Top Stories


Top Stories - Tax law

Evaluating Cambodia’s Tax Reform

By ASEAN Briefing , Posted: 6th February 2017 08:33
Cambodia’s updated Law on Financial Management for 2017 reflects the government’s ongoing efforts to revamp the country’s tax system and bring more businesses operating in the informal sector into the formal tax regime by offering incentives for small taxpayers. The amended laws, which came into effect on January 1, offer lower tax rates for small an ... Read more...

Taxation of Export Processing Enterprises in Vietnam

By Vietnam Briefing , Posted: 23rd January 2017 08:15
It is becoming easier to trade across borders from Vietnam, according to the World Bank’s Doing Business Guide. Due in large part to Vietnam’s proximity to China and the country’s access to the ASEAN free trade area, exports of goods added up to over US$170 billion in 2016. The government expects export sales to be one of the key drivers for economic growth in 2017, a ... Read more...

Meeting the challenges of Value Added Tax implementation in the GCC states

By Jennifer O'Sullivan & Morris Rozario, Posted: 16th January 2017 08:24
The strategic motivation to introduce VAT in the Persian Gulf countries is the ultimate aim of the GCC Union (comprising Bahrain, Saudi Arabia, United Arab Emirates, Kuwait, Qatar and Oman) to achieve economic integration that would lead to a common market and economic and monetary union. The IMF has long identified the introduction of VAT and corporate tax as a primary means to enhance market mec ... Read more...

An Overview of China’s VAT Reform

By China Briefing , Posted: 10th January 2017 07:58
Hailed as China’s most significant tax reform in over two decades, the value-added tax (VAT) was comprehensively implemented as the country’s only indirect tax in 2016, effectively replacing the business tax (BT) that previously applied to a number of industries. The reform is part of Beijing’s efforts to restructure the Chinese economy from one driven by labor-intens ... Read more...

Non-Resident Withholding Tax Regime on Taxable Australian Property

By Davide Costanzo, Director Tax and Business Advisory & Varun Kumar, Tax Manager – Moore Stephens (WA), Posted: 2nd December 2016 09:09
From 1 July 2016, the disposal of certain Australian property (including real estate) by non-resident Vendors will be subject to a non-final 10% withholding tax. The purpose of this is to assist in the early collection of tax from foreign residents and encourage them to meet their tax obligations in Australia. The tax is required to be withheld by the Purchaser and remitted to th ... Read more...

ATAD’s GAAR Of No Surprise: Czech Courts Affirm A Complex Cross-Border Intra-Group Restructuring Was A Disregardable Abusive Transaction

23rd November 2016 08:25
Without exaggeration, one can say that the aftereffects of the 2007 financial crisis launched a new era in tax compliance that has been characterised by an unprecedented number of anti-tax avoidance initiatives across all fields of taxation at both global and EU level. Besides measures focused on comprehensive data collection and reporting, the domestic extension of which was briefly a ... Read more...

Tax Avoidance Schemes – why you shouldn’t touch them with a barge pole

By John Leyden , Posted: 17th November 2016 10:13
As a tax adviser in practice for almost 20 years, it never ceases to amaze me the kind of tax avoidance schemes that are dreamt up and marketed.   They rely on one thing for them to work for the tax avoidance industry – greed, plus a belief that you can get away without paying any tax at all.   I have never advised a c ... Read more...

Taxation in New Zealand

By Geoffrey Cone, Posted: 9th November 2016 08:48
New Zealand has two principal taxes: income tax (which includes domestic and non-resident withholding taxes), and goods and services tax (GST). Income tax is based on New Zealand residence or New Zealand sourced income. GST is based on the transfer of goods and services in New Zealand.  There is no capital gains tax, wealth tax or inheritance tax in New Zealand,although care must be taken ... Read more...

Exchange of Information on Tax Rulings – A New Reality

By Gesina van de Wetering, Posted: 14th October 2016 08:35
1 EU: Automatic Exchange of Information of Tax Rulings   On 31 August 2016, the Dutch State Secretary of Finance submitted the awaited draft ‘Act on the exchange of information on rulings’ (the Act) to the Lower House.This Act implements the recent amendments made to Council Directive 2011/16/EU (the Direc ... Read more...

Assessing the Hong Kong – Russia Double Taxation Agreement

By China Briefing, Posted: 6th October 2016 08:27
The long-awaited Comprehensive Double Taxation Agreement (CDTA) between Hong Kong and Russia entered into force on July 29, 2016. The agreement will take effect on April 1, 2017 in Hong Kong and January 1, 2017 in Russia. Signed at the beginning of 2016, the CDTA aims to provide greater certainty on taxing rights between Hong Kong and Russia, incentivizes foreign investm ... Read more...

Malaysia Announces 70% Tax Exemption for Shipping Industry

By Asean Briefing, Posted: 6th September 2016 08:07
Malaysia’s Ministry of International Trade and Industry revealed tax incentives on August 9th targeting the shipping industry. Incentives will be applied with immediate effect and will be available for periods of five years.   Understanding Incentives Shipbuilding incentives will be applied to both ... Read more...

Tax Implications of Rehabilitation Expenditure in Namibia

By Gerda Brand & Olivia Nghaamwa, Posted: 5th July 2016 07:52
The mining industry in Namibia plays a significant role in the growth and development of the country’s economy. It is therefore important to ensure that all efforts are made to ensure its sustainability.   During 2015, the mining industry contributed 11.9% to the gross domestic product of Namibia. Furthermore, the total contributions from the mining ind ... Read more...

FATCA Leads to Stricter Reporting and More Taxation for Non-U.S. Mutual Funds

By Dezan Shira & Associates, Posted: 20th May 2016 09:10
In July we reported that India and the United States signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA). The agreement is designed to increase transparency between the two nations on tax matters and took effect September 30, 2015.&n ... Read more...

Exclusive Q&A on Corporate Tax with Devon M. Bodoh

11th April 2016 09:58
Have there been any recent regulatory changes or interesting developments? On November 19, 2015, the US Treasury Department (the “Treasury”) issued Notice 2015-79, describing regulations that the Treasury intends to issue concerning inversion transactions.  Specifically, Notice 2015-79 describes regulation ... Read more...

Individual Income Tax in Malaysia for Expatriates

By Dezan Shira & Associates, Posted: 25th February 2016 09:41
Personal Income taxation in Malaysia is laid out in general terms under the Income Tax Act of 1967. While this is the principal piece of legislation covering taxation in Malaysia, further legislation has since been introduced in order to supplement and clarify existing policy.   Enacted on an annual basis, the Malaysian budget is one of the most readily available ... Read more...

Update on legal, regulatory and tax changes in the residential mortgage and buy-to-let markets in 2016 and beyond

By Simon Hopewell, Henry Davenport & Janet Hall, Posted: 29th January 2016 09:49
As we prepare ourselves for another year of predicted growth in the UK residential housing sector a number of important legislative, regulatory and tax changes will begin to be implemented as soon as March 2016 which will directly affect the residential mortgage and buy-to-let (BTL) markets.   Many professionals and practitioners have not yet begun to concentrate ... Read more...

Applying for Income Tax Incentives in China New Streamlined Record-Filing System Launched

By Dezan Shira & Associates, Posted: 18th December 2015 11:21
In a recent move to simplify China’s tax incentive application procedures, the State Administration of Taxation abolished the preliminary approval system for preferential corporate income tax (CIT) policies. This means that enterprises are no longer required to apply to the local tax bureau before they obtain the preferential tax benefits. Instead, the SAT has launched a new “a ... Read more...

India’s Withholding Tax for Non-residents

By Dezan Shira & Associates, Posted: 15th December 2015 09:35
The Indian government has become progressively more strict about what is considered income under tax law and who must file an income tax return. In particular, companies required to withhold taxes, and individuals or companies in receipt of income, have found themselves subject to increasingly stringent withholding rules. The topic of withholding taxes can be problematic both for the payer (whethe ... Read more...

Hungarian tax procedures: rebooted

By Tamás Fehér, Posted: 4th December 2015 12:22
It is indeed very usual for Hungarian tax laws to be amended significantly at the end of each year.  This year, however, is a bit special, as the focus of the changes is not so much the substantive tax rules, but rather the procedural ones.  They fit into a wider scheme to completely overhaul how tax audits and tax procedures are conducted in Hungary; and not just at the authorit ... Read more...

Tax incentives for new investments in Iceland

By Garðar G. Gíslason, Garðar Víðir Gunnarsson & Gunnar Viðar, Posted: 30th September 2015 12:30
A new Act governing the regulatory regime concerning regional incentives for new investments in Iceland (“the Incentives Act”) has been implemented, which makes Iceland an interesting choice for international investors looking for a competitive edge.  The potential tax incentives are however, not the only thing that should spark an interest with investors.  Th ... Read more...

An Own Goal In The Making? The Implementation Of BEPS In New Zealand

By Neil Russ, Posted: 28th September 2015 09:10
New Zealand is a country with a significant land mass and a small population, located in the South Pacific.  Although its ethnic origins were Māori and European, today New Zealand is a truly Asian country with strong links to China, Japan, Singapore, the Middle East and elsewhere, in addition to our traditional trading and investment partners in Australia, Canada, the European Union, and ... Read more...

Kuwait Tax Law and Recent Developments

By Alok Chugh, Posted: 1st September 2015 12:04
The Kuwaiti Government favours a free market, with little official intervention.  Kuwait has a small, open economy that is dominated by its oil industry, because of which other non-oil sectors of the economy, such as agriculture and manufacturing, play a lesser role in the economy.   Currently, the following taxes are imposed by the Ministry of Finance o ... Read more...

Shifting Sands in MENA

By Guy Taylor & Kevin McManus, Posted: 26th August 2015 09:42
An insight into the changing tax landscape in the Middle East as the region looks beyond its reliance on oil and gas exports and also starts to take stock of broader international focus on the level of taxes paid by corporate groups.    Ronald Regan once said “the government’s view of the economy could be summed up in a few short phra ... Read more...

Calculating Expatriate Income Tax in India

By Tracy Sloop Frost, Dezan Shira & Associates, Posted: 27th July 2015 09:31
In India, an individual’s income is taxed at graduated rates, depending on his/her duration of stay in India and income level. Non-employment income is taxed at a variable rate according to income type. In this article, we outline the rates and calculation methods for both income sources, and summarize common deductions and inclusions in income for expatriates working in India. ... Read more...

Pensions Legislation: The Oncoming Train

By Ian Neale, Posted: 14th July 2015 10:30
It just never ends, does it?  Gone are the days when 'all' an employer had to worry about was managing the defined benefit pension scheme deficit.  Since the advent of automatic enrolment in 2012, pension provision for workers has come onto everyone's radar.  This article looks ahead from within the turbulence created by non-stop tinke ... Read more...

Analysis of Case Studies in Africa Following the Introduction of Transfer Pricing Regulations

By Prof. Dr. Daniel N. Erasmus , Posted: 18th June 2015 14:43
More African countries are introducing transfer pricing regulations.  We have seen an increase in the number of TP controversies.  Here are some case studies of TP controversies we have been involved in, in Africa:   Case Study: Malawi   Issues: Sourcing fees to a procurement intermed ... Read more...

Exclusive Q&A On Transfer Pricing With Luis Carrillo

15th June 2015 08:45
1. What benefits does a firm receive in hiring a transfer pricing specialist?   The benefits of hiring a transfer pricing specialist include greater collaboration with external advisors; greater independence in regards to risk assessment, planning and compliance; and greater cost control over transfer pricing risk.  However, ... Read more...

India Regulatory Brief: Tax Collection to Widen in Tier-II Cities, Company Registrations on Decline

By Dezan Shira & Associates, Posted: 12th June 2015 11:36
I-T Expanding Tax Collection Efforts in Tier-II Cities The Income Tax Department plans to expand its tax collection activities in Tier II cities, such as Jaipur in Rajasthan state, Indore in Madhya Pradesh state and Vishakhapatnam in Andhra Pradesh state. The initiative follows a directive from the federal government to increase the number of taxpayers in the country by ... Read more...

Vietnam to Increase Special Consumption Tax on Imported Cars

By Dezan Shira & Associates, Posted: 28th May 2015 09:37
HCMC – As Vietnam continues to attempt to build up its domestic auto industry, the Ministry of Finance has announced that it has drafted a plan to increase the special consumption tax (SCT) on imported cars by changing the basis on which the tax is calculated. The Vietnamese government has been concerned that the current method of SCT calculation has resulted in a competitive advantage f ... Read more...

China to Roll Back Local Tax Incentives for Foreign Investors

By Rainy Yao, Posted: 8th May 2015 09:18
In December last year, the Chinese government released a circular that requires all the local governments to roll back their regional tax incentives (including subsidies and discounted land and utility fees) for foreign companies. The circular further stipulates that local governments are no longer allowed to offer regional tax incentives or preferential land policies without permission from the S ... Read more...

Getting a Handle on India’s ‘Tax Terrorism’ Against Foreign Investors

By Dezan Shira & Associates, Posted: 5th May 2015 09:43
The tax authorities in India have a very erratic reputation when it comes to their treatment of foreign invested companies in India. Challenges by Indian authorities, and retrospective tax liability rulings from the courts ... Read more...

Landmark change to Portugal’s tax treatment of fiduciary structures (Trusts)

By Verónica Pisco, Posted: 1st May 2015 10:32
The Individuals Income Tax Code suffered major alterations, in Portugal, with effect for Portuguese residents, from 1 January 2015.  The new tax law was published on 31 December 2014, together with the new Budget for 2015 and alterations to the Corporate Tax Code.  In consequence, trusts established by Portuguese residents are now to be taxed for the first time.  Under t ... Read more...

Tradable Tax Incentives a Boost for Service Exporters

By Dezan Shira & Associates, Posted: 10th April 2015 08:20
The federal government is looking to boost India’s services exports via expanding the scope of the existing tax incentive scheme to make it more widely used and effective. The initiative was unveiled in India’s new five-year foreign trade policy on April 1; the plan is a part of the government’s overall strategy to promote service exports for a range of sectors, inclu ... Read more...

An introduction to Italy’s perspectives for 2015

By Angelo Carlo Colombo & Martino Canal, Posted: 7th April 2015 09:31
After three years of recession, 2015 is expected to be the year in which GNP in Italy will resume growth.  Also, thanks to a number of coinciding favorable conditions: low interest rates, an abundance of cash in circulation (thanks to the ECB’s Quantitative Easing), political stability, and reforms completed and promised by the Government.  In addition, the Universal Ex ... Read more...

Philippines Seeks to Allay Fears about Upcoming Tax Incentives Management and Transparency Act

By Dezan Shira & Associates, Posted: 25th March 2015 09:48
The Philippines’ Senate has introduced the Tax Incentives Management and Transparency Act, which attempts to create greater transparency around tax incentives. However, the new legislation has proven controversial – businesses have been fearful that they may lose their current tax breaks.   Speaking in the Filipino Senate, Senate President Pro ... Read more...

Taxation and Technology: Recent Developments on Cloud Computing in Brazil

By Maurício Barros, Posted: 24th March 2015 08:55
For some time now increasing technological development has caused uncertainty in the application of the Law.  This is because technology and the new business models it makes possible develop at a much faster rate than the slow legislative process.  The problem is even worse in the tax area because of the Brazilian Constitution’s rigidity in regard to taxes, taxpayers&am ... Read more...

An Exclusive Q&A On Corporate Tax With J. Leonard Teti II

18th March 2015 09:29
1) Are there any regulatory changes or litigation trends which need to be monitored carefully in 2015? Certainly the biggest US tax trend to watch is statutory: the possibility of tax reform, especially corporate tax reform.  The rise of inversion transactions over the past several years (and the limited success ... Read more...

Exclusive Q&A On Corporate Tax With Tom McClelland

9th March 2015 08:51
1. Are there any regulatory changes or litigation trends which need to be monitored carefully in 2015?   Vietnam’s tax regulations are always in a state of change.  Many of the changes applicable in 2015 are positive, including the removal of the cap on deductibility of advertising and promotion ... Read more...

ASEAN Tax and Regulatory Update

By Dezan Shira & Associates, Posted: 24th November 2014 09:03
In this article we highlight some of the recent tax and regulatory actions taken in the ASEAN region. For further insight into any of these topics or for any other queries, please contact Dezan Shira & Associates.   The importance of ASEAN continues t ... Read more...

Transfer Pricing Aspects in Business Restructurings across Balkans

By Anastasia Sagianni, Posted: 19th November 2014 09:36
Due to tremendous changes in the global economy scene, companies seek opportunities for developing corporate restructuring plans.  The term “Corporate Restructuring” entails the reorganisation of a company in order to attain efficiency and adaptation to new markets.    It is not enough anymore for companies to develop their d ... Read more...

Companies Law and Taxation in Hong Kong

By Mr. Aska Mak, Posted: 31st October 2014 08:52
According to the Fraser Institute’s annual Economic Freedom of the World report released on 7 October 2014, Hong Kong is ranked as one of thetop 10 most economically free jurisdictions.  The maturity law a ... Read more...

Malaysia-Indonesia Tax Battle Set to Boost Crude Palm Oil Sales

By David Lee, Posted: 13th October 2014 09:02
  For economists and investors interested in Southeast Asia, it is vitally important to be informed about the state of tariffs on crude and refined resources. The region is lauded for its raw, export-driven trade of foods, oils, minerals, and tropically-sensitive materials. Regardless of their individual values, the trade and taxation of exported resources from Southeast Asia ... Read more...

Oman - 2014 Current Fiscal & Tax Trends

By Ahmed Amor & Alkesh Joshi, Posted: 25th September 2014 08:46
The Government of Oman’s fiscal budget for 2014 reflects a deficit of US$4.7billion, with tax and duties expected to be the second largest contributor to the exchequer after oil and gas.  The Government also expects a 17% increase in tax collections compared to 2013.  This clearly underscores the importance of tax collection.    ... Read more...

Indirect Transfers Continues To Create Controversy

By Ranjeet Mahtani, Posted: 24th September 2014 08:39
“Indirect transfers” has garnered worldwide attention in the recent past.  The controversy which begun during the year 2007, continues to be the most talked about corporate income tax controversy.  This article briefly touches upon this issue, given a recent judgment of the High Court of Delhi in Copal Research Ltd and the legislative amendments.  ... Read more...

Vietnam Expands the Scope of the Foreign Contractor Tax

By Dezan Shira & Associates, Posted: 15th September 2014 10:01
In a newly released circular, the Vietnamese government has expanded the reach of the Foreign Contractor Tax (FCT). The FCT Circular 103/2014/TT-BTC, issued by the Ministry of Finance, replaces the previous FCT Circular 60/2012. Circular 103 will become effective on October 1, 2014. FCT is the main ... Read more...

India is at the Cross Road of Major Indirect Tax Reforms

By Nihal Kothari, Posted: 12th September 2014 08:23
The present indirect tax structure in India is quite complex.  Multiple taxes are levied by the Federal (referred as central) and State governments on tradable goods and services.  On imports three different elements of customs duties are levied.  Excise duty is levied on domestic manufacture of goods at different slab rates depending on the product.  Service ta ... Read more...

Luxembourg: An Update for Wealth Management and Innovative Products

By Francis Hoogewerf FCA, Posted: 9th September 2014 09:10
Luxembourg, being a crossroad between France, Germany and Belgium, makes it an ideal destination for entrepreneurs.  The country has a very strong reputation in banking, investment funds and is an ideal location in Europe to centralise cross-border tax arrangements.    The status of the country, as the number one investment centre in the EU and ... Read more...

Tax Risks & Controversies – Current Trends in the Middle East

By Morris Rozario & Alkesh Joshi, Posted: 4th September 2014 08:53
New tax legislation, more extensive compliance requirements and stringent tax enforcement in many countries are increasing tax risks for companies doing business in the Middle East and North Africa (MENA) region.   EY’s global 2014 tax risk and controversy survey confirms the above on-the-ground experience in the MENA region.   ... Read more...

Taxation in Luxembourg

By Sébastien Labbé and Jean-Paul Olinger, Posted: 2nd September 2014 08:50
Sébastien Labbé and Jean-Paul Olinger, tax partner specialised in the financial services sector now leading KPMG Luxembourg’s tax practice and tax director within the Financial Services team of KPMG Luxembourg, respectively, spoke to Corporate Livewire in reference to recent tax changes which could affect the Luxembourg market. ... Read more...

The Past, Present and Future of VAT Reform in China

By Rainy Yao and Zhou Qian, Posted: 1st September 2014 08:34
At the start of 2012, China launched a massive reform to replace BT with VAT, two of the country’s three major indirect taxes. Prior to the reform, VAT was levied only on the sale and import of tangible goods and on the provision of processing, repair, and replacement services. Meanwhile, BT was levied on the provision of all other services as well as the transfer of intangible and real ... Read more...

The World Turned Upside Down: Understanding Corporate Inversions

By J. Leonard Teti II, Posted: 29th August 2014 09:58
History tell us that, before leaving America after Lord Cornwallis’s surrender to George Washington at Yorktown, the British fife and drum corps played “The World Turned Upside Down”.  The recent trend of so-called “inversion” transactions among US companies breathes new meaning into the song.    ... Read more...

Transfer Pricing in Malaysia: Past, Present and Future

By Sowmya Varadharajan, Posted: 14th July 2014 09:06
Transfer pricing, which refers to the manner in which multinational corporations transfer goods and services between and within each other, continues to be an important issue for the Inland Revenue Board (IRB) in Malaysia. This article discusses recent developments in transfer pricing in Malaysia and advises taxpayers operating in Malaysia on how to prepare for scrutiny by the IRB. &l ... Read more...

International Taxation in South Africa: Double Tax Agreements, & Legislation

By Basil Coutsoudis, Posted: 17th June 2014 08:49
In an international trade context, international taxation refers to various treaty provisions relieving international double taxation.  It incorporates domestic legislation covering foreign income of residents and domestic income of non-residents.   It incorporates domestic legislation,(1) treaty provisions containing domestic ... Read more...

Exclusive Q&A On Transfer Pricing

With Nate Carden, Posted: 13th June 2014 09:21
Q) What benefits does a firm receive in hiring a transfer pricing specialist? Practitioners focused on transfer pricing typically serve many clients in similar industries, which means the specialist's advice to one taxpayer is informed by how other taxpayers approach transfer pricing. Possessing the ability to assess how one taxpayer& ... Read more...

Two-Year Tax Breaks Proposed for Philippines' Startups

By Dezan Shira & Associates, Posted: 12th June 2014 09:08
Paolo Benigno Aquino, Chairman of the Senate Committee on Trade, Commerce, and Entrepreneurship, has filed a bill that would grant a tax exemption for startup businesses in the Philippines during their first two years of establishment. According to Aquino, Senate Bill 2217< ... Read more...

China Enhances Export Tax Rebates to Boost Foreign Trade

By Dezan Shira & Associates, Posted: 28th May 2014 09:12
In response to a recent slump in foreign trade, China’s State Council has announced a swath of new export tax measures, including plans to improve the country’s export tax rebate system and simplify the application pro ... Read more...

The Tax Benefits For Foreign & International Investors From The Newly Approved Portuguese Corporate Income TAX Reform

By Jorge Veiga França, Posted: 24th March 2014 09:27
This article is mainlyfocused on the recent Portuguese Corporate Income Tax Reform that entered into force last January 16, 2014, with the enactment and issuing in the Official Gazette of Law nº 2/2014. Special emphasis is made to the benefits resulting there from to foreign or international investors that decide to invest in the Portuguese territory or through it, namely wit ... Read more...

Vietnam Issues Circular 219 on VAT

By Dezan Shira & Associates, Posted: 3rd March 2014 08:47
The Vietnamese government has recently released Circular 219 and contains guidance on the implementation of the new VAT Decree 209. The Circular is effective retroactively from January 1, 2014, and is a replacement for Circular 06/2012.   Key changes brought about by Circular 219   With regards to ze ... Read more...

Calculating Taxes and Duties for Import to China

By Angela Ma, Posted: 6th February 2014 09:34
The taxes involved in import to China include import duties, value-added tax (VAT), and possibly consumption tax (CT) if the product being imported falls under CT specified categories. For foreign trading companies engaged in the business of selling (or import) to China, it is wise to be fully clear about the relevant tax issues before rushing into signing any sales contracts, because the amount o ... Read more...

Calculating Value-Added Tax in China

By Dezan Shira & Associates, Posted: 10th January 2014 08:51
In 2012, China launched the value-added tax (VAT) pilot reform to improve the efficiency of its national tax system. The VAT pilot reform replaces business tax (BT) with VAT in the transportation industry and certain modern service sectors at the start of 2012.   First implemented in Shanghai, the reform expanded to Beijing in September 2012 and Jiangsu, Anhui, F ... Read more...

Implications of the VAT Reform in China

By Dezan Shira & Associates, Posted: 20th December 2013 08:58
The VAT pilot reform represents tax saving opportunities for many taxpayers, but increased tax burdens for others. For service providers in China who are now registered as general VAT taxpayers, they can claim input VAT credits for the purchase of goods, fixed assets and services used in their business. It is therefore more advantageous for these service providers to contract with other providers ... Read more...

Utilising Tax Credits in the Entertainment Industry

By Marc Jacobson & David Jacob, Posted: 18th December 2013 09:34
One of the biggest concerns of every film and TV producer is how to take advantage of tax credits and rebates.  These incentives can heavily influence where a producer chooses to spend its budget during all three phases of the production (preproduction, production and post-production).  The purpose of the tax incentives is to attract productions into the state that will create jo ... Read more...

China Clarifies Details for the Coming Fiscal and Tax Reforms

By Dezan Shira & Associates, Posted: 11th December 2013 08:36
One of the key focal points mentioned in the “Decision on Major Issues Concerning Comprehensively Deepening Reforms (hereinafter referred to as the “Decision”)” is to deepen the reform of China’s fiscal and tax system. Recently passed during the Third Plenary Session of the 18th Central Committee of China’s Communist Party (Third Plenum), ... Read more...

ASEAN’s Rising Minimum Wage Levels: Vietnam

By Dezan Shira & Associates, Posted: 6th November 2013 14:06
Several ASEAN countries have raised their minimum wage standards recently to adjust their respective salary levels to the rising costs of living and to provide their citizens with higher purchasing power. However, many businesses and investors have complained that the somewhat drastic wage hikes have hurt the market in terms of competitiveness and lowering worldwide interest in establishing a busi ... Read more...

What’s Up in France? – Everything new is Expensive

Written by Jérôme Barré, Posted: 30th September 2013 09:06
As in past years, 2013 is in France a year very interesting one concerning tax actuality. Indeed, the 2013 Finance Act and 2012 Amended Finance Act have brought a lot of news most of it not particularly positive for tax payers. Some of this changes concerned corporate tax while others concerned income tax and, consequently, company managers. We propose you a brief summar ... Read more...

From Crisis to Opportunity: Portugal is becoming a Gateway for Investment

By Tiago Marreiros Moreira & Francisco Cabral Matos, Posted: 26th September 2013 16:07
The Portuguese economy has been facing significant challenges particularly in the past few years, not only as an immediate result of the financial crisis, but also and in a more structural manner, in the general context of the worldwide globalisation.    Whilst it may be argued that Portuguese enterprises took some time to break new grounds and expand th ... Read more...

Austria - Beyond Mozart & Chocolate

By Imke Gerdes, Posted: 19th September 2013 08:18
On a global scale, the last years were characterised by the economic crisis, which prompted discussions on the level of the OECD, the European Union and the UN on rightful taxation and ensuring that countries get their fair share in revenue.  The most significant developments, the fight for transparency and against unfair tax competition, resulted in the OECD Report on Base Erosion and Pr ... Read more...

Transfer Pricing Disputes Likely to Increase in France due to Budget Deficits

By Cyril Maucour, Posted: 17th September 2013 09:14
Foreign companies with operations in France have been experiencing or most certainly will experience a tax audit in France as the French Tax Authorities (FTA) tend to regularly audit French companies.   The FTA have been very active in the audit field as the total amount of notified adjustments, including principal penalties and interest, was in the range of EUR ... Read more...

The Tax Amnesty under the New Colombian Tax Bill

Written by Monica Reyes and Andrea Catalina Nieto, Posted: 11th September 2013 09:28
Customarily, the tax reforms that are implemented as part of the fiscal policies of each government in Colombia include tax “amnesties” to incentive taxpayers to comply with obligations that the tax authorities find difficult to enforce, in order to increase the collection of revenues by offering the exclusion from penalties and delayed payment interest.  ... Read more...

The BAA Case & VAT on Deal Costs

By Paddy Behan, Posted: 5th September 2013 08:39
Why should anyone in the M&A world worry about VAT?  The simple answer is cost: VAT can drive deal costs up by 20%.  The importance of VAT risk is illustrated by decision in BAA Ltd v Revenue and Customs Commissioners.    What happened in the BAA case?  < ... Read more...

China Signs Multilateral Tax Convention to Combat Tax Evasion

By Dezan Shira & Associates, Posted: 2nd September 2013 08:24
On August 27, the Administrator of China’s State Administration of Taxation (SAT), Wang Jun, signed the “Multilateral Convention on Mutual Administration Assistance in Tax Matters (hereinafter referred to as the ‘Convention’)” of the Organization for Economic Co-operation and Development (OECD) in Paris on behalf of Chinese government, illustrating ... Read more...

China’s VAT Reform Creates Confusion in Remittances to Foreign Suppliers

By Dezan Shira & Associates, Posted: 16th August 2013 08:34
Hollywood studios owed millions in just one example   Following China’s reform of its value-added tax (VAT) system, effective from August 1st, many international businesses have fallen foul of confusion in the regulations, preventing many from being paid. In the Chinese film industry alone, Hollywood studios including Warner Bros, S ... Read more...

China Releases Administrative Measures on Authorized Tax Collection

By Dezan Shira & Associates, Posted: 24th June 2013 08:18
With the view to strengthen the administration over authorized tax collection, China’s State Administration of Taxation released the “Administrative Measures for Authorized Tax Collection (Announcement [2013] No. 24, hereinafter referred to as ‘Measures’)” on May 30, which stipulates the scope and conditions o ... Read more...

Vietnam’s Taxes on Business

By Dezan Shira & Associates, Posted: 14th June 2013 08:31
In a tough global economy, major foreign investors continue to prioritize their investments into Vietnam. Many small-medium sized enterprises are following in step, acting on the business potential that Vietnam holds for companies of all sizes and a variety of industries. It is thus increasingly important to understand the taxes which Vietnam imposes on business. &am ... Read more...

How to Avoid Double Taxation in Vietnam

By Dezan Shira & Associates, Posted: 3rd June 2013 08:36
Both foreign and domestic residents of Vietnam are able to obtain reductions and exemptions on their taxes through a variety of different methods. Thanks to the DTAAs that Vietnam has, the tax reductions and exemptions you may be subject to are easy to understand and to take advantage of – all you need to do is follow the simple steps listed below to apply.   ... Read more...

Tax Implications of a Service Permanent Establishment

By Eunice Ku and Shirley Zhang, Posted: 31st May 2013 08:26
With an increasing number of foreign enterprises starting to conduct business in China, tax liabilities resulting from business activities within the country are fast becoming an issue of key concern. If an establishment or venue of a non-resident enterprise constitutes a service permanent establishment (PE) in China, it will be subject to 25 percent CIT on all of its China-sourced income, as well ... Read more...

Introduction to Double Taxation Avoidance in Vietnam

By Dezan Shira & Associates, Posted: 28th May 2013 09:32
With regard to international trade, the various countries’ tax systems oftentimes put global investors in the unfavorable position of having to face redundant taxes on their income —i.e., double taxes . For example, a company may be subject to taxes in its country of residence and also in the countries where it raises income through foreign investm ... Read more...

Tax Focus: M&As of Chinese Domestic Companies by Foreign Investors

By Eunice Ku and Shirley Zhang, Dezan Shira & Associates, Posted: 2nd May 2013 08:52
With respect to M&As involving the acquisition of Chinese domestic companies by foreign investors, in June 2009, the Ministry of Commerce promulgated the “Provisions on Foreign Investors’ Merger with and Acquisition of Domestic Enterprises (Order No. 6, ‘M&A Provisions’),” which address share and asset acquisitions of Chinese enterp ... Read more...

Import-Export Taxes and Duties in China

By Shirley Zhang, Dezan Shira & Associates, Posted: 21st March 2013 09:03
Importing to and exporting from China generally involves three types of taxes:   1.    Value-added tax; 2.    Consumption tax; and 3.    Customs duties.   1. Value-added Tax for Imported Goods ... Read more...

U.S. Foreign Account Tax Compliance Act in Full Swing

By Dezan Shira & Associates, Posted: 11th March 2013 08:41
The Foreign Account Tax Compliance Act (also known as FATCA), was enacted in 2010 by the U.S. Congress to target non-compliance by U.S. taxpayers using foreign accounts. It requires foreign financial institutions (FFIs) to report to the Internal Revenue Service (IRS) information about financial accounts held by U.S. taxpayers worth more than US$50,000, or by foreign entities in which U.S. taxpayer ... Read more...

An Overview of India’s Taxes on Business

By Dezan Shira & Associates, Posted: 20th February 2013 08:49
In this article, we give a brief overview of India’s major taxes and duties on business, including Corporate Income Tax, Dividend Distribution Tax, Minimum Alternative Tax, Value-Added Tax, Central Sales Tax, Goods And Service Tax, Customs Duty, Excise Duty (CENVAT) Service Tax, Capital Gains Tax, Wealth Tax, and Withholding Tax.   The central and state ... Read more...

Vietnam vs. China: Corporate Income Tax

By Dezan Shira & Associates, Posted: 28th January 2013 09:48
Many foreign investors operating in China today are looking at Vietnam as a sort of additional “province” or alternative hub to integrate into their current Chinese or Asian supply chain. This is particularly true in sectors where China and Vietnam often compete, such as leather goods, shoes, textiles, furniture and light electronics. This list is set to expand as Vietnam is up ... Read more...

China Expat Tax Filing and Declarations for 2012 Income

By Dezan Shira & Associates, Posted: 25th January 2013 10:14
Individual income tax (IIT) is normally withheld from wages or salaries by employers and paid to the tax authorities on a monthly basis (within 15 days of the end of each month).   An annual IIT declaration should be submitted to tax authorities within three months of the end of the previous calendar year (i.e., between January 1, 2013 and March 31, 2013 for the ... Read more...

The Settlement Of Tax Disputes

By Philip Baker QC, Hui Ling Mccarthy & Laurent Sykes, Posted: 2nd January 2013 12:58
Tax disputes happen.  This is an inevitable consequence of complex tax systems and complex fact matrices.  The important thing is that they are either avoided – if possible – when tax advice is given, or, if they cannot be avoided, that they are resolved satisfactorily.   Tax barristers belong to that part of the UK legal pro ... Read more...

Double Tax Agreements– An invaluable framework for certainty of tax outcomes in the Middle East and North Africa region

By Tobias Lintvelt & Seema Sharma, Posted: 7th December 2012 10:10
The tax environment in Middle East & North Africa (“MENA”)   In many MENA countries, the Arab spring has brought to the fore, the urgent need to substantially increase employment and improve the social well being of their population majorities.  Governments in these countries are responding with th ... Read more...

Da Nang Offers Massive Tax Incentives for Dutch Businesses

4th December 2012 10:07
Da Nang Hi-Tech Park is the newest among three high-technology zones in Vietnam, besides Hoa Lac Hi-Tech Park in Hanoi and the Ho Chi Minh City Hi-Tech Park. Da Nang City is calling for foreign investment in its hi-tech park by promising attractive incentives. The Vice Chairman of Da Nang Phung Tan Viet presented in front of the Dutch business representatives in an event ... Read more...

India Amends DTAs with Spain and the United Kingdom

By Dezan Shira & Associates, Posted: 28th November 2012 09:12
India has initiated the process to revise its double taxation avoidance agreements (DTAs) with over 75 countries in an effort to strengthen its legislative framework to control the black money generated domestically and the flow of such illegal funds to foreign countries. On October 26, India signed a protocol to amend the existing 19-year-old DTA with Spain to facilitate the exchange ... Read more...

Ireland - The Domicile of Choice For Structuring Distressed Asset Deals

By Eleanor MacDonagh, Fergus Gillen & Mark White, Posted: 12th November 2012 09:03
Since 2008, US private equity funds, among other investors, have been seeking to invest in distressed debt portfolios in Ireland and elsewhere.  In the past 10 months in Ireland, however, there has been a marked increase in the number of deals completing.  Interesting trends are emerging in connection with the structures explored and employed for the purposes of housing the targe ... Read more...

Tax Disputes – Barbados & The Caribbean

By Dominique Pepin, Posted: 6th November 2012 09:07
Disagreements, to various degrees, are a part of every relationship.  The use and enforcement of taxing statutes has the potential to give rise to conflict, with both the taxing authorities and the taxpayers having opposing views and objectives.   As in many other relationships, a tax dispute takes its roots in the actions of a third party:  in ... Read more...

Tax Planning & Investment Opportunities In Ireland

By Damien Malone, Posted: 30th October 2012 09:09
The number of businesses locating in Ireland over the past decade has increased enormously with major multinationals basing their international operations here and foreign individuals starting their business – some helped by state aided international start-up funds to target investor ready overseas entrepreneurs – in Ireland.   R ... Read more...

Offshore: Tax, Morality & The Future

By David Petit, Posted: 23rd October 2012 09:06
The media had a field day over Jimmy Carr’s use of a tax scheme using an offshore jurisdiction and once again politicians have been quick to tap into the concern of the general public, this time linking tax avoidance, or should I should say tax mitigation, to issues regarding morality.   This is dangerous ground of course; some may questio ... Read more...

Germany plans to further amend its business taxation system: new tax burdens for corporate minority holdings

By Stefan Süss & Dr. Thomas Fox, Posted: 9th October 2012 08:52
German legislators plan to further amend the German domestic holding privilege. Proposed plans include making capital gains and dividends from certain corporate minority stakes fully taxable. The changes will have a large impact on the German tax landscape, and they bring Germany closer to the ambitious and often-copied taxation system introduced in the early 2000s. This article provides ... Read more...

Limiting Tax Exposure for American Expatriates in China

By Dezan Shira & Associates, Posted: 8th October 2012 08:36
American expatriates’ global income may be exposed to China individual income tax (IIT) at marginal rates reaching 45 percent. The expatriate may also be required to contribute to the new Chinese social insurance program, and Chinese entities employing such an expatriate may be required to contribute at a multi ... Read more...

Amendment to the Singapore-Vietnam Double Taxation Agreement

By Tom McClelland, Posted: 3rd October 2012 08:44
Singapore has historically been a favoured holding company location for investment into Vietnam.   The Singapore-Vietnam Double Taxation Agreement (“DTA”) has been a major reason for this.   In September Singapore and Vietnam signed a second protocol to amend certain Articles of the Singapore-Vietnam Double Taxation Agreement (“DTA& ... Read more...

China Releases Circular to Crack Down on Tax Over-Collection

By Dezan Shira & Associates, Posted: 1st October 2012 09:07
To standardize the law enforcement of tax collection and ensure the thorough implementation of tax policies, China’s State Administration of Taxation (SAT) issued the “Notice on Implementing the Inspection over Tax Collection on Individual Businesses (hereinafter referred to as the ‘Notice’)” on September 3, aiming to crack down on the over-collect ... Read more...

GAAR Execution May Be Postponed to 2016-17

By Dezan Shira & Associates, Posted: 11th September 2012 08:41
A specialist group on tax laws recommended that the Indian government postpone execution of the General Anti-Avoidance Rules (GAAR) until financial year 2016-17 and eliminate capital gains tax on securities transfers to ensure investment and capital flows. The group, appointed by the Prime Minister of India, suggested a series of steps which are likely to alleviate invest ... Read more...

VAT General Taxpayer Status: How & Why

By Christian Fleming, Posted: 7th September 2012 09:42
VAT status in China crucial for pre-incorporation financial planning, especially for SMEs.  One factor to consider when calculating the overall cost of China’s recent VAT reform is whether or not a company should become a general taxpayer or remain a small-scale taxpayer.  Although the VAT rate for small-scale taxpayers is much lower than that for general ta ... Read more...

Is Portugal Still An Interesting Country For Investors To Look At?

By Tiago Marreiros Moreira & Francisco Cabral Matos, Posted: 4th September 2012 09:10
Saying that “Portugal is an interesting country for investors to look at” may seem a bold statement.  We take the risk of putting forward such statement, but we also take the opportunity to give substance to it and have a glance on some of the existing opportunities and a few others coming up soon.   Portugal has suffere ... Read more...

Restrictions On Tax Deductions For Acquisition Financing

By Sara Luder, Sébastien de Monès & Paul Sleurink , Posted: 29th August 2012 08:31
The UK has made great strides in reforming its corporate tax rules to make it competitive for UK based multinationals.  Corporates are exempt from tax on dividend income and on gains arising on the sale of subsidiaries, but they are still, broadly speaking, entitled to claim an interest deduction in respect of acquisition debt.     ... Read more...

Vietnam Tax Developments

By Tom McClelland, Posted: 20th August 2012 09:00
If there is one thing that is certain concerning Vietnam’s tax system it is change.  This has been no different in 2012 with new regulations for all the major taxes.  There have been some positive changes including a new withholding tax Circular in which the interest withholding tax rate (a deemed Corporate Income Tax (“CIT”)) has been re ... Read more...

Managing Tax Risk & Tax Controversy In The Middle East

By Morris Rozario, Posted: 13th August 2012 08:39
All companies are concerned with the same bottom-line question about their taxes: “How much are we going to pay this year?”  For global companies, that question is harder to answer than it has been for many years.    From a business perspective, tax costs like all other expenses, need to be managed to ensure cer ... Read more...

VAT Pilot Reform to be Implemented in Beijing and Other Regions from September

By Dezan Shira & Associates, Posted: 10th August 2012 09:52
On July 31, 2012, the Ministry of Finance and the State Administration of Taxation issued the “Notice on Commencing the Business Tax (BT) to Value-added Tax (VAT) Conversion Pilot Reform in the Transportation and Certain Modern Services Industries in Beijing and Seven Other Provinces and Municipalities (hereinafter referred to as the ‘Notice’)”.& ... Read more...

India Tax Deadline Approaching

By Dezan Shira & Associates, Posted: 3rd August 2012 10:01
The tax filing date for the financial year 2011-12 is July 31, 2012.  Returns can be filed after July 31, 2012 but before the relevant assessment year (March 31, 2013), however it is advisable to file the tax returns by the due date.   The timelines for filing up of tax returns are as follow:    - November 30, ... Read more...

China Issues Guiding Opinions to Regulate Taxation Administrative Discretion

By Yao Lu, Posted: 25th July 2012 09:37
To standardize the enforcement of taxation law and safeguard the legitimate rights and interests of taxpayers, China’s State Administration of Taxation (SAT) issued the “Guiding Opinions on Regulating the Administrative Discretion of Taxation Authorities (guoshuifa [2012] No.65, hereinafter referred to as ‘Opinion’)& ... Read more...

India’s Goods and Service Tax

By Chris Devonshire-Ellis, Posted: 20th June 2012 08:30
 India’s goods and service tax (GST) is a nationwide comprehensive indirect tax levied on the manufacturing, sales and consumption of goods as well as services. GST is intended to create a single unified Indian market with fewer complications – in turn making it an attractive investment destination. Current scenari ... Read more...

Ten Cities and Provinces Apply to Participate in VAT Reform Pilot Scheme

By Xiaolei Gu, Posted: 30th May 2012 09:06
At a conference with the China Certified Tax Agents Association, Deputy Director of the Department of Goods and Services Tax under the State Administration of Taxation, Long Yuehui, revealed that 10 cities and provinces have officially applied to participate in the value-added tax (VAT) reform pilot scheme so far, including Beijing, Chongqing, Shenzhen, Tianjin, Xiamen, Anhui Province, Fujian Prov ... Read more...

Carbon Tax

By Martin Fowler, Posted: 23rd May 2012 09:27
One of the most contentious political issues facing a number of countries either now or in future years involves placing a price (or tax) on carbon.   It has been said that arguably the two most important issues the world currently faces are:   1) The prevention of  nuclear weapons falling in to the hands of rogue states o ... Read more...

India Issues Ruling on Transfer Pricing Aspect of Royalty Payments

By Dezan Shira & Associates, Posted: 18th May 2012 10:39
The Delhi High Court, in its ruling on the case of Commissioner Income Tax vs. EKL Appliances Limited (Taxpayer), has given its decision on the transfer pricing aspects of a royalty payment by the Taxpayer to its associated enterprise. In its judgment, the High Court ruled that royalty payments cannot be prohibited on instances of continuous loss where the spending was proven to be inc ... Read more...

China RO vs. FICE

By Dezan Shira & Associates, Posted: 14th May 2012 09:25
Recent changes to China’s tax treatment of representative offices (ROs) have started to infringe on the viability of using an RO as a vehicle for “investment” into China in terms of increasing financial pressure. While often stated as being an “investment” vehicle, alongside wholly foreign-owned enterprises (WFOEs) and foreign-invested commercial e ... Read more...

China: Individual Income Tax Liabilities for Senior Personnel

By Eunice Ku, Posted: 2nd May 2012 10:34
The individual income tax (IIT) liability of employees holding a director or senior management position (including general and deputy managers, supervisors, persons occupying functional chief positions, and other persons occupying similar management level positions, collectively “senior personnel”) in China is dependent on a few factors, namely:   ... Read more...

China’s SAT Issues Measures for Claiming Zero-Rated VAT

By Dezan Shira & Associates, Posted: 30th April 2012 09:56
Following the pilot value-added tax (VAT) reform and the issuance of the “Circular on the Application of Zero VAT Rate and VAT Exemption on VATable Services (caishui [2011] No. 131, hereinafter referred to as ‘No. 131’),” China’s State Administration of Taxation (SAT) on April 5 issued ... Read more...

Brazilian Business Opportunities Under Updated Taxation System

By Gerd Foerster, Posted: 18th April 2012 10:22
Amongst the several advantages of doing businesses in Brazil, the most important are related to the Brazilian territorial size and its population.  Possessing an almost continental extension, being the fifth largest country of the world in area and with a population of approximately 200 million inhabitants, Brazil has a consuming market of more than 120 million people. ... Read more...

Vietnam’s New Tax Schedule for 2012

By Nguyen Huyen , Posted: 17th April 2012 11:15
Vietnam’s Ministry of Finance issued Circular No.157/2011/TT-BTC on November 14, 2011, stipulating the tax rates of export and import tariff preferences under the list of taxable items. The Decree takes effect from January 1, 2012. The 2012 tax schedule has been rene ... Read more...

India Increases Service Tax Rate

By Dezan Shira & Associates, Posted: 12th April 2012 10:21
Service tax is the tax charged on services offered, which has to be collected from the clients and paid to the government. If these taxes increase, there is an increase in many expenses such as mobile bills, insurance premiums, professional consultations, property purchases from the builder, courier expen ... Read more...

Increased Transfer Pricing Interest In Argentina

By Carlos Casanovas and Milton Gonzalez Malla, Posted: 4th April 2012 12:36
Governments are increasingly focused on raising revenues through taxation.   As a result, more jurisdictions are ramping up their enforcement efforts — not only in developed nations but also in many emerging markets.   For instance, tax collection in Argentina has risen steadily during late years.  In fiscal year 2010 government' ... Read more...

Through The Open Window - Leveraging Cross-Jurisdictional Opportunities For BVI Property Transfers

By Willa Tavernier, Posted: 30th March 2012 11:49
A rare congruence of exemptions under the US and BVI tax codes has prompted United States (“U.S.”) citizens holding British Virgin Island (“BVI”) property to undertake inter vivos transfers to their heirs during 2012. The U.S. lifetime gift tax exclusion up to $5 million, ... Read more...

Six Key Points Regarding China’s Tax Reforms in 2012

By Dezan Shira & Associates, Posted: 16th March 2012 10:27
According to the “Report on the Implementation of Central and Local Budgets for 2011 and on Draft Central and Local Budgets for ... Read more...

Investing in Australia

By Robyn Schofield, Posted: 1st February 2012 10:17
With a flat corporate tax rate of 30% (applying to both revenue and capital gains), Australia is far removed from the zero or low tax jurisdictions traditionally considered to be "tax havens".  Nonetheless, the Australian Government has long desired to establish Australia as a financial services hub and the past decade has s ... Read more...

SAT Clarifies VAT Issues Concerning Overdue Tax Payment Vouchers

By Dezan Shira & Associates, Posted: 17th January 2012 09:42
On December 29, the State Administration of Taxation (SAT) issued the “Announcement on Issues Concerning the Offset of Value-added Tax (VAT) using Overdue Tax Payment Vouchers (SAT Circular [2011] No. 78)” (the “Announcement”) to resolve the issue of the inability of general VAT payers to declare input V ... Read more...

Tax Rates in Vietnam

By Dezan Shira & Associates, Posted: 16th January 2012 10:12
As the Global Financial Crisis rumbles on, with certain reduced growth rates on the horizon for Europe and the United States, multinationals are looking elsewhere to achieve their business goals. Asia, a region riddled with wars and ineffective economic policies for much of the past century, has finally stepped into the front line of global trade and com ... Read more...

Tax Rates in China

By Dezan Shira & Associates, Posted: 29th December 2011 12:41
As the Global Financial Crisis rumbles on, with certain reduced growth rates on the horizon for Europe and the United States, multinationals are looking elsewhere to achieve their business goals. Asia, a region riddled with wars and ineffective economic policies for much of the past century, has finally stepped into the front line of global trade and commerce. Like most things in emerging ... Read more...

Tax Rates in India

28th December 2011 12:51
As the Global Financial Crisis rumbles on, with certain reduced growth rates on the horizon for Europe and the United States, multinationals are looking elsewhere to achieve their business goals. Asia, a region riddled with wars and ineffective economic policies for much of the past century, has finally stepped into the front line of global tr ... Read more...

Tax Rates in Singapore

By Dezan Shira & Associates, Posted: 22nd December 2011 10:18
As the Global Financial Crisis rumbles on, with certain reduced growth rates on the horizon for Europe and the United States, multinationals are looking elsewhere to achieve their business goals. Asia, a region riddled with wars and ineffective economic policies for much of the past century, has finally stepped into the front line of global trade and com ... Read more...

Tax Rates in Hong Kong

By Dezan Shira & Associates, Posted: 19th December 2011 10:59
As the Global Financial Crisis rumbles on, with certain reduced growth rates on the horizon for Europe and the United States, multinationals are looking elsewhere to achieve their business goals. Asia, a region riddled with wars and ineffective economic policies for much of the past century, has finally stepped into the front line of global trade and com ... Read more...

Taxation of the Oil Sector in Central Africa (CEMAC Area)

By François NOUVION, Posted: 7th December 2011 09:56
The Hydrocarbons legislations of countries that belong to the Monetary and Economic Community of Central Africa (CEMAC: Cameroon, Central African Republic, Congo, Gabon, Equatorial Guinea, Chad) all provide, as a rule, that hydrocarbons contained in the soil and subsoil are the property of the State and therefore belong to the public domain(1). Agreements entered into ... Read more...

Singapore as a Holding Domicile for Your China Operations

By Chris Devonshire-Ellis, Posted: 21st November 2011 09:42
Both Hong Kong and Singapore provide viable domiciles for a holding company…But what are the differences? Singapore doesn’t usually come onto the radar for most folks when it comes to holding China investments, but in the changing dynamic ... Read more...

The changing Middle East income tax landscape –Deemed profit basis tax declarations under threat

By Morris Rozario, Posted: 20th October 2011 09:04
The advent of the Arab Spring civil unrest has brought about paradigm changes to the political and social economic landscapes in countries from Bahrain to Tunisia, with the bells ringing change continuing to toll in many countries.  The promulgation of new tax laws with lower income tax rates and the impact of the continuing global financial turmoil are also contributing impetus ... Read more...

VAT And Export Of Services

By Mirjeta Emini of Boga & Associates, Posted: 18th October 2011 09:39
In the ambit of the Stabilization and Association Agreement entered into between Albania and EU, Albania has adopted certain amendments to its VAT legislation aiming to harmonize its internal legislation with that of the EU.  Some newly adopted rules on VAT treatment of exports have been associated to the harmonization obligation.  Though sub-legal acts have also been pa ... Read more...

Significant Vietnam Tax Developments

By Tom McClelland, Posted: 17th October 2011 08:54
In September the Vietnam Ministry of Finance released draft regulations which have introduced significant changes with respect to the taxation of cross border transactions.  These include the introduction of a thin capitalization rule restricting interest deductions, changes in the withholding tax rates as well as new transfer pricing provisions which include the initial regulato ... Read more...

Zero-tax UK Companies

By Milton Grundy, Posted: 14th October 2011 09:37
Those who live in the United Kingdom do not think of themselves as inhabiting an offshore centre.   Quite the contrary.   But those who do not live in the United Kingdom can to a surprising degree use the country as if it were an offshore centre.  Some readers will no doubt remember the happy days when the zero-tax non-resident English company ... Read more...

Adverse economic aspects of withholding taxes in the Republic of Congo

By Richard Moulet of Sutter & Pearce, Posted: 3rd October 2011 11:23
The Republic of Congo  has not escaped the wave of relocation occurred with respect to taxes on income, in many African countries for a good ten years Indeed, the traditional taxation of Francophone African states is based on the principle of territoriality, reproduction of the French system by which it is derived. However ... Read more...

Transfer Pricing: A New Tax Challenge for Chile

By Osiel González, Mauricio Loy and Tyriak Bruzual, Posted: 30th September 2011 09:36
As a result of Chile's entry as a full member of the OECD, Transfer Pricing (TP) has received special attention by both the Chilean IRS and the taxpayers.  In this perspective, both parties have devoted time and resources to learn more in detail the scope and the implications that this has now nationally and internationally. ... Read more...

The UK within International Structures – Recent Developments

By Tom Cartwright, Posted: 29th September 2011 10:21
The idea of Chancellor George Osborne in a poncho may be a surprising image, but recent proposals for change in UK tax law in the international sphere have been a case of the good, the bad and the ugly. CFC Reform – Finance Companies The UK's controlled foreign company (CFC) rules apply to impose a charge ... Read more...

The Belgian notional interest deduction: Practical uses of a unique corporate income tax feature

By Axel Haelterman & Robert Neyt , Posted: 26th September 2011 10:27
1. Introduction The Belgian Notional Interest Deduction (NID), is a unique, straightforward and beneficial tax measure contributing to Belgium’s status as a centre for corporate headquarters and intra-group financing entities.  It reduces the effective corporate income tax (CIT) rate, increases the after tax retu ... Read more...

Romania – Emerging Market with “Tax Appeal”

By Andrei Dumitrache, Posted: 19th September 2011 10:00
Whenever called to give a few words on doing business in Romania, I always dedicate a substantial part of that to the Romanian corporate tax system.  The reason is besides any personal bias, Romania does not lack a certain “tax appeal” making it a desirable target for entrepreneurs with an appetite for emerging markets.  ... Read more...

Interesting Trends of Anti-avoidance in Thailand

By Chinapat Visuttipat, Posted: 15th September 2011 09:53
Why ‘Pizza Hut Inc.’ was deemed to receive ‘taxable income’ in Thailand? The  Supreme Court of Thailand ruled in mid 2010 on the case of withholding tax and value added tax (VAT) against Minor Food Group (MFG: a listed company in the Stock Exchange of Thailand) and Pizza Hut Inc. was deemed to receive a part of franchise ... Read more...

The Austrian Tax Authority Vigorously Focuses on Marketing Intangibles

By Imke Gerdes of Baker & McKenzie, Posted: 13th September 2011 09:52
In times of decreasing tax revenue, tax administrations seek for the means to raise the same.  Amongst others, Marketing Intangibles became a favorite source for tax administrations, as there are no clear guidelines on the scope of a Marketing Intangible and foremost, whether there even is a Marketing Intangible.  Therefore, whenever this subject arises, intensive discus ... Read more...

The LSTA Model Credit Agreement: Overview of Tax Changes

By Michael L. Schler, J. Leonard Teti II and Steven J. Lorch, Posted: 12th September 2011 09:44
Introduction The Loan Syndications and Trading Association (“LSTA”) is an organization devoted to promoting a fair and orderly corporate loan market and advancing and balancing the interests of all market participants.  On August 10, 2011, the LSTA released new tax provisions f ... Read more...

Tax in Cyprus

By Sylvia Loizides, Posted: 8th September 2011 09:48
Cyprus is very inviting indeed.  From its beautiful beaches to its treasured culture, combining a rewarding standard of leaving in tune with Cypriot hospitality, Cyprus is a dynamic place to be. But, more importantly, Cyprus is a dynamic place to invest.   At the heart of this statement lies the country’s t ... Read more...

Taxation in the Cayman Islands

By Richard Mansi of Thorp Alberga, Posted: 5th September 2011 09:47
There are several reasons why the Cayman Islands remain the leading offshore international financial centre.  Taxation is one of them. The Cayman Islands are a free market tax neutral jurisdiction.  The government of the Cayman Islands raises revenue solely via a number of indirect methods and without resorting to an ... Read more...

Recent Developments in Slovak Tax Law

By Matej Firický, Posted: 2nd September 2011 10:06
1. Modification of investment tax relief Corporate income tax relief was introduced in 2008 and since then it has become the most popular form of state aid granted by the Slovak government. However, only a certain portion of the tax base reported in the tax return could be exempt from taxation.  In other words, to calculate t ... Read more...

The Austrian Transfer Pricing Guidelines 2010; Useful or useless?

By Imke Gerdes , Posted: 1st September 2011 09:37
In October 2010, the Austrian Ministry of Finance published the first domestic transfer pricing guidelines (“TP Guidelines”), which were awaited by practitioners for a long time.  A first draft that was circulated for comments however, foreshadowed that the TP Guidelines would not be as helpful as experts had hoped for.  This article aims at giving a ... Read more...

UK corporate entities used in offshore tax structures

By Geoffrey Simpson, Posted: 30th August 2011 09:45
The UK is thought of worldwide as a high tax jurisdiction with strong tax avoidance legislation and a harsh attitude to users of offshore tax havens.  This is normally true for UK businesses and resident individuals that try to reduce their UK tax by diverting profits from UK activities into offshore structures.  However overseas companies and their owners living outside ... Read more...

Australia’s New Tax Regimes

By Gordon Grieve, Posted: 24th June 2011 15:43
Despite increasing economic uncertainty across the globe, Australia remains a land of opportunity for offshore investment particularly in the energy and resources sector.  It's important that investors are aware that the sector currently faces the prospect of new taxes at the federal level and a likely increase of royalty imposts at the state level. ... Read more...

Wealth management, tax planning and opportunities for company or trust formation in Switzerland

By Geoff Melamet and Pierre Gritti, Posted: 26th May 2011 20:05
Switzerland has become an increasingly important centre for the fiduciary industry least of all for its geographical position in the centre of Europe as well as for its established private banking and fiduciary sector.  The legislative and regulatory aspects are recognised by the administration.  Switzerland is well served by all the major banks which makes it easy to op ... Read more...

Cyprus Tax Regime Benefits for International Business

By Elias Neocleous and Philippos Aristotelous , Posted: 26th May 2011 08:18
Over the years Cyprus has developed into one of the world's leading locations for holding and finance companies.  Its myriad advantages include the transparent legal system, excellent communications and world-class professional and banking services.  The country is also an EU member state with an open market economy and no restrictions on capital movements. ... Read more...