Category: Japan

Japanese investment in Pakistan

Japan has remained a cornerstone of Pakistan’s economy for the past many years. Japanese Companies have invested in all sectors across Pakistan. Be it auto, trading, manufacturing, infrastructure development, packaging, steel manufacturing, indenting, etc a large number of Japanese Companies have a strong presence in Pakistan. Pakistan’s Investment and Corporate… – Continue reading

Japan, Qatar reach tax treaty agreement

TOKYO, Dec 17 (KUNA) — Japan and Qatar have reached a substantive agreement on a bilateral tax treaty that will help businesses and investors avoid double taxation involving the two countries, the Foreign Ministry announced Wednesday. The agreement aims to clarify the taxation on cross-border investment and economic activities between… – Continue reading

Japan’s Manufacturing Rose, Abe Plans Corporate Tax Cut

Unlike China, Japan‘s manufacturing activities rose in December. Flash PMI from HSBC came out at 52.1, up from 52 in November. A reading over 50 signals expansion. Meanwhile, the Nikkei newspaper reported that Japan’s government is considering lowering the corporate tax rate by 2.5 percentage points starting next April. Among… – Continue reading

How Google and Apple Make Their Taxes Disappear

Around the world, countries are desperately seeking ways to stop multinational companies from earning profits within their borders without paying taxes on them, while stashing trillions in tax havens like the Cayman Islands. The British government, after a search, says it knows how to tax the profits Google earns in… – Continue reading

Hong Kong exchanges notes with Japan regarding comprehensive agreement on avoidance of double taxation

Hong Kong (HKSAR) – The Government of the Hong Kong Special Administrative Region today (December 10) exchanged notes with the Government of Japan regarding the Exchange of Information (EoI) Article in the Agreement between the Government of the Hong Kong Special Administrative Region of the People’s Republic of China and… – Continue reading

Japan, Qatar to launch tax treaty talks

TOKYO, Dec 5 (KUNA) — Japan will launch negotiations for bilateral tax treaty with Qatar aimed at helping businesses and investors avoid double taxation involving the two countries, the Foreign Ministry announced Friday. The first round of talks will be held here on December 8, the ministry said in a… – Continue reading

Offshore Services – British Virgin Islands

The Tax Information Exchange Agreement (TIEA) between Japan and the British Virgin Islands came into effect on October 11 2014. Authority and scope The BVI-Japan TIEA is essentially consistent with the Organisation for Economic Cooperation and Development standard model template for TIEAs. It provides for assistance through exchange of information… – Continue reading

Mitsubishi wins big for Japanese trading companies in Indian Berry ratio transfer pricing case

Meredith McBride in Hong Kong Mitsubishi Corporation India’s victory over the Indian tax authorities in the New Delhi Tax Tribunal on the use of the Berry ratio (gross margin divided by operating expenses) sets important precedents for transfer pricing litigation in India, advisers believe, because it legitimises the use of… – Continue reading

Toyota, Mitsui, Marubeni to sign first set of pacts

Mitsui, Toyota and Marubeni are likely to be among Japanese companies that would sign the first set of bilateral advance-pricing agreements (APA) with India shortly. These agreements will provide certainty to Japanese multinational firms operating in India and avoid conflicts over sharing of taxes between India and that country. Two… – Continue reading

AIG was avoiding taxes when it was owned by the US government

After the US bailed out the insurance conglomerate AIG in 2008, the company’s employees kept to business as usual—which included setting up complex tax structures to avoid taxes in Europe and Japan. In 2008, the company was on the brink of a bankruptcy that would have created huge losses throughout… – Continue reading

Japanese Taxation of a PE under the AOA Approach

Background The “Authorized OECD Approach” (“AOA”) rule for taxation of permanent establishments (“PE”) was introduced in Japan’s 2014 tax reform and will be applied to fiscal year commencing April 1, 2016. The new rule includes changes to source rules, the introduction of transfer pricing to intra-company transactions, and the introduction… – Continue reading

FATCA Tracker – October 01, 2014

Nearly 105,000 financial institutions are listed on the US Internal Revenue Service (IRS) database of Foreign Account Tax Compliance Act (FATCA) organisations complying with the tax reporting rules for US citizens. The latest list was published on October 1, 2014 by the IRS and shows 104,344 financial organisations have signed… – Continue reading

Wealth Inequality Accelerates Worldwide on Inheritance, Tax Avoidance

Wealth inequality is growing worldwide, according to a new report by Credit Suisse. A greater share of wealth is being held by a smaller number of ultra-rich families worldwide as larger inheritances, family trusts, and similar arrangements to avoid taxes help the ultra-wealthy gain a greater portion of total capital… – Continue reading

Tokyo District Court Allows Tax Saving from Share Repurchase

On May 9, 2014, the Tokyo District Court reversed a large tax that had been imposed on a large U.S. multinational’s Japanese holding company (“Japan HoldCo”). Under the Japanese Corporate Tax Law, if a shareholder returns shares to an issuing company (i.e., the issuing company acquires treasury shares), a portion… – Continue reading

UBS in $1.4 Billion Test of French Tax-Evasion Crackdown

UBS AG, the world’s biggest manager of money for the rich, has become the test case for French President Francois Hollande’s tax-evasion crackdown. The Swiss bank is set to learn from a Paris appeals court on Sept. 22 if it must post a 1.1 billion-euro ($1.4 billion) bond to cover… – Continue reading

Scrap Withholding Tax & MAT on Japanese Companies In India: Suggests Minister, Embassy Of Japan

Minister, Embassy of Japan Mr. Isomata Akio asked India to exempt Japanese manufacturers, operating in India from withholding tax and Minimum Alternate Tax (MAT) so that these do not evolve into being one of the trade barriers and stagger Japan from becoming India’s largest trade partner in times to come. Japan investments and technology… – Continue reading

Facing up to Fatca

This article was first published in the 2nd quarter 2014 edition of Personal Finance magazine. Most people accept that they have to pay taxes in their country of residence. But citizens of the United States and green card holders who live outside that country – even if they have never… – Continue reading

Broken levy: How U.S. tax law encourages inversions

An innocuously named species of transaction has inspired a political furor this summer. After a number of U.S. companies announced plans to move overseas in so-called inversion deals, Sen. Carl Levin proposed banning them outright. President Barack Obama called the companies unpatriotic. Because of the controversy, Walgreen Co. backed away… – Continue reading

101 Countries Sign Up For FATCA Network

Foreign Account Tax Compliance Act (FATCA) has been in force for a month and still more countries are joining the tax network. So far, 101 countries and financial jurisdictions have either signed or agreed to join FATCA. FATCA is aimed at identifying US taxpayers with offshore bank accounts and investments. Overseas… – Continue reading

Burger King-Tim Hortons: Is Canada becoming a corporate tax haven?

Potential inversion deal highlights dropping corporate taxes in Canada, now the lowest among 10 countries, with the U.S. in 5th place. Fast-food giant Burger King faced anger from both Washington and average Americans Monday, a day after it announced that it was in talks to buy Tim Hortons and relocate… – Continue reading

G20 to press for ‘rapid timeline’ for exchange of tax information

NEW DELHI: G-20, a group of developed and developing nations, is likely to press for adoption of “rapid timelines” by different countries for automatic sharing of information with a view to curb tax evasion. The issue of automatic sharing of tax information would figure prominently during the meeting of G-20… – Continue reading

Tax pact with Japan effective May 22

The Tax Information Exchange Agreement (TIEA) signed by Macau and Japan comes into force on May 22, the Ministry of Finance of Japan said in a press release published yesterday. Starting from May 22, both contracting parties can request information for criminal tax matters without regard to the taxable year… – Continue reading

Argentine Official Meets FIFA’s Blatter on Soccer Tax Avoidance

Argentina’s tax agency head is meeting FIFA President Sepp Blatter today to tell him how soccer teams are evading taxes in the $3.7 billion player trading market. Ricardo Echegaray has traveled to the soccer ruling body’s headquarters in Zurich to inform Blatter that his agency has detected techniques used by… – Continue reading

Use HK’s access to marts in China, Japan and S Korea

KUALA LUMPUR: Small and medium enterprises (SMEs) should tap Hong Kong’s access to the markets in China, Japan and South Korea to gain tax advantages under the double-taxation deduction pact signed between Malaysia and HK. Hong Kong Trade Development Council deputy executive director, Margaret Fong, said HK SMEs paid five… – Continue reading

Apple to IBM hoard $206b abroad to avoid US tax

The largest US-based companies added $206 billion to their stockpiles of offshore profits last year, parking earnings in low-tax countries until Congress gives them a reason not to. The multinational companies have accumulated $1.95 trillion outside the US, up 11.8 per cent from a year earlier, according to securities filings… – Continue reading

G-20 Agrees on Automatic Tax Data Sharing, OECD Says

Group-of-20 nations agreed to implement a global standard for automatically exchanging information between tax authorities by the end of 2015, the Organization for Economic Cooperation and Development said. The endorsement is a step toward putting an end to “banking secrecy as we know it,” Pascal Saint-Amans, director of the OECD’s… – Continue reading

G20 to tackle transfer pricing with new tax exchange scheme

The days of multinational companies being able to use the Double Irish Dutch Sandwich to avoid taxation may soon be coming to an end, with the G20 group of nations looking to create a reporting standard to allow for automatic exchange of tax information. In the official communique coming at the end… – Continue reading