Issue No. 2 - 2016  
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70th Congress of the International Fiscal Association
25-30 September 2016,


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Principles of Transfer Pricing
5-9 September 2016
Kuala Lumpur

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Number 2 - 2016 contains the following:
Important International Tax Developments – Foreign Capital Gains Withholding Tax, and Anti-Google, Netflix and Amazon Taxes
Michael Butler, Alicia Jennison and Ria Neilson
Australia has recently introduced, or will soon introduce, important legislation with significant implications for foreigners who invest in Australian real estate (both residential and agricultural) or sell goods or services to Australian consumers. The article takes a close and practical look at the impact of some of these key developments on international transactions and the foreign parties.
The New Asian Tigers: Tax Update on the Mekong Region
Jack Sheehan, Clint O’Connell, Bernard Cobarrubias and Emvalee Chiarapurk
The five countries of the Mekong region, namely Cambodia, Laos, Myanmar, Thailand and Vietnam, are part of an important growth area in ASEAN. While tax administrations in other parts of the world are grappling with issues of tax avoidance amid increasing scrutiny of international tax structures, the tax policies of the Mekong region countries are geared towards more effective tax management while at the same time keeping tax rates competitive to attract foreign investment. Mekong region tax authorities are also continuously enhancing tax collection measures, and there is an increased focus on transfer pricing in some countries. This article presents a brief analysis of some recent and significant tax changes in the Mekong region countries.
Equalization Levy Proposal in Indian Finance Bill 2016: Is It Legitimate Tax Policy or an Attempt of Treaty Dodging?
Dr Amar Mehta
This article provides an analysis of the recently introduced equalization levy on online advertisements in India. The question is whether this levy is compatible with the Indian tax treaties. The issue is of particular interest for non-resident enterprises and academics.
Importance of Human Involvement for Income Characterization as Fees for Technical Services
Dr Amar Mehta
This article provides an analysis of the Indian case law on services rendered abroad by non-resident service providers to Indian customers. The question is whether such service providers are taxable in India even if no human involvement in India is required. The issue is of particular interest for non-resident enterprises, law firms and academics.
Minimum Alternate Tax and the Indian Tax Treaties
Dr Amar Mehta
B This article provides an analysis of the Indian case law on the minimum alternate tax provisions under the Indian Income Tax Act 1961. The question is whether article 7 of the Indian tax treaties precludes this tax. A recent decision of the Income Tax Appellate Tribunal of Delhi confirms that it does so. The issue is of particular interest for non-resident enterprises, law firms and academics.
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