I have been meaning to write about this for the past week. But work and other distractions have intervened. I have just received a copy of the January 4 edition of Tax Notes International. In it is an excellent article contrasting worldwide taxation v territorial taxation entitled ‘Perspectives on the Worldwide v Territorial Taxation Debate’. [...]
For those readers based in Beijing I wanted to remind you about a M&A forum that will be held in Beijing tomorrow morning. As I noted previously, I will be one of the speakers at the forum and will focus my discussion on the tax issues involved in M&A transactions. The other speakers will concentrate [...]
Yesterday, I mentioned that the SAT has issued a new circular (Guoshuifa [2010] 18) with respect to the taxation of representative offices. I have been reviewing this circular this morning and there is a lot of interesting detail in it. I will post more generally on the circular but for now I want to concentrate [...]
Okay as I mentioned, here is my analysis of Guoshuifa [2010] 18. This actually represents my second nostradamus moment during the existence of China Tax Insights. Once again, for those who had paid attention to the tax landscape in China it was not completely surprising. For the last few months I have, on several occasions, [...]
As my last post indicated, I have been on a slight hiatus for the past two to three weeks. I am now back at my desk and have been swamped with a number of new circulars and orders issued by the SAT. There is some real juicy ones here as well; there will be no [...]
One of my aims for posts on China Tax Insights is to avoid blatant self-promotion of myself or my firm, Hwuason. Instead, I prefer to write substantive and in-depth posts that evidence the quality of legal work my firm does. However, I am going to break this rule just this once.
Over the last 7 days [...]
China Tax Insights has been on a slight hiatus over the past three weeks. This was a combination of Chinese New Year, a rather busy work schedule and, most significantly, the fact that my wife just had our first child. You can look forward to a burst of energy on here over the next few [...]
As I mentioned a week or so ago, the SAT has prepared a draft of new detailed M&A rules. These have not been issued yet, but Hwuason managed to get a copy of the draft. I will outline some of the more salient points over two separate posts:
Reasonable business purpose
The draft rules provide further details [...]
In a clear sign that China is getting increasingly bold in its response to an ongoing trade dispute with the U.S., Chinese authorities Friday slapped preliminary import duties of as much as 105.4% on U.S. chicken products.
The Ministry of Commerce which announced the decision said U.S dumping is hurting China’s domestic poultry industry. Once the [...]
Australian tax law permits a deduction in taxable income where a taxpayer ’s income is stolen. In particular, section 25-45 of the Income Tax Assessment Act 1997 provides that a taxpayer can deduct a loss in respect of money if:
the taxpayer discovers the loss in the income year,
the loss was caused by theft, stealing, embezzlement, [...]