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South Korea: How to determine permanent establishment in South Korea

Mee-Hyon Lee and Young-uk Park of Lee & Ko examine the definition and determining factors of a PE, and the resulting tax effects as it is interpreted and applied in Korea.

August 29 2011
FREE: Rolls Royce does have PE, Delhi court rules

The Delhi High Court has ruled that Rolls Royce’s operations in India created a permanent establishment and so is liable to tax.

August 29 2011
Record profits could increase tax burden for Australian miners

BHP Billiton has posted an Australian record for annual earnings of A$22.5 billion ($23.6 billion), almost doubling profits for the second consecutive year. This further evidence of the mining boom has led to Australians calling on the government to make taxation on the sector more severe.

Matthew Gilleard, August 29 2011
China: Taxpayers urged to conduct appraisals when transferring equity interests

Taxpayers in China transferring equity interests in Chinese companies are being advised to conduct appraisals to determine the fair market value of the transferred interest.

Jack Grocott, August 29 2011
China eliminates double tax on restricted stock transfers By Jack Grocott

China's State Administration of Taxation has issued guidelines to reduce the risk of double taxation of gains where businesses transfer restricted stocks that they hold on behalf of other businesses.

Jack Grocott, August 29 2011
Thailand: How tax affects reorganisation in Thailand

Chinapat Visuttipat, of HNP Counsel – Taxand, looks at the tax consequences of business reorganisation.

August 29 2011
China issues warning about Barbados holding companies By Jack Grocott

The SAT is targeting the use of intermediate Barbados holding companies China has warned against the use of intermediate Barbados holding companies by foreign companies looking to invest in China.

Jack Grocott, August 29 2011
Treaties of the week - August 30 2011

Type of Agreement Country Country Date Signed Double taxation avoidance agreement India Georgia August 24 2011

August 29 2011
Intangible assets valuation and high uncertainty

In the eighth in a series of 10 articles on tax-effective intellectual property management, Emmanuel Llinares, Lionel Ochs and Vladimir Starkov of NERA provide an example of mitigating the risks of intra-group sales of intangibles when there is uncertainty about the asset being transferred.

August 29 2011
OECD’s new head of transfer pricing named

Caroline Silberztein’s replacement as head of the OECD’s Transfer Pricing unit has been named as Joseph Andrus.

August 29 2011

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