Category: Japan

Countries that accept BEPS minimum standards may participate in global tax effort, OECD says

Any country that agrees to adopt the OECD/G20 base erosion profit shifting (BEPS) project minimum standards and pay an annual fee will be allowed to participate in future BEPS project work, according to a plan agreed to by the OECD today. The OECD’s framework for BEPS plan implementation, to be… – Continue reading

Automatic exchange of financial account information

The Government recently introduced into the Legislative Council a bill to provide a legal framework for the implementation of automatic exchange of financial account information in tax matters (“AEOI”). This would have significant implications both for financial institutions and, in a cosmopolitan city like Hong Kong, for many of their… – Continue reading

Taiwan, Italy sign pact to avoid double taxation

Taipei, Feb. 15 (CNA) The Ministry of Foreign Affairs said Monday that Taiwan and Italy have completed an agreement to avoid double taxation and tax evasion. The Ministry of Foreign Affairs said Monday that Taiwan and Italy have completed an agreement to avoid double taxation and tax evasion. The ministry… – Continue reading

Varner: Taxes and international trade

A while back in Germany, I was driving on the straight as an arrow B-1. That is Bundesstrasse, the equivalent of a U.S. highway, a notch below the Autobahn. Roads tend to curve around farmers’ fields, having been there first. The B-1 from Cologne on the Rhine toward Berlin was… – Continue reading

Treaties and treats

In the heyday of strict implementation of tax laws, it is a welcome relief to some taxpayers that a tax treaty relief application (TTRA) is after all, what it is supposed to be, a relief. To begin with, tax treaties are entered into by countries to reconcile their respective fiscal… – Continue reading

Secret accounts overseas urged to be reported

Those who have been hiding their income or wealth overseas had better think again, as Korea will soon be exchanging financial information with multiple countries, including tax havens. They are advised to voluntarily report it to the government before the end of March to be given a grace period, said… – Continue reading

MAP-ping tax reform: Good start to resolving transfer pricing row with US

Though the use of the retrospective tax on Vodafone and Cairn tend to grab the headlines, a large part of the ‘tax terror’ in India has really been the contribution of the high-pitched transfer pricing (TP) additions to the income of the MNCs Though the use of the retrospective tax… – Continue reading

The Asia Tax Awards are back: Enter now for 2016

The revived Asia Tax Awards will feature categories for companies, firms and individuals. The Asia Tax Awards are back! More than five years after they last took place in November 2010, the Asia Tax Awards will be held once again on Thursday May 5 2016, following the Asia Tax Forum,… – Continue reading

100 transfer pricing disputes with US resolved, says CBDT

NEW DELHI: The Central Board of Direct Taxes (CBDT) today said it has resolved as many as 100 transfer pricing disputes with the US, which will lead to an environment of “tax certainty and encourage MNCs” to do business in India. The resolution of such issues, CBDT said further, follows… – Continue reading

31 nations sign agreement on exchange of country-by-country transfer pricing reports

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading

S. Korea, Macau to sign tax information exchange agreement

Macau’s Financial Services Bureau (DSF) has confirmed to Business Daily that the local authority is to sign a Tax Information Exchange Agreement (TIEA) with South Korea, which would add to the existing 15 jurisdictions that have already signed this agreement with the territory. According to the Bureau, its South Korean… – Continue reading


The new advanced pricing agreements cover sectors like investment advisory, IT enabled services and manufacturing In the current fiscal year, which is the third year of APA programme, 30 agreements have been signed so far. As part of efforts to reduce tax disputes related to international transactions carried out by… – Continue reading

The hidden wealth of nations

India’s biggest source of FDI is India itself, money departing on a short holiday to a tax haven and then routed back as FDI. Will the government muster up the political will to clamp down on the tax-allergic business elite? This could be a bumper year for the ever-lucrative tax… – Continue reading

Intl bodies to fight global tax evasion / Maximum of $240 bil. said to be dodged

The Yomiuri Shimbun Four international organizations will join forces to devise unified global tax rules aimed at preventing tax evasion by multinational companies. The four entities involved are the Organization for Economic Cooperation and Development, the United Nations, the International Monetary Fund and the World Bank. The OECD — whose… – Continue reading

Luxembourg Tax Alert 2016-02

January 2016 You will find below a summary of some of the most important tax developments that have happened since the release of our last newsletter, at OECD, EU or country level, in the area of tax transparency and the fight against tax avoidance. EU – Tax transparency and anti-BEPS… – Continue reading

Gear up for modifications in tax legal guidelines, treaties

The international community led by the had initiated the (BEPS) project a few years ago with the aim of ensuring that profits are taxed where economic activities are performed and where value is created. Governments, and social groups have been voicing their concern over the past decade that multinational enterprises… – Continue reading

A Tax Agreement is Signed Between Taiwan and Japan

Japan, Taiwan January 4 2016 After many years of discussion and negotiation, Taiwan’s Association of East Asian Relation and Japan’s Interchange Association finally signed 「THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVAION WITH RESPECT TO TAXES ON INCOME」(the “DTA”) in Tokyo on 26 November 2015. For the… – Continue reading

2015: A Watershed Year in Corporate Tax?

Multinational companies have enjoyed a sustained period of falling corporate tax rates around the world. However, with the conclusion of the OECD’s base erosion and profit shifting project earlier this year marking the start of fundamental changes to the international tax system, and with governments more determined than ever to… – Continue reading

Indian companies with foreign units likely to be impacted by POEM guidelines

MUMBAI: Many manufacturing and trading subsidiaries of Indian companies that are currently operating independently outside India may have to pay taxes in India as they could fail the new test set under the Place of Effective Management (POEM) guidelines. Not just that, some of the companies could see complications with… – Continue reading

Offshore bank gets up to $840k in payroll rebate

It’s probably not the best time in the province to announce a payroll rebate to a major offshore bank promising to create 50 jobs in Halifax. Nova Scotia Business Inc. on Tuesday announced a rebate worth a potential $840,000 over six years to the Bank of N.T. Butterfield and Son… – Continue reading

India: Marketing intangibles by licensed manufacturer, no transfer pricing adjustment

The Delhi High Court held that the taxpayer’s advertising, marketing, and sales promotion expenses were not an “international transaction” under provisions of India’s tax law, and thus, could not be the basis of a transfer pricing adjustment. The court further held that a “bright line test” as applied by the… – Continue reading

Transfer pricing law in Thailand and the BEPS initiative

Initiated by the Organisation for Economic Cooperation and Development in 2013 and endorsed by the G-20, the OECD’s “Action Plan to Address Base Erosion and Profit Shifting (BEPS)” includes 15 key areas to encourage more transparency, better reporting and more cooperation between countries in which multinational companies operate. On October… – Continue reading

Double taxation avoidance

India and Korea on December 9 agreed to suspend collection of taxes during the pendency of Mutual Agreement Procedure (MAP). This MoU will relieve the burden of double taxation for the taxpayer in both the countries. Two days later, India and Japan signed a protocol for amending the existing convention,… – Continue reading

Latvian president calls for double taxation treaty with Japan

Latvian President Raimonds Vejonis on December 15th accepted the credentials of the Japanese Ambassador to Latvia, Mariko Fujii, and noted an increase in Latvia-Japan trade recently but said there was still room for growth in economic cooperation, the Latvian president’s press service reported LETA. He said that a treaty for… – Continue reading

Netherlands: European Commission Puts Netherlands On Notice Regarding Its Tax Treaty With Japan

The European Commission asked the Netherlands on 19 November to amend the limitation on benefits (LOB) provision in the existing Dutch-Japanese tax treaty. The LOB provision may be detrimental to Dutch companies held by residents of certain EU/EEA countries when they receive interest, royalties and dividends from Japan. They may… – Continue reading

13 States Sign Up To OECD’s New Tax Info Exchange Standard

Thirteen jurisdictions signed the OECD Multilateral Competent Authority Agreement (MCAA) at a meeting on October 29-30, 2015, in Barbados. In joining the MCAA, the territories commit to automatically exchange tax information with other nations’ tax authorities under the OECD’s new tax information exchange standard, the Common Reporting Standard. A total… – Continue reading

Why are Tax Inversion” Relocations Accelerating?

Tax inversions — the process of U.S. firms, merging with or buying foreign companies to shift their taxpaying headquarters abroad — have deprived the U.S. Treasury of ever-increasing billions of dollars. Although President Barack Obama promised to take punitive action against companies deliberately engaging in mergers and/or acquisitions for tax… – Continue reading

TaxTalk Today- 7th December 2015

Australian Taxation Office New or updated materials on ATO website, including: Class ruling to be released on Wednesday BAS reporting – offshore to offshore supply of goods: Some taxpayers are incorrectly including offshore to offshore supplies of goods in their business activity statements (BAS). This document sets out to clarify… – Continue reading

Apple, Amazon and Microsoft’s mega-million con: How titans of the new economy screw us all on taxes

Tech titans powering the economy shelter money through insane tax-avoidance havens. It’s wrong — and adding up Offshore tax havens enable not only individuals to dodge taxes—they also enable multinational corporations to do so. Often this tax avoidance is done within the letter of the law: multinational groups exploit the… – Continue reading


Global taxpayers can expect to pay more tax in the years ahead. Many governments worldwide continue to update their tax legislation and expand their tax systems to repay debt and pay for increased social welfare, even as the memory of the last global financial crisis lingers. These are the conclusions… – Continue reading

Previewing US Tax Reform

The latest Tax Reform Business Barometer survey, issued by The Tax Council and Ernst & Young, found that tax professionals expect Congress to approve tax reform legislation no earlier than 2017, with most congressional leaders having all but given up hope that tax reform is achievable in the remainder of… – Continue reading

Ethiopia: Unmet Demands of the G20

The creation of the Group of Twenty (G20) was believed to serve as a remedy to the harsh realities of the world today. The initial formation of the Group of Seven G7 could do little to avert pertinent challenges both the developing and the developed nations face frequently. So a… – Continue reading

European Commission requests the Netherlands to amend the Limitation on Benefits clause in the Dutch-Japanese Tax Treaty for the Avoidance of Double Taxation

On November 19, 2015 the European Commission published the key decisions of its November infringement package. One of the key decision mentioned is the Commission’s decision to request the Netherlands to amend the Limitation on Benefits (LOB) clause in the Dutch-Japanese Tax Treaty for the Avoidance of Double Taxation, which… – Continue reading

China stocks jump amid global rally on Fed minutes

Fed decision due after December 15-16 meeting Hong Kong and mainland Chinese stocks both closed significantly higher on Thursday, adding to a global stock rally after minutes from the US Federal Reserve’s October meeting sent a stronger signal about a possible December rate increase. The Hang Seng Index advanced 1.4… – Continue reading

KPMG leader visit highlights BEPS initiative

Latest developments under the Base Erosion and Profit Shifting (BEPS) initiative of the Organisation for Economic Co-operation and Development (OECD) was one of the key points of a recent four-day visit by KPMG’s global leader for Transfer Pricing Services Sean Foley to Vietnam. He shared the issue with Vietnam’s General… – Continue reading

Mutual Agreement Procedure (MAP) for navigating the tax tangle

If statistics are anything to go by, today India is the world’s fastest growing economy at 7.3% in 2015, outstripping the global average of 3.1%. With a new government in the centre, we do seem to be riding high on the growth trajectory. The Modi government has certainly done its… – Continue reading

Japan, Taiwan to sign tax treaty

TAIPEI — Japan and Taiwan will sign a bilateral tax treaty aimed at improving the flow of people and investment between the two economies, sources familiar with the matter said on Wednesday. The treaty will reduce or eliminate taxes on dividends repatriated from companies’ overseas branches and help avoid issues… – Continue reading

UK: Consultation Over Fixed Cap On UK Tax Deductibility Of Corporate Interest Expense: Plucking The Feather In The Cap?

The UK Government launched a consultation on 22 October 2015 regarding the UK corporate tax rules for interest deductibility. The consultation seeks views on the design of a general limitation for UK corporation tax deductions for interest and similar finance costs, imposing a capcalculated by reference to a fixed percentage… – Continue reading

Switzerland & Luxembourg among DTA approvals sent for US Senate vote

Eight tax treaties and protocols were passed forward for a ratification vote by the full US Senate at a business hearing of the Committee on Foreign Relations on November 10, reports Tax News. The Committee approved the new US double taxation agreements (DTAs) with Chile and Hungary, and protocols to… – Continue reading

Anatomy of transfer pricing

Currently 15,980 foreign companies are operating in Korea. While hiring workers and producing goods and services, foreign investors encounter numerous difficulties and experience a variety of grievances. One particular grievance brought to our attention is that they suffer from a discrepancy between the value of imported goods assessed by the… – Continue reading

G20 vows balanced growth – Capital flow a concern

Antalya, Nov. 16: The Group of 20 nations today pledged to adopt sound macroeconomic policies to achieve strong, sustainable balanced growth. The near-term objective would be to support growth, create jobs and put debt as a share of gross domestic product (GDP) on a sustainable path. Data show that several… – Continue reading