Search results for

A monthly commentary on the notable facts, figures and goings-on in the tax world.

Thuan Pham Vietnam is a country with a high volume of imports and exports, many of which are transported by sea. For this reason, most of the leading international shipping lines have been present in Vietnam for years via shipping agencies, forwarding agents and other commercial representatives. Vietnam's income tax regulations impose tax on foreign carriers for outbound transactions only. In addition, most of Vietnam's double taxation agreements (DTAs) have a clause on international traffic that gives the right to tax to the home country where the carrier is a resident. Given this, it seems that most foreign carriers should be exempt from tax in Vietnam on the income generated from international ocean traffic. However, the complexity of international transportation activities and a cumbersome process to apply for DTA exemption discourage many taxpayers from taking advantage of this benefit. There is often a long waiting period while the tax authority assesses the dossiers and comes to a final decision regarding DTA exemption. Now, in an effort to simplify the DTA notification process and assist taxpayers (ocean carriers) with tax treaty benefits, the Ministry of Finance (MOF) has drafted an official ruling for collection of opinions from experts.

Brendan Kelly and Jinghua Liu, of Baker & McKenzie, explain how the issuance of Notice 698 in China has impacted tax planning for global operations and the way deals must be structured and negotiated

Tax litigation and controversy specialist Steven Dixon has been elected as a new member in Miller & Chevalier's Washington, DC office.

Recent headlines might lead you to think that the only thing that interests multinational business is dodging taxes, and the only thing that interests governments is maximising the tax yield. The perception that low and middle income individuals are facing increasing taxes at a time when big multinationals are not contributing their fair share has become a political problem now identified by the G20.

Kevin Cummings has joined BDO to develop the firm's banking, capital markets and asset management tax capabilities in the UK.

A senior technical reviewer in the Internal Revenue Service's (IRS) transfer pricing branch has joined Mayer Brown's tax controversy practice in Washington, DC. Jason Osborn will represent taxpayers in transfer pricing controversies and advise on transfer pricing planning and the negotiation of advance pricing agreements (APA) with the IRS and foreign tax authorities.

The newly approved law Nº 20.630 has brought about several reforms of the Chilean tax legislation, raising, for example, the corporate tax rate to 20%, assimilating the cost of the limited liability companies’ (LLC) capital interests with that of the corporations’ stocks, unifying the taxation of the non-deductible expenses, and, including, as a great novelty, a new article 41E to the Income Tax Law, containing the new Chilean regulation on transfer pricing. Marcelo Muñoz Perdiguero, of Salcedo y Cia, explores the new measures.

Andrew Sliwa, Hadley Leach and William Methenitis of Ernst & Young in the US look at the problems associated with cross border effectiveness, provide hypothetical examples of how the issue can impact your tax department and explain how to apply the theory to the realities of business.

On December 26 2012, the Cambodian government passed the 2013 Financial Management Law which updated the registration tax (sometimes referred to as a seal tax). In some instances the scope of the tax was modified and in others completely new categories of "transfers" that will also be subject to the tax were created.