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Issue No. 2 - 2015 of the Asia-Pacific Tax Bulletin is now available online.

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Number 2 - 2015 contains the following:
ARTICLES
Australia
Partnerships – Are We There Yet?
John Walker
This article is based on a paper presented at the Baker & McKenzie 30th Annual Asia-Pacific Tax Conference held in Hong Kong from 13-14 November 2014. The 31st Annual Asia-Pacific Tax Conference is to be held in Singapore in November 2015.
New Caledonia
Decentralization of the Tax Legislation Process in New Caledonia – Originality, Impact and Limitations
Guillaume P. Blanc
This article looks at the unique constitutional status and extensive tax legislative powers of New Caledonia. It analyses the specific constitutional and institutional status of New Caledonia to show the effect of the decentralization process on the capacity of New Caledonian authorities to implement economic development reforms through tax legislation, such as the introduction of tax incentives for foreign direct investment.
Taiwan
Partnerships
Yishian Lin
The author analyses the taxation of partnerships in Taiwan and their suitability as inbound investment structures by foreign investors. The proposed introduction of limited liability partnerships and the potential impact is also discussed.
INDIAN CASE LAW MONITOR
The Limited Force of Attraction Rule
Dr Amar Mehta
The author, in this article, provides an analysis of the limited force of attraction rules of article 7(1) of the UN Model Convention and the Indian case law on the matter.
TRANSFER PRICING
Singapore
Issuance of the 2015 Singapore Transfer Pricing Guidelines
Luis Coronado, Henry Syrett and Viknesh Danabalan
This article is a continuation of the previous article in IBFD’s Asia-Pacific Tax Bulletin dated November/December 2014 (Volume 20, Number 6, 2014), wherein the authors provided comments with regard to the key differences between the IRAS consultation paper on the transfer pricing guidelines and the final OECD report on Action 13. The revised guidelines were released by IRAS on 6 January 2015, and this article summarizes again the main similarities and differences between the key compliance issues in Section D of the final OECD report on Action 13 and the 2015 Singapore Transfer Pricing Guidelines.
COMPARATIVE SURVEY
The comparative survey articles are based on selected papers presented at the Baker & McKenzie 30th Annual Asia-Pacific Tax Conference held in Hong Kong from 13-14 November 2014. The 31st Annual Asia-Pacific Tax Conference is to be held in Singapore in November 2015.
Australia
The Cloud, E-Commerce and Taxable Presence
John Walker and Tom Roth

 

Japan
The Cloud, E-Commerce and Taxable Presence
Ryutaro Oka

 

Korea (Rep.)
The Cloud, E-Commerce and Taxable Presence
Kyu-Dong Kim

 

Singapore
The Cloud, E-Commerce and Taxable Presence
Allen Tan, Lee Shih Hui and Tiffany Toh

 

Hong Kong
Loss Utilization
Alex Yang

 

Japan
Loss Utilization
Ryutaro Oka

 

Malaysia
Loss Utilization
Adeline Wong and Tan Yi Lyn

 

Philippines
Loss Utilization
Ronald Bernas

 

Singapore
Loss Utilization
Lee Shih Hui

 

Vietnam
Loss Utilization
Thanh Vinh Hguyen

 

INTERNATIONAL PERSPECTIVE ON ASIA-PACIFIC TAXATION AND INVESTMENT
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