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On January 16, 2017 the Inland Revenue Department of the Government of the Hong Kong Special Administrative Region issued a press release announcing that on that same date the Government of the Hong Kong Special Administrative Region of the People’s Republic of China and the Government of the Republic of Belarus signed an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital (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.
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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According to the overview of DTAs and TIEAs as available on website of the Liechtenstein Government the Agreement between the Government of the Italian Republic and the Government of the Principality of Liechtenstein on the Exchange of Information on Tax Matters (Hereafter: the TIEA), which was signed on February 26, 2015, entered into force on December 20, 2016.
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In earlier article we have already reported on the reasoned opinions that several parliaments submitted regarding the proposals of the European Commission for a Common Corporate Tax Base (CCTB) and for a Common Consolidated Corporate Tax Base (CCCTB). (See our articles from December 29, 2016 and January 12, 2017) On the website of the Council of the European Union also the Reasoned Opinion(s) of the UK House of Commons on the application of the principles of subsidiarity and proportionality of the proposals for a CCTB and for a CCCTB has been made available. The deadline for submitting reasoned opinions expired on January 3, 2017. The Motion of the UK House of Commons dates from January 9, 2017.
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On January 12, 2017 a working document prepared by the co-rapporteurs of the European Parliament’s Committee of Inquiry to investigate alleged contraventions and maladministration in the application of Union law in relation to money laundering, tax avoidance and tax evasion (PANA) was released. The document, which is dated December 15, 2016, was prepared by PANA’s co-rapporteurs Jeppe Kofod and Petr Ježek. The document has been prepared to outline the approach these two co-rapporteurs would like to follow during the PANA committee mandate and in view of its final report. The document aims at presenting their understanding of the subject and highlights the key issues, activities, actors and practices these co-rapporteurs feel would require thorough research.
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On January 12, 2016 the Inland Revenue Authority of Singapore (IRAS) released the fourth edition of its Transfer Pricing Guidelines. Several amendments, updates and additions have been made in comparision to the prvious (third) edition.
According to IRAS the aim of the Guidelines is to provide taxpayers with guidance on transfer pricing relating to:
(a) Applying the arm’s length principle when transacting with their related parties;
(b) Applying the arm’s length principle for specific transactions, like related party services and loans;
(c) Maintaining transfer pricing documentation; and
(d) Facilities provided under tax treaties to resolve transfer pricing disputes.
The Guidelines furthermore explain IRAS’ transfer pricing compliance programme and position regarding various transfer pricing matters.
Read more: Singapore – IRAS releases the fourth edition of its Transfer Pricing Guidelines
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