further benefit their citizens. According to Tax Administration 2015, which looks at 56… – Continue reading

OECD Releases Its Annual Tax Administration Report

On August 11, 2015, the Organisation for Economic Co-operation and Development (OECD) released its annual report addressing global tax administration. The OECD’s stated mission is to “promote policies that will improve the economic and social well-being of people around the world.” The OECD describes its annual report as follows: Tax… – Continue reading

British Teachers Abroad Have One Last Chance to Avoid UK Taxes on Their Pension

QROPS specialists are offering free transfers to Gibraltar QROPS for August only for teachers who want to retire abroad and avoid all UK taxes and future UK taxes on their existing teacher’s pension scheme. This is the final chance for teachers living abroad to transfer their UK pensions outside the… – Continue reading

Japan – Article 7 (Business profits) under UK tax treaty

July 27: Japan’s Ministry of Finance announced the exchange of diplomatic notes concerning application of Article 7 (Business profits) under the new income tax treaty between Japan and the United Kingdom. Background Provisions of the amended Japan-UK income tax treaty (signed 17 December 2013) generally were effective 1 January 2015…. – Continue reading

Japan and the UK exchange notes concerning article 7 (“business profits”) of the Japan-UK Tax Convention

On July 23, 2015 the Japanese Ministry of Finance issued a press release announcing that on July 22, 2015 the Government of Japan and the Government of the United Kingdom exchanged notes concerning Article 7 of the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland… – Continue reading

Rich countries rejected an international plan to let the UN help fight tax evasion

At a global summit that addressed how illicit financial flows interfere with reducing poverty, wealthy nations rejected a plan to expand the UN’s power to fight global tax evasion. The plan, promoted by developing economies and transparency groups, was the subject of the meeting between delegations of UN members from… – Continue reading

Industrialized Countries Accused of Blocking Developing Countries from International Tax Effort

The U.S., Japan and Europe are being accused of blocking developing countries from participating in efforts to combat international tax evasion. Policymakers have been gathered this week in Addis Ababa, Ethiopia for the 3rd Financing for Development Conference, where discussions have been underway about ways to combat corporate tax evasion…. – Continue reading

Where will the money flow from Gorgon, our biggest ever mining project?

Energy giants called to explain billions in tax havens To describe Gorgon as another super-sized resources project in Western Australia does not do justice to the scale and scope of the venture. When the taps are turned on later this year and liquefied natural gas begins to flow, Australia will… – Continue reading

OECD establishes roadmap for membership with Lithuania

10/07/2015 – The OECD set out a clear path for Lithuania’s accession to the Organisation, reinforcing the OECD’s commitment to further extend its global membership. On 8 July 2015 the 34 OECD Members adopted the Roadmap for the Accession of Lithuania to the OECD Convention setting out the terms, conditions… – Continue reading

Japan MoF names Masatsugu Asakawa as top financial diplomat

Japan’s Ministry of Finance said international policy veteran Masatsugu Asakawa will become the country’s top financial diplomat, whose tasks include co-ordinating with other nations and the IMF as well as arranging currency interventions. Asakawa’s broad network with policymakers both inside and outside Japan puts him in an ideal position to… – Continue reading

Public Bank ties up with Japanese banks

PETALING JAYA: Public Bank Bhd yesterday signed a memorandum of understanding (MoU) with Saitama Resona Bank Ltd and Kinki Osaka Bank Ltd to cross-sell each other’s banking products in Malaysia and Japan. Saitama Resona Bank and Kinki Osaka Bank are wholly-owned subsidiaries of Resona Holdings Inc, which also owns Resona… – Continue reading

France: French Tax Update – Recently Published Noteworthy Decisions – July 2015

The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months. BUYBACK AND CANCELLATION OF OWN SHARES The tax treatment of buybacks, from the shareholders’ point of view, has now been simplified through a change of legislation, i.e.,… – Continue reading

FATCA – Which Countries Are In And Out

FATCA – Which Countries Are In And Out The controversial US Foreign Account Tax Compliance Act (FATCA) law is set to start from July 1, 2014, so with less than 21 days to go, here’s a look at which countries are in and who is outside of the tax network…. – Continue reading

Extend automatic sharing of tax information to all nations: Railway Minister Suresh Prabhu

India has strongly argued for widening the agenda for sharing of information on tax issues and has called for holding a roundtable on infrastructure to deepen investment in this critical sector. Railway minister Suresh Prabhu, India’s sherpa for the G20 meeting, raised several issues to highlight the concerns of emerging… – Continue reading

LPC-Turkish borrowers target Asian loan investors

Turkish banks and companies are trying to sell syndicated loans to Asian investors after a drop in Asian lending but investors are wary of increasing Turkish exposure due to political instability following June’s elections, bankers said. Turkish borrowers are targeting Asian investors in a bid to extend loan maturities after… – Continue reading

Wal-Mart Has $76 Billion in Overseas Tax Havens, Report Says

Wal-Mart Stores Inc. owns more than $76 billion of assets through a web of units in offshore tax havens around the world, though you wouldn’t know it from reading the giant retailer’s annual report. A new study has found Wal-Mart has at least 78 offshore subsidiaries and branches, more than… – Continue reading

Bank of Singapore Knows Family Matters

House Foreign Affairs Committee Chairman Ed Royce (R-CA) and Congressional Armenian Caucus Co-Chair Frank Pallone (D-NJ) were among the first Congressional leaders to welcome the May 7th signing of the U.S.-Armenia Trade and Investment Framework Agreement (TIFA), a longstanding policy priority for the Armenian National Committee of America (ANCA). Chairman… – Continue reading

Countries and Companies Square Off Over International Tax

An OECD initiative on tax evasion is causing ripples around the world While a host of topics — from the necessity and the proposed scope of corporate tax reform, to corporate rate reduction and corporate inversions — are of major concern to those engaged in international tax, the overriding issue… – Continue reading

Applied Materials and Tokyo Electron Call Off $10 Billion Merger

TOKYO — Two of the world’s largest manufacturers of the machinery used to produce semiconductors, Applied Materials of the United States and Tokyo Electron of Japan, on Monday dropped plans to merge after the Department of Justice said that combining their businesses would restrict competition. The proposed $10 billion deal… – Continue reading

The “Netflix tax” – coming to a country near you

The arrival of Netflix in Australia has brought into sharp relief the GST base erosion problem caused by global digital commerce. Along with the non-taxation of low-value imported goods, the absence of GST on services and digital products imported by consumers represents an omission from the tax base that is… – Continue reading

The Cost of Business in Myanmar Compared With China

Myanmar remains an enigmatic country – one of the largest and most populated in Asia but also one of its poorest and least understood. It remains a country that has largely stood still for seventy years – hardly any infrastructure of note was developed in the country since the end… – Continue reading

OECD MAP Statistics Show Pressing Need for Mandatory Binding Arbitration

The OECD Mutual Agreement Procedure Statistics for 20131 (MAP Statistics), released on November 25, 2014, show a dramatic surge in the inventory of mutual agreement procedure (MAP) cases among OECD member countries. The MAP Statistics confirm that the potential for double taxation is increasing. This is reflected most starkly in… – Continue reading

UK Firms, Economy Burdened By High Tax Rates

The UK is inhibiting its economy with a tax burden 18 percent heavier than the global average and should consider setting a specific target for lowering the overall tax take, according to research by accountants UHY Hacker Young. UHY’s findings show that tax revenue in the UK represents a third… – Continue reading

China: Asia Tax Bulletin – Spring 2015

CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading

European Union: European M+A News, Spring 2015

EUROPEAN M&A DOS AND DON’TS FOR NON-EUROPEAN BUYERS Inbound M&A in Europe by non-European buyers increased in 2014 by 68.6% compared to 2013, representing over a third of USD 901.4 billion total European M&A.1 For non-European buyers the basic framework of transactions may be similar, but there are a number… – Continue reading

Uranium demand is putting miner Cameco back on investors’ radar

The outlook for uranium, moribund for some time, is looking up. And that means shares of Cameco Corp., the Saskatoon-based miner one analyst calls “the only real blue-chip stock in the sector,” are up, too – about 20 per cent from their 52-week lows. The stock has received a host… – Continue reading