May 2018
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Sponsored by Russell McVeaghThe New Zealand Court of Appeal has overturned a High Court decision allowing a New Zealand taxpayer foreign tax credits for tax spared (under Chinese law) to Chinese companies treated as controlled foreign companies under New Zealand's CFC rules.
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Sponsored by Deloitte SwitzerlandOn March 21 2018, the Swiss Federal Council sent to the Swiss Parliament the dispatch on the draft legislation for the so-called Swiss Tax Reform Proposal 17.
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Sponsored by KPMG ChinaAgainst a backdrop of continuing China-US trade tensions, Chinese President Xi Jinping on April 10, at the Bo'ao Forum for Asia, announced a 'four-point plan' for the further liberalisation of rules governing foreign investment in, and trade with, China.
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Sponsored by KPMG ChinaThe long awaited Announcement 9 has been released by the State Administration of Taxation of China (SAT). Effective from April 1 2018, Announcement 9 replaces Circular 601 and Announcement 30, both of which are key circulars setting out the rules for foreign investors claiming tax treaty benefits on their Chinese-sourced dividends, interest and royalties (passive income).
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Sponsored by Fenwick & WestThe Tax Cuts and Jobs Act (2017 Act) overturned Grecian Magnesite v Commissioner, which held that the sale by a foreign person of its interest in a partnership engaged in a US trade or business was not subject to US tax.
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Sponsored by Dhruva AdvisorsIndian law provides that the dividends paid by domestic companies to their shareholders are liable to a dividend distribution tax at the company level. As a corollary, such dividends are exempt in the hands of shareholders, subject to certain exclusions.