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New On The Network Today
This feed is published daily with selected new or updated
content from across our network. For a list of network sites, many of
which feature daily news, see below. |
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| 09/09 New
Lowtax Editor Column, by Kitty Miv |
| 08/09 New
PBTG Editor Column, Caroline, PBTG editor |
| 07/09
Flaws Uncovered In UK PAYE Tax System, Tax-News.com |
| 06/09
German Cabinet Agrees 'Future Package', Tax-News.com |
| 03/09
South Africa Rejects Mining Tax, Tax-News.com |
| 02/09 New
Lowtax Editor Column, by Kitty Miv |
| 01/09 New
PBTG Editor Column, Caroline, PBTG editor |
| 01/09 International
Privacy and Security, Investors Offshore special feature |
| 31/08
Lowtax Belize, annual update |
| 27/08
IRS To Drop UBS Lawsuit, Tax-News.com |
| 26/08 New
Lowtax Editor Column, by Kitty Miv |
| 25/08 New
PBTG Editor Column, Caroline, PBTG editor |
| 24/08
Uruguay Stays On OECD Grey List, Tax-News.com |
| 23/08 Don't
Forget Doha, And I Don't Mean The Tennis, Jeremy Hetherington-Gore
blog entry |
| 20/08
Ireland Plans Social Security Overhaul, Tax-News.com |
| 19/08 New
Lowtax Editor Column, by Kitty Miv |
| 18/08 New
PBTG Editor Column, Caroline, PBTG editor |
| 17/06
Lowtax Cayman Islands, annual update |
| 16/08
Germany's Fiscal Court Seeks Property Tax Reform, Tax-News.com |
| 13/08 Jurisdiction
Special Focus: Antigua and Barbuda, Investors Offshore special feature |
| 12/08 New
Lowtax Editor Column, by Kitty Miv |
| 11/08 New
PBTG Editor Column, Caroline, PBTG editor |
| 10/08 Brazil
Cuts Import Tariffs, Tax-News.com |
| 09/08 Ukraine
Tax Code Published, Tax-News.com |
| 06/08
France Plans Reform Of Property Tax Credit, Tax-News.com |
| 04/08 New
PBTG Editor Column, Caroline, PBTG editor |
| 02/08 Islamic
Finance - The New Mainstream Alternative, Investors Offshore special
feature |
| 28/07 New
PBTG Editor Column, Caroline, PBTG editor |
| 27/07 UK
Launches Raft Of Tax Consultations, Tax-News.com |
| 26/07 Fat
Tax On The Menu , Jeremy Hetherington-Gore blog entry |
| 23/07 Sarkozy
Seeks 'Fiscal Convergence' With Germany, Tax-News.com |
| 20/07 Singapore
Base For Tuvalu OIFC, Tax-News.com |
| 15/07 St
Vincent & The Grenadines, Investors Offshore special feature |
13/07 Tax-
News.com Jersey Review 2010-2011 |
| 12/07 Goodbye
To All That, Jeremy Hetherington-Gore blog entry |
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06/07 Hong
Kong Full PBTG Guide, added to Personal Business Tax Guide |
| 28/06
Lowtax Dubai, annual update |
| 18/06 Singapore
- Another Hong Kong?, Investors Offshore special feature |
| 15/06 Swiss
Parliament Approves UBS Agreement, Tax-News.com |
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08/06 Dubai
Full PBTG Guide, added to Personal Business Tax Guide |
| 04/06
Lowtax Panama, annual update |
| 01/06
Lowtax Luxembourg, annual update |
| 03/03
Personal Business
Tax Guide, PBTG, has launched! |
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| Providing essential tax news and information for globally
mobile artists, contractors, entrepreneurs, professionals, small businesses,
sportspersons and entertainers. |
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| Lowtax Network Sites |
| Lowtax Network Portal:
'Low-tax' business and investment in the top 50 jurisdictions covered in
exceptional detail. |
| Tax News: Global
tax news, continuously updated through the day. |
| Investors Offshore:
The independent offshore and alternative investment guide for expatriates
and the globally aware investor. Sponsored by HSBC
Bank International. |
| Law & Tax
News: Daily news and background data on tax and legal developments
for international business. |
| Offshore-e-com:
A topical guide to offshore e-commerce focused on tax and regulation. |
| Lowtax Library:
One of the web's largest and most authoritative business and investment
information sources. |
| US Tax Network:
The resource for free online US taxation information, covering: corporate
tax, individual tax, international tax, expatriates, sales and e-commerce
tax, investment tax. |
| NEW! Personal
Business Tax Guide: Providing essential tax news and information
on business for contractors, entrepreneurs, professionals, small businesses,
artists, sportspersons and entertainers. |
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| Hong Kong Inland Revenue Issues Note On Transfer Pricing Practice |
by Mary Swire, Tax-News.com, Hong Kong
Tuesday, December 08, 2009
Hong Kong's Inland Revenue Department (IRD) has issued Departmental Interpretation and Practice Notes
No. 46 (DIPN 46) entitled "Transfer Pricing Guidelines – Methodologies and Related Issues."
DIPN 46 also refers to the previous DIPN 45 which deals with double taxation relief of transfer pricing adjustments. Hong Kong has so far concluded five Double Taxation Agreements (DTAs) with Belgium, Thailand, Mainland China, Luxembourg and Vietnam. They all mandate the adoption of the arm’s length principle for pricing transactions between associated enterprises. It is expected that future DTAs will contain similar provisions.
The purpose of DIPN 46 is to illustrate how the IRD would apply transfer pricing principles; and to indicate how the IRD would seek to apply transfer principles to resolve disputes involving transfer pricing issues.
DIPN 46 further explains the Organization for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines in the Hong Kong context, in particular the way the OECD transfer pricing methodologies would be applied in Hong Kong under the Inland Revenue Ordinance (IRO).
DIPN 46 makes it clear that IRD would seek to apply the principles in the OECD Transfer Pricing Guidelines, except where they are incompatible with the express provisions of the IRO.
DIPN 46 illustrates that the provisions in the IRO and the relevant articles in the DTAs should allow the IRD to reallocate profits or adjust deductions by substituting an arm's length consideration.
This comprehensive report in our Intelligence Report series
examines the global and national landscapes in which companies can use transfer
pricing to improve their after-tax returns, including summaries of recent
developments in design of the corporate supply train, the usefulness of 'offshore'
in international corporate tax planning, and a section covering the spread of
DTAAs and CFC laws. It is available in the Lowtax Library at http://www.lowtaxlibrary.com/asp/subs_reports.asp
and a description of the report can be seen at
http://www.lowtaxlibrary.com/asp/description_report16.asp
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| THE LOWTAX LIBRARY
One of the web's largest and
most authoritative business and investment information sources. Alongside
topical, daily news on worldwide
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Our 16 constantly updated
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tax-planning in depth, including banking secrecy, the EU's savings tax
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Reports are available for immediate downloading or as subscription
services with news pages.
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