China: Business tax phases out, service tax changes

Dr. Bernd-Uwe Stucken and Yun Wei, Salans, Shanghai Unlike other countries, China adopts both business tax (“BT”) and value added tax (“VAT”) in its turnover tax system. While the VAT system mainly applies to the sale of goods, BT is primarily levied on taxable services. The difference in tax systems causes some industries to be [...]

Taxation of German Rental Income Earned by Nonresidents

Michael Birk, Ebner Stolz Mönning Bachem, Germany In this article, the author critically outlines and describes the Public Ruling of the German Federal Ministry of Finance on rental income from real estate which is subject to non-resident taxation, according to section 49 para 1 no 2 lit (f) German Income Tax Act. The Decree was [...]

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 [...]

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