Blog
Applying or renewing Major Exporter Scheme
To date, we have performed more than 200 ASK (Assisted Self Help Kit) certification reviews for client applying or renewing for the Major Exporter Scheme (“MES”) in our capacity as Accredited Tax Advisor (GST). The common mistakes uncovered during the review are...
Voluntary or Compulsory GST registration?
If a company or limited liability partnership or sole proprietorship reasonably expect its turnover or revenue to be more than S$ 1 million in the next 12 months, then it is liable to apply for GST registration. IRAS do allow for voluntary GST registration if entities...
Transfer Pricing Documentation
A common question is, “when does transfer pricing occur.” It occurs typically when multi-national companies enter into sale and purchase transactions with their related companies, or loan to related companies. It can be also a situation, when a Singapore parent...
Cyber threats against Singapore businesses surge in 2019: CSA
The frequency and sophistication of various cyber threats such as website defacements, phishing incidents, and malware activities rose in Singapore last year, said a report published by the Cyber Security Agency (CSA) of Singapore on Friday. Read More
Transfer Pricing Regimes for Developing Countries
Comprehensive anecdotal and academic evidence reveals that multinational enterprises (MNEs) transfer income from high-tax countries to low-tax jurisdictions to reduce their corporate tax burden. Political and public debates on the topic were recently reignited by the...
“Taxation Where Value is Created” and the OECD/G20 Base Erosion and Profit Shifting Initiative
Dealing with base erosion and profit shifting presupposes that it is known what this is. The concept of value creation claims to provide an answer as to where profits should be taxed and, therefore, when the tax base is being shifted. The OECD introduced value...
Planning for Multilateral Tax Controversy in the Post-BEPS World
All multinational groups (MNEs) are, should or will be addressing their existing international tax planning structures with respect to a new world that is rapidly changing in apparently dramatic ways. The process may be supervised at the level of the board of...
The Impact of the OECD/G20 Base Erosion and Profit Shifting Project on the Task for Developing Countries of Applying the Arm’s Length Principle in Practice
The intention here is to assess the (highly practical) matter of whether the OECD’s Base Erosion and Profit Shifting (BEPS) project has helped, or alternatively hindered, the task for developing countries of applying transfer pricing rules pursuant to the arm’s length...
The Evolving World of Global Tax Planning: Part II
Part I of this three-part series addressed one of the considerations that MNEs may want to take into account when adapting their effective tax rate strategies (ETR strategies) in the evolving world of global tax planning.1 The current global tax environment,...
The Evolving World of Global Tax Planning: Part I
In the global community, the reigning paradigm seems to be political chaos. News updates in all media justifydeclare the seemingly ever-deepening divides in the world – wars in the Middle East, tension between the West and Russia, economic malaise in China,...
Country-by-Country Reporting and the International Allocation of Taxing Rights
In this article, I discuss the OECD country-by-country reporting (CbCR) requirements, the disconnect between CbCR and current tax policy, the potential benefits and costs of CbCR (including misinterpretations of the data), and what all of this might mean for the...
Increased Transfer Pricing Regulations: What about the Managerial Role of Transfer Pricing?
This article is based on a recently completed dissertation on the management accounting role of transfer pricing in an international environment. The research aims at narrowing the gap between “management accounting” and “fiscal” studies of transfer pricing. In...
Senior Tax Counsel’s Report
TRANSFER PRICING – A simple topic; some complex solutions! This week, in the spirit of The Tax Summit’s week of innovative and educational sessions, I thought I might try something a little different – a short, simple review for beginners of a complex topic. The topic...
IASB Releases Consultation on Goodwill and Impairment
The International Accounting Standards Board (IASB) is exploring how to help investors hold companies to account for acquisitions and improve the accounting for goodwill. A Discussion Paper titled Business Combinations—Disclosures, Goodwill and Impairment was released...
OECD Covid-19 Tax Treaty
On 3 April 2020, the Organisation for Economic Co-operation and Development (OECD) published on its website an OECD Secretariat Analysis of Tax Treaties and the Impact of the COVID-19 Crisis (the guidance). Governments around the globe are taking increasingly...
The “Unified” Fund Exemption Regime in Hong Kong
For over a decade, the Hong Kong SAR Government had been modifying the specific tax exemption regimes for investment funds (especially privately offered funds) with a view to attracting more funds and fund managers to establish themselves in Hong Kong. The journey...
Optimise Your Risk Identification and Management Processes by Blending External Company Information with Your Own Tax Data
Tax administrations have been facing pressure from the electorate and media to combat tax avoidance and profit shifting away from their jurisdictions. Responding to this, G20 countries through the Organisation for Economic Co-operation and Development (OECD), and the...
Overview of Tax Rules in Uzbekistan in 2019
In the sections that follow, we describe the most significant taxes in Uzbekistan. There are a number of other less significant or specific taxes, such as excise taxes and a number of taxes on “subsurface users” (i.e. oil, gas, and mining companies). It is important...
簡評台灣境外資金課稅概況暨新境外資金 匯回專法介紹
近年國際間反避稅、反洗錢、反資助恐怖主義及反貪腐呼聲高漲，各稅區政府愈加重視資訊交換，採行 如金融機構共同申報準則(Common Reporting Standard, CRS)、移轉訂價三層文檔等規定。台灣地區已通過 對法人的反避稅措施—受控外國公司(Controlled Foreign Company, CFC) 與實際管理處所(Place of Effective Management, PEM) 法令及個人CFC 條文作為配套。此外，免稅天堂經濟2019 年起陸續立法引進經濟實質新 規(Economic Substance...
The Impact of Tax-Related Incentives on Innovation: Evidence from China
In the past decade, China has astonished the world with its speedy transformation into an innovation superpower. It is of interest to understand the strategies that have been implemented by the Chinese Government to achieve the great advancements that have been made...
“BEPS 2.0” and the Future of Intra- Group Financing in Hong Kong
Under Hong Kong’s territorial tax system, only interest income that is derived from Hong Kong (or deemed as such) can generally be within the scope of Hong Kong Profits Tax. Hong Kong companies that lend overseas are in some cases not subject to Hong Kong Profits Tax...
A Critical Assessment of the Hong Kong Inland Revenue Department’s Revised Departmental Interpretation and Practice Note No. 28 on the Deductibility of Foreign Tax
As a general rule, the well-informed Hong Kong tax practitioner tends to anticipate developments in Inland Revenue Department (IRD) departmental interpretation and practice notes (DIPNs) with a sense of dread and stoic resignation. In our well-worn cynicism, we assume...
Taxation of Carried Interest – View from Hong Kong
The tax treatment of carried interest (often referred to simply as “carry”) has been a contentious issue in Hong Kong for a number of years and one which has never been comprehensively addressed by the Inland Revenue Department (IRD). In this article, we examine the...
A Review of Recent Board of Review Cases
This article will review the cases reported in the second and third supplements of Volume 33 of Board of Review Cases, which were published in April and July 2019, respectively. There are four profits tax cases, five salaries tax cases, one property tax case, one...
Budget Proposals 2019 – 20
The Hong Kong economy grew solidly in the first three quarters of 2018, with a 3.7% real GDP growth in the first three quarters of 2018 over a year earlier. Taking into account the various increasing downside risks in the external environment, the HKSAR Government...
Mauritius: An Investment Gateway to Africa for Chinese Companies
Abstract With its strategic geographic location between China and Africa and its stable regulatory environment, Mauritius looks set to strengthen its position as an investment gateway to Africa under China’s “Belt and Road” initiative. This article discusses the tax...
Rising Global Tax Controversies – A Business’s Best Plan for Managing Tax Controversies amid Greater Transparency and Scrutiny
In the current turbulent tax landscape, a good way for a business to stay ahead of controversy is to adopt a global perspective everywhere it operates while establishing a global tax controversy strategy that is integrated with a strong tax risk and corporate...
Tax Litigation and the System of Appeal in Pakistan
This article provides a critical analysis of the level of tax litigation and the appeal system in Pakistan. The author triggers a debate on the possible reasons for the increased tax litigation and the excessive pendency of tax appeal cases, especially in the high...
Managing China Customs and Trade in the Era of a New Global Trade Order and Industry 4.0
Global trade has attracted a lot of attention lately though regrettably most of the headlines are negative. The current global trade environment is arguably the most complex in modern history and protectionist sentiment is on the rise (e.g. the US-China trade dispute,...
The Uneasy Relationship between Permanent Establishments and Section 14 of the Inland Revenue Ordinance
I have previously written in this journal that all tax was, at its origin, territorial and that even residence-based systems of taxation have not thereby ceased to be territorial, but rather have merely expanded the nexus of territoriality to focus on the attributes...
Cost of Information and Life under the New Transfer Pricing Regime
Multinational enterprises (MNEs) ordinarily operate in a vertically integrated manner, but each 'profit centre' optimises its own profits. Transfer pricing (“TP”) policy is at the heart of this phenomenon as it determines how MNEs’ profits should be optimised in such...
New Tax Deduction of Three Additional Types of Intellectual Property Rights Reignites the Controversies Surrounding Sections 16EC(4)(b) and 39E(1)(b)(i) of the Inland Revenue Ordinance
Three New Types of Specified Intellectual Property Rights Now Eligible for Tax Deductions The Inland Revenue (Amendment) (No. 5) Ordinance 2018 has recently been enacted to grant tax deductions for three new types of specified intellectual property rights (“IPRs”),...
A Review of Recent Board of Review Decisions
This article reviews the cases published in Volume 33 of the Inland Revenue Board of Review Decisions and its First Supplement. There are five cases on salaries tax and personal assessment, four cases concerning profits tax, and three penalty tax cases. All the...
Be Cool and Clear on the CPF Act
The Central Provident Fund (CPF) Board has stepped up enforcement inspections on employers in recent years. Nearly S$2.7 billion in CPF arrears were recovered from employers within a five-year period from 2014 to 2018, whether through desktop audits, on-site audits or...
Tax Arrests And More
Promoting Tax Excellence by SIATPPage | 1Since the commencement of the Income Tax (Amendment) Act 2018and the Goods and Services Tax (Amendment) Act 2018on 12 November 2018 and 1 January 2019 respectively, the power of the Inland Revenue Authority of Singapore (IRAS)...
Impact of COVID19 on BV – Global perspectives
The iiBV, in collaboration with the International Valuation Standards Council, (IVSC), Institute of Valuers and Appraisers, Singapore (IVAS), Duff & Phelps, and Leadenhall is pleased to present “Impacts of COVID 19 on Business Valuations - Perspectives from...