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LETTER FROM THE EDITOR
p. 64
ARTICLES
Australia
Profit Shifting and the ATO’s Approach to Risk Profiling
Michael Jenkins
pp. 65-69
The author outlines profit shifting through transfer pricing as one of the major areas of focus of the tax authority. An analysis of the tax authority’s risk identification and assessment activities are also discussed.
Addendum - Non-Resident Capital Gains Tax To Be Abolished
Paul Korganow, Rose Li and Lawrence Wong
p. 70
The Australian government introduced a number of changes to the tax laws amending the Australian international taxation regime with a view to make Australia more attractive for international investment. This Addendum discusses amendments to the draft Bill that was the subject of an article previously published in the Asia-Pacific Tax Bulletin.
Hong Kong
A Commentary on Hong Kong’s Tax Treaties
Alfred K.K. Chan
pp. 71-79
In recent times, Hong Kong has concluded three comprehensive tax treaties and is in the process of negotiating similar treaties with a number of other countries. The author, after discussing basic international tax concepts and principles, examines the impact of the tax treaty with China and makes a number of recommendations.
Malaysia
Structuring an Appropriate Transfer Pricing Policy
S.M. Thanneermalai, Jagdev Singh and Anushia Soosaipillai
pp. 80-86
Malaysia introduced transfer pricing guidelines in 2003 and the number of transfer pricing audits conducted since has been on the rise. This article outlines the recent developments in this area and highlights the salient features of a sound transfer pricing policy.
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New Zealand
The Taxation Issues Involved with Adopting IFRS
Adrian Sawyer and Andrew Smith
pp. 87-94
New Zealand adopted IFRS in 2002 with effect for accounting periods commencing on or after 1 January 2007 (with early adoption from 1 January 2005 permitted). While there is no comprehensive link between financial reporting requirements and the determination of taxable income for income purposes in New Zealand, a surprising number of tax consequences flow from the decision, necessitating a response from government officials. In this article, the authors review the officials’ Issues Paper, and the implications this is likely to have for New Zealand reporting entities required to use IFRS.
Singapore
Casenote - Deductibility of Loan and Related Expenses
Sundareswara Sharma
pp. 95-98
The Court of Appeal’s decision, dismissing the tax authority’s appeal, on the deductibility of borrowing expenses, guarantee payments and prepayment penalties is discussed.
South Korea
Recent Amendments to the Transfer Pricing Rules and Their Implications
Yoon Oh
pp. 99-106
This article outlines the recent changes to the transfer pricing rules and highlights the implications of the changes.
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