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From the overview of Competent Authority Agreements we understand that the Competent Authority Agreements that Singapore has concluded with the following jurisdictions for the Common Reporting Standard will enter into force on January 31, 2017:
· Finland;
· Iceland;
· Ireland;
· Japan;
· Malta;
· The Netherlands;
· Norway;
· South Africa; and
· The United Kingdom.
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On January 31, 2017 the Japanese Ministry of Finance issued a press release announcing that on January 30, 2017 the Government of Japan and the Government of the Republic of Austria signed a new Convention for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (Hereafter: the DTA).
Although the DTA has been signed, it has not entered into force yet. For the DTA to enter into force, the respective ratification procedures have to have been finalized in both countries. When entering into force the DTA will replace the Convention between Japan and the Republic of Austria for the Avoidance of Double Taxation with respect to Taxes on Income which was signed at Vienna on 20 December, 1961.
Below we will discuss a selection of provisions included in the DTA of which we think they might interest our readers.
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On October 20, 2016 the OECD launched the global review of Mutual Agreement Procedures (MAP) programmes by releasing key documents, approved by the Inclusive Framework on BEPS, that will form the basis of the Mutual Agreement Procedure peer review and monitoring process under Action 14 of the BEPS Action Plan. (For further information we refer to our article from October 20, 2016). The peer review and monitoring process will be conducted by the Forum on Tax Administration MAP Forum (FTA MAP FORUM), with all members participating on an equal footing.
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On January 27, 2017 the Australian Taxation Office (ATO) published a tax risk management and governance review guide. According to ATO the guide sets out principles for board-level and managerial-level responsibilities, and examples of evidence that entities can provide to demonstrate the design and operational effectiveness of their control framework for tax risk.
ATO furthermore states that the guide was developed primarily for large and complex corporations, tax consolidated groups and foreign multinational corporations conducting business in Australia. However, according to ATO the principles outlined in the guide can also be applied to a corporation of any size if tailored appropriately. When appropriate ATO assesses the tax governance processes of large business entities that it has under review.
According to ATO the aim of the guide is to help taxpayer understand what ATO believes better tax corporate governance practices look like, so that taxpayers can:
· develop or improve its own tax governance and internal control framework;
· test the robustness of the design of the taxpayer’s framework against ATO’s best practice benchmarks;
· understand how to demonstrate the operational effectiveness of the taxpayer’s key internal controls to the taxpayer’s stakeholders, including ATO.
Read more: Australian Taxation Office publishes a tax risk management and governance review guide
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On January 26, 2017 the UK Government published several pieces of draft legislation that are supposed to take effect as per April 1, 2017. The subjects of these pieces of draft legislation include a.o.:
· relief for carried-forward losses
· corporate interest restriction
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