Cross-border Merger Taxation in Japan

Shimon Takagi, White & Case LLP, Tokyo The following article looks at cross-border merger taxation in Japan, focusing on qualified triangular mergers which were introduced in Japan in 2007. I. Introduction As the world economy has become more integrated, global M&A has become an important strategic option for multinational corporations. Japan introduced qualified triangular mergers, [...]

Switzerland, Ireland Sign Revised Double Taxation Treaty

GENEVA — Switzerland and Ireland have signed a revised double taxation treaty enhancing cross-border information exchange in tax investigations. In a statement, the Swiss Federal Department of Finance said the accord, signed in Dublin Jan. 26, is based on international information exchange provisions set out by the Organization for Economic Cooperation and Development. Switzerland has [...]

Shanghai VAT pilot: Clarification of zero rate/exemption for services provided to overseas entities

Sarah Chin, Gao Li Qun and Candy Tang, Deloitte, Shanghai I. Introduction China’s Ministry of Finance (MOF) and the State Administration of Taxation (SAT) jointly issued widely anticipated guidance on December 29, 2011 that clarifies the scope of taxable services eligible for the zero rate or exemption under the VAT reform pilot program in Shanghai [...]

France and Luxembourg Cut VAT On E-books, Breaking Away From EU Policy

Rick Mitchell  PARIS — France and Luxembourg implemented measures Jan. 1 that slash valued-added tax rates applying to electronic book sales, becoming the first European Union member countries to challenge EU policy that allows traditional printed books and audio books, but not e-books, to benefit from so-called preferential VAT rates. On the first of this [...]

Australia: Update on GST and grants

Stephen O’Flynn and Andrew Cromb, Moore Stephens, Melbourne On November 2, 2011 the Australian Taxation Office released Draft GST Ruling GSTR 2011/D4: Grants of Financial Assistance (the “Draft Ruling”). The draft ruling represents a substantial rewrite of an earlier ruling on the same topic, GSTR 2000/11 (the “Old Ruling”), and follows numerous court decisions which [...]