A taxpayer’s recent challenge to the significant delay by the tax authorities to rule on assessments has met with limited success by the High Court. The Court ruled that the Commissioner has the power to continue the issuance of protective assessments until the issue is decided but the significant delay by the Commissioner is unacceptable. Page 1

Indian Business Support Services Taxable

The AAR held that business support services will be construed as fees for technical services under the India UK double taxation avoidance agreement and the Indian Income tax Act and, therefore, will be subject to tax in India. Page 1

The ability of enterprises registered with the Philippines Economic Zone Authority to deduct royalty payments to foreign corporations when computing taxable gross income has been eliminated. New VAT regulations have been issued increasing the reporting requirements and a decision clarifying the proper party to file an excise tax refund has been issued. Page 3

Three new tax circulars address significant changes to the special sales tax, value added tax and corporate income tax and discuss how taxable income is determined and new requirements to obtain a 0% VAT rating. Page 7

VAT Reform in China

The initial pilot program in Shanghai is set to expand to other regions during 2012. The trial program divides businesses into general VAT payers, small scale VAT payers and adds two new VAT rates. Page 11