Transfer pricing is recurring issue at Asia forum
01 June 2012
The 2012 International Tax Review Asia Tax Forum, held in Singapore, once again attracted scores of tax professionals from throughout the Asia-Pacific region and beyond. While transfer pricing was high on the agenda, it was not the only concern and other panels included: keeping in step with Chinese rules changes; establishing trust between officials and taxpayers; dealing with developing tax systems; the Indian reform; cross-border issues; dispute resolution; improving effectiveness in the tax department through technology; and indirect tax.
|Taxpayers investing into Asia are often torn between Hong Kong and Singapore
Amit Gupta, Asia Pacific and Japan tax director of Dell, and Bill
Thomson, Asia Pacific tax director of TimeWarner discussed the
implications of the Indian Supreme Court's decision in Vodafone,
in which the authorities were told they must look at foreign investment
transactions as a whole and not look-through or dissect them into
elements and the form of a transaction can only be disregarded if it is a
sham or carried out for tax-avoidance reasons.
When dealing with circular 698, which sets out the rules for indirect
share transfers in China, the panellists, which also included Eric
Roose, a partner of Morrison & Foerster in Tokyo, Michael Velten,
head of Asia tax for CLSA in Hong Kong, and Pieter de Ridder, a partner
of Loyens & Loeff in Singapore, told delegates they should consider
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