Liao Tizhong is deputy director general of international taxation in the State Administration of Taxation (SAT) of the People’s Republic of China. He speaks to TPWeek, in a two-part interview, about China's audit focus, the country's taxation of the indirect transfer of equity shares, OECD's BEPS project and challenges to China's international tax administration.
Liao Tizhong, deputy director general of international taxation in the State Administration of Taxation (SAT) of the People’s Republic of China, has emphasised the government’s commitment to developing its transfer pricing system in an interview with TPWeek, including setting-up a separate division for the administration of offshore income.
Liao Tizhong is deputy director general of international taxation in the State Administration of Taxation (SAT) of the People’s Republic of China. He speaks to TPWeek, in two parts, about China’s stance on international taxation and what multinational taxpayers can expect from SAT in the coming years.
The head of Vietnam’s transfer pricing department, within the General Department of Taxation (DGT), speaks to TPWeek about developments in the country’s legislation including the status of advance pricing agreements (APA), thin capitalisation and permanent establishment (PE) guidance and the potential for safe harbours.
The Internal Revenue Service (IRS) is inviting public comment on the development of bilateral safe harbours with US treaty partners, giving taxpayers and foreign competent authorities the opportunity to influence a safe harbour programme applicable to a large number of cross border transactions. But taxpayers and advisers have said there could still be disadvantages for multinationals.
Multinational companies are more concerned about the image their tax affairs portray to the public than ever before but, with tax departments operating in a number of different countries, with various tax managers responsible for managing that jurisdiction’s tax affairs, how can a company stay on top of its tax affairs and judge the structures that may be acceptable in one country but cause problems in another?
