IN THIS ISSUE:
Permanent Establishment in Japan
Japan’s NTA confirmed that Overseas Investors who make use of the co-location services of the Tokyo Stock Exchange will not be considered to have a permanent establishment in Japan by reason of such Overseas Investors’ use of such services. Page 1Transfer Pricing and Services
The increasing number and variety of Chinese cross-border intercompany services has caused tax authorities to increase their focus on transfer pricing issues related to services. Inconsistent treatment by different tax authorities continues to be problematic. Page 1
China Update
China clarifies the application of the business tax to international communication services. Further guidance issued on the ability of nonresidents to claim tax treaty benefits. Page 3
Property Value Escalation In China
The recent significant escalation in the value of real property in China may result in the enactment of a property tax. Officials are becoming increasingly concerned over income disparity resulting in adverse implications for high earners. Page 5
Snapshot
Singapore and New Zealand DTA comes into effect. Page 9
Philippines Update
The BIR is increasing audit scrutiny of large high risk taxpayers, 80% of such taxpayers have reported lower income in 2009 than the previous tax year. Tax collections overall have exceeded the goal for 5 consecutive months. Page 10
