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The Competent Authorities of Singapore and the Republic of Korea concluded an Agreement on the Automatic Exchange of Financial Account Information to Improve International Tax Compliance (Hereafter: The Agreement) based on the Common Reporting Standard (CRS).
Singapore and the Korean Republic will commence the Automatic Exchange of Information under the CRS by September 2018. The first year for which information will be exchanged under the Agreement is 2017.
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On October 13, 2016 the U.S. Department of the Treasury (Hereafter: The Treasury) and the U.S. Inland Revenue Service (Hereafter: The IRS) issued final regulations to address earnings stripping. The aim of the regulations is to further reduce the benefits of corporate tax inversions, level the playing field between U.S. and non-U.S. businesses, and limit the ability of companies to lower their tax bills through transactions involving debt that do not support new investment in the United States. According to the Treasury the regulations also require large corporations claiming interest deductions to document loans to and from their affiliates, just as businesses of all sizes do when they borrow from unrelated lenders. The rules were proposed in April along with temporary anti-inversion regulations.
Read more: U.S. Department of the Treasury issues Final Earnings Stripping Regulations
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On October 13, 2016 the Competent Authorities of Singapore and Japan concluded an Implementing Arrangement on the Automatic Exchange of Financial Account Information to Improve International Tax Compliance (Hereafter: The Agreement) based on the Common Reporting Standard (CRS).
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From October 11 through October 14, 2016 the United Nations organized the Twelfth Session of the Committee of Experts on International Cooperation in Tax Matters. According to the provisional agenda and organization of work as made available by the United Nations in this respect some interesting items were scheduled to be discussed.
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On October 12, 2016 the Japanese Ministry of Finance issued a press release announcing that on that same date the Governments of Japan and of the Kingdom of Belgium signed a Convention for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (Hereafter: the DTA).
Although the DTA has been signed, it has not entered into force yet. For the DTA to enter into force, the respective ratification procedures have to have been finalized in both countries. When entering into force the DTA will replace the Convention between Japan and the Kingdom of Belgium for the Avoidance of Double Taxation with respect to Taxes on Income which signed on March 28, 1968, as amended by the Protocol signed at Brussels on November 9, 1988 and the Protocol signed at Brussels on January 26, 2010.
Below we will discuss a selection of provisions included in the DTA of which we think they might interest our readers.
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