Permanent establishment: a tax concept that every business executive should appreciate
The concept of permanent establishment (PE) is arguably one of the most important issues in treaty-based international tax law25/08/2020
Preparation – the key to mitigating post-Covid-19 tax controversy
Governments around the world responded the economic consequences from quarantines and lockdowns from the COVID-19 pandemic by offering support and then stimulus17/08/2020
Asian family enterprises – beyond three generations
It is often cited that 70% of wealthy families typically lose their wealth by the second generation16/06/2020
A trusted tax advisor
I have been practicing tax for more than 35 years11/06/2020
International – the importance of regular evaluation of transfer pricing policies
Over the last couple of years, the number of specific transfer pricing audits has risen sharply across the globe20/04/2020
Increased tax transparency and tax authority cooperation fuels tax controversy momentum in the Asia-Pacific region
The Organisation of Economic Co-Operation and Development (OECD)’s Base Erosion and Profit Shifting (BEPS) project has provided fuel for tax authorities in the Asia-Pacific (APAC) region. With increased tax transparency and tax authority cooperation, tax authorities continue their momentum for...30/03/2020
Important issues for HNWIs in a dynamic global environment
The flow of private capital across borders, together with the ease of living and working in different countries, creates opportunities for High Net Worth Individuals (HNWIs)20/08/2019
How the Singapore transfer pricing landscape has evolved over a decade
The recent “10 year challenge” that went viral on social media saw people comparing photos of themselves in 2009 to those taken in 201906/08/2019
Draft profit attribution rules by India – Emergence of new controversy or end of it?
The concept of Permanent Establishment has as much history as the history of double tax conventions itself.06/08/2019
Recent Judicial Pronouncements on controversies around India-Mauritius Treaty
In the past, there has been a lot of litigation in India on whether the Mauritius treaty benefit is available investors from different countries (generally United States, United Kingdom, etc.)31/07/2018
Tax controversy in a connected world
Organizations need a global perspective and policies that cover all jurisdictions in which they do business31/07/2018
Transfer pricing updates: a Southeast Asia perspective
Southeast Asia is a diverse region with a global merchandise share of US$2.2t , of which the largest contributor is intra-Southeast Asia trade, at around 24%.08/05/2018
Intra-Group Services And Their Effects In Colombia
In Colombia transfer pricing rules date back to the year 2002 when by means of the Law 788 of that year, articles from 260 to 260-11 were added to the Tax Code (TC)19/07/2017
BEPS Action 13 impact on a non-OECD/G20 jurisdiction
This article intends to give a perspective of the challenges that MNEs may confront when dealing with non-standard documentation, based on the first year experience of the Action 13 implementation in one of the non-OECD/G20 countries.17/07/2017
Hong Kong enacted new law to attract corporate treasury operations
On 3 June 2016, the HKSAR Government gazetted the Inland Revenue (Amendment) (No. 2) Ordinance 2016 (the new law) that sought to attract multinational and mainland China enterprises to establish corporate treasury centres (CTCs) in Hong Kong by amending the Hong Kong Inland Revenue Ordinance (IRO)03/08/2016
France and BEPS: a changing transfer pricing landscape
The operative, but not exclusive, article of law in France that currently governs transfer pricing is Article 57 of the French Tax Code ("FTC"), entitling French Tax Authorities ("FTA") to reassess related transactions whose conditions deviate from what independent parties would have agreed under...
30/09/2015
Regulation, transparency, and the coming IT revolution in Tax
Background
The global tax environment is rapidly changing. Tax strategies, which have been legal and common for many years, are increasingly regarded as unacceptable. The public perception that corporates artificially shift earnings to low tax jurisdictions and default on their "social contract" has...
30/09/2015
Keeping up to pace with transfer pricing developments in Asian countries
Recent international tax developments in Asia reflect the growing focus on transfer pricing, in tandem with global developments. This summary highlights recent key transfer pricing policy announcements in the region and discusses the potential local impact of country-by-country reporting (CBCR)...
30/09/2015
Tax valuation of IPs in post-deal reorganisation
As part of Base Erosion and Profit Shifting Project (BEPS), OECD has recently issued a publication on transfer pricing aspects of intangibles. The topic of the publication is important, as during the past decades many countries have witnessed a shift from the capital intensive economy to the economy...
31/03/2015
Hong Kong braces itself for a heightened level of transparency
On 25 March 2014, Hong Kong signed a standalone tax information exchange agreement (TIEA) with the US for the enforcement and assessment of taxes. This is the first TIEA signed by Hong Kong after the legal framework for entering into TIEAs with other jurisdictions was put in place last July.
The...
01/09/2014
Aspects of transfer pricing in the Netherlands
The Dutch approach to the arm's length principle has always kept pace with the evolving international interpretation, and arguably in certain aspects has even been ahead of its time. The OECD guidance around alignment between the actual controlling of risks with the contractual division of risks, as...
01/09/2013
ASEAN transfer pricing developments
It has been more than seven years since the Inland Revenue Authority of Singapore (IRAS) released the Singapore Transfer Pricing Guidelines (Guidelines). The key developments in recent times are an increase in the focus of the IRAS on transfer pricing compliance and the use of Advance Pricing...
01/09/2013
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