Asia Newsletter - Microsoft€¦ · Investment Funds Law was approved which will enter into effect...

Asia Newsletter

January 2013

C I VIL LAW N O TA RI E SATTORNEYS AT LAW TAX ADVISER S• •

The information below is produced by Loyens & Loeff in Singapore and Hong Kong. It is designed to alert those (interested in) doing

business in the Asian region to recent developments in the region. Such developments are discussed in brief terms and are based on

generally available information. The materials contained in this publication should not be regarded as a substitute for appropriate detailed

professional advice. The information below was assembled based on information available as at 31 December 2012.

1LOYENS & LOEFF Asia Newsletter – January 2013

China (PRC)In kind contributions to ForeignInvested Enterprises

• As of 22 October 2012, the Provisional Regulations on Equity

Capital Contributions to Foreign Invested Enterprises (“the

Regulations”) issued by the Ministry of Commerce entered into

force. The Regulations allow domestic or foreign investors to

make a capital contribution into a Foreign Invested Enterprise

(“FIE”, i.e. an enterprise incorporated in China with foreign

investment) by way of a contribution in kind of shares in a

domestic company. The Regulations apply to three types of

transactions. These are the contribution of equity in a domestic

company to (i) a newly incorporated FIE; (ii) an existing FIE;

and (iii) a non-FIE to convert that company into an FIE.

• Investors can only make such contributions if the following

requirements are met:

• the investor has full title to the equity interest in the subsidiary;

• the registered capital of the domestic company has been fully

paid-up;

• the equity interest is free of any pledge or other security

interest and has not been subjected to a court ordered freezing;

• the constitutional documents of the domestic company do not

prohibit or restrict the transfer of the equity interest;

• if the domestic company is an FIE, it must have passed its

annual inspection in the previous year;

• all corporate and governmental approvals required for the

transfer of the equity interest have been obtained; and

• the domestic company is not a real estate enterprise, a foreign

invested investment company or a foreign invested venture

capital (equity) investment enterprise.

• The shares being contributed must be valued by a licensed

valuator in China and the amount contributed to the registered

capital of the FIE by the shareholders may not exceed the value

on the report issued by the valuator. Such contributions and

other in kind, i.e. non-cash capital contributions may not exceed

70% of the FIE’s registered capital.

Administrative Review Committee of theSAT established

• On 26 October 2012, the Administrative Review Committee

(“Committee”) of the State Administration of Taxation (“SAT”)

was established. The Committee consists of 16 officials from

different divisions of the SAT and 8 external experts from

universities and tax firms. One of the main functions of the

Committee is to review taxpayers’ appeals on complex and key

tax issues.

New advance pricing agreements sign byBeijing tax authority

• It was reported by China Taxation News on 12 November

2012, after 4 rounds of negotiations in the past 3 years, that a

bilateral advance pricing agreement (“BAPA”) has been

concluded between Microsoft and the state/local tax authority

of the Haidian District of Beijing. In addition, the state/local

tax authority of the Chaoyang District of Beijing extended the

BAPA with Maersk, a wholly foreign owned company, for another

5 years. Both BAPAs provide the two companies certainty

about their profits allocation to China and the Chinese tax

treatment thereof. Until now, the (state) tax authority in Beijing

has concluded BAPAs with 3 companies.

New tax treatment on dividend income fromlisted company

• On 16 November 2012, the SAT, the Ministry of Finance

(“MOF”) and the Security Supervision Committee jointly issued

Caishui [2012] No.85 which will enter into effect as of 1 January

2013. It provides that dividends received by individuals from

companies listed on the Shanghai/Shenzhen Stock Exchange

are subject to 20% individual income tax on:

• 100% of the dividend income if the shares are held for 1

month or less;


• 50% of the dividend income if the shares are held for more

than 1 month but not more than 1 year; and

• 25% of the dividend income if the shares are held for more

than 1 year.

• Also it provides that dividends received by securities investment

funds from listed companies are subject to same individual

income tax treatment.

Securities Investment Funds Law amended

• On 28 December 2012 the amendment to the Securities

Investment Funds Law was approved which will enter into effect

as of 1 June 2013.

• Among others, the amendment brings privately offered funds

(“private funds”) within the scope of the regulation regime. As

a result, funds whose units are offered to no more than 200

qualified investors will become subject to regulations, be it less

stringent. For example, a private fund manager only needs to

register with the Fund Industry Association (“FIA”). After private

offering of a private fund, the fund manager should make a

filling at the FIA and the FIA will report to the Securities Regulatory

Commission (“SRC”) if the fund is qualified. Once approved

by the SRC, a private fund manager may also manage public

funds if certain conditions are met.

• The amendment also clarifies that publicly offered funds can

invest in derivatives determined by the SRC besides listed

shares and bonds and other form of securities regulated by the

SRC. By comparison, private funds are permitted to make

broader investments in publicly offered shares, bonds and fund

units, and other forms of securities and derivatives determined

by the SRC.

• Private equity funds and venture capital funds are not covered

by the amended law.

Supplementary notice to the VAT reform

• On 4 December 2012, the SAT and the MOF issued Caishui

[2012] No.86 as supplementary tax policy for the VAT reform.

Among others, it provides that:

• A zero VAT rate applies to transportation services provided

between mainland China and Taiwan/Hong Kong/Macau or

within Taiwan/Hong Kong/Macau by qualifying taxpayers

registered in the pilot areas;

• Immediate VAT refunds are available for domestic cargo

transportation, storage and loading services provided by

taxpayers registered in Dongjiang Bonded Port in Tianjin; and

• Shipping agency service falls within the scope of cargo

transportation agency service.

Treatment of overpaid VAT clarified inasset restructuring

• On 13 December 2012, the SAT issued the Notice [2012]

No.55 to clarify the treatment of overpaid VAT of a general

taxpayer in asset restructuring. If the general taxpayer transfers

all its assets, liabilities and personnel to another VAT general

taxpayer (“another taxpayer”) and cancels its tax registration

following procedures, its input VAT which has not been deducted

can be used by another taxpayer for deduction purpose. The

notice enters into effect as of 1 January 2013.

New deduction rules of individualincome tax of lawyers

• On 7 December 2012, the SAT clarified expense deduction

of lawyers for individual income tax purpose in the Notice

[2012] No. 53. Among others, for shared income received from

a law firm, the limitation on deduction is increased from 30%

to 35%. In addition, when calculating taxable income, the

deductible expense should be based on legal and effective

receipts. If no such receipts available, deemed expense will

be deducted at 8% for annual individual income less than

RMB 500,000; 6% for the income more than RMB 500,000

but less than 1 million; 5% for the income more than

RMB 1 million. The deduction rules have effect from 1 January

2013 to 31 December 2015.

International Tax Developments

• Cayman Islands. On 15 November 2012, an Exchange of

Information Agreement between the Cayman Islands and China

entered into force which will have effect as of 1 January 2013.

• Denmark. On 27 November 2012, Denmark ratified the new

China-Denmark tax treaty, which will replace the current

treaty between two countries once in force and effective. Under

the new tax treaty, dividend withholding tax may be further

reduced to 5%. Capital gains derived from shares are generally

allocated to the shareholder state, unless the shares derive

their value mainly from immovable property.


• Japan. On 4 December 2012, the Notice [2012] No.49 issued

by the SAT clarifies that two newly added taxes in Japan, the

special reconstruction income tax (“SRIT”) and the special

reconstruction corporation tax (“SRCT”), fall within the scope

of taxes covered under the China-Japan tax treaty. On 7

December 2012, the SAT further clarified in an interpretation

note that these two taxes can be credited against Chinese tax

under the double taxation avoidance article of the tax treaty.

SRIT applies on the base income tax liability or withholding tax

liability of Japanese taxable persons at a rate of 2.1%, from 1

January 2013 to 31 December 2037. SRCT applies on base

corporation tax liability of taxable companies at a rate of 10%

from 1 April 2012 to 31 March 2015. Both taxes were introduced

for the purpose of funding reconstruction after the earthquake

in 2011.

• Korea. On 29 October 2012, China and Korea signed a new

social security treaty, which will replace the current one once

it becomes effective.

• On 20 November 2012, it was announced that a trilateral free

trade agreement among Japan, China and Korea is under

negotiations.

• Sweden. It was reported on 26 November 2012 that a social

security treaty between China and Sweden is under negotiations.

Hong KongBuyer’s Stamp Duty on residential propertiesintroduced

• On 26 October 2012, the Hong Kong Government announced

that a Buyer’s Stamp Duty (“BSD”) will be introduced. As a

result, the Stamp Duty (Amendment) Bill 2012 was published

in the Gazette on 28 December 2012 which amends the Stamp

Duty Ordinance (“SD Ordinance”) to introduce such BSD on

residential property transactions.

• Upon the enactment of the legislation, BSD is charged at a flat

rate of 15% of the price of residential property if the property is

acquired by any person who is not a Hong Kong permanent

resident (“HKPR”) on or after 27 October 2012 including

foreigners, local and overseas companies, unless an exemption

applies. The BSD is on top of the existing stamp duty and the

Special Stamp Duty (“SSD”), if applicable.

• On 10 October 2012, the Government clarified the exemptions

for the newly introduced BSD. Among others, exemptions

include the acquisition of residential property by a HKPR jointly

with one/more non-HKPR close relatives (i.e. spouse, parents,

children, brothers and sisters) and transfer of residential property

to one or more non-HKPR close relatives.

• The current SD Ordinance provides relief to the transfer of

immovable property within a group of associated companies.

On 30 October 2012, the Government clarified that BSD is not

exempt if a company (i) transfers its residential property to its

subsidiary on or after 27 October 2012; and (ii) after that indirectly

transfers the property by selling the subsidiary’s shares to a

non-associated party within 2 years.

Special Stamp Duty amended

• The Stamp Duty (Amendment) Bill 2012 published on 28

December 2012 further increases the SSD by adjusting its rates

and extending the holding period.

• Previously SSD was payable if any residential property was

acquired on or after 20 November 2010, either by an individual

or a company (regardless of where it is incorporated), and resold

within 24 months, unless exemptions apply. Under the amended

SSD regime, for any residential property acquired by an individual

or a company on or after 27 October 2012 and resold within

36 months, new rates apply: 20% if the property has been held

for 6 months or less; 15% if the property has been held for

more than 6 months but for 12 months or less; or 10% if the

property has been held for more than 12 months but for 36

months or less.

Tax and stamp duty relief for Islamic bonds

• The Inland Revenue and Stamp Duty Legislation (Amendment)

Bill 2012 was gazetted on 28 December 2012. The proposed

amendments will provide for tax and stamp duty relief for

issuance of relevant Islamic bond products, as these transactions

would normally not have existed in a comparable conventional

bond structure of similar economic substance. The Bill will be

presented to the Legislative Council for first reading on 9

January 2013.


• Canada. On 11 November 2012, the Canada-Hong Kong tax

treaty was concluded in Hong Kong. Once in effect, the tax


treaty reduces Canada withholding tax on dividend to 5%/15%,

interest to 10% and royalties to 10%. An anti-abuse rule is

included in each of these articles. Capital gains derived from

shares are generally allocated to the shareholder state, unless

the shares derive their value mainly from immovable property.

• France. On 27 December 2012, Hong Kong sought clarification

from France that a Hong Kong resident company is exempt

from 25% French branch remittance tax on its income earned

in France under the dividend article of the France-Hong Kong

tax treaty.

• Qatar. In November 2012, Hong Kong and Qatar initiated the

first round of negotiations for a tax treaty.

• South Africa. On 5 November 2012, the first round of negotiations

for Hong Kong-South Africa tax treaty was initiated.

• Switzerland. On 15 October 2012, the Hong Kong-Switzerland

tax treaty entered into force. The tax treaty generally has effect

as of 1 January 2013 in Switzerland and as of 1 April 2013 in

Hong Kong. The tax treaty reduces Swiss withholding tax on

dividends to nil/10% and interest to nil withholding tax. Royalty

withholding tax in Hong Kong is reduced to 3% and Swiss capital

gains upon sale of Swiss shares is generally prohibited under

the treaty. A general anti-abuse rule is included in the treaty.

• EFTA countries. Following ratification by all parties, the free

trade agreement between Hong Kong and the Member States

of the European Free Trade Association (“EFTA”) entered

into force on 1 October 2012 for Iceland, Liechtenstein and

Switzerland, and on 1 November 2012 for Norway. This broad-

based agreement covers trade in goods, trade in services,

investment, intellectual property rights, government procurement,

competition and trade and environment. It is the third agreement

that EFTA concluded with an Asian partner, after Singapore

and South Korea.

IndiaTax residency certificate

• On 17 September 2012, the Government of India issued a

Notification prescribing the format of the Tax Residency Certificate

(‘TRC’) to be obtained by a non-resident assessee for claiming

any Tax Treaty benefits entered into by India.

• A new Rule 21AB has been inserted in the Income-tax Rules,

1962. The Rule provides that a duly verified certificate should

be obtained from the Government of the country or the specified

territory, of which the non-resident assessee claims to be a

resident for the purposes of tax, and shall contain the following

particulars, namely:

• Name of the assessee;

• Status (individual, company, firm etc.) of the assessee;

• Nationality (in case of individual);

• Country or specified territory of incorporation or registration

(in case of others);

• Assessee’s tax identification number in the country or specified

territory of residence or in case no such number, then, a

unique number on the basis of which the person is identified

by the Government of the country or the specified territory;

• Residential status for the purposes of tax;

• Period for which the certificate is applicable;

• Address of the applicant for the period for which the certificate

is applicable; and

• In addition to the above, the Rule also provides for a format

for the application to be made by an Indian resident for

obtaining a TRC for India to claim any benefits under the Tax

Treaty entered into by India.

Conditions for lower interest withholding taxrate of 5%

• Courtesy IBFD it was reported that the Indian Central Board

of Direct Taxes issued Circular No. 7 of 2012 dated 21 September

2012 in relation to foreign borrowings by Indian companies in

respect of the lowering of the withholding tax rate from 20%

to 5% on interest payments by Indian companies for borrowings

made in foreign currency, i.e. under a loan agreement or issue

of long-term infrastructure bonds. Previously, the approval of

the Central Government was required in respect of the borrowings

and the rate of interest to be paid on such borrowings. With

the issuance of this Circular, the Central Government provides

automatic approval (no specific approval required) to all

borrowings that satisfy the following conditions.

• In respect of borrowings under a loan agreement:

• it should take place on or after 1 July 2012;


• it should be in compliance with External Commercial

Borrowings (ECB) Regulations issued by the Reserve Bank

of India (RBI) and should be for the entire term of the loan

agreement;

• the loan agreement should not be a restructuring of an

existing agreement to avail of the benefit of a lower

withholding tax rate; and

• the borrowing Indian company should have obtained a Loan

Registration Number (LRN) issued by RBI.

• In respect of the issue of long-term infrastructure bonds:

• it should be authorized under ECB regulations;

• it should have an original maturity term of 3 years or more;

• the end use of the proceeds of such bond issue should

be for the infrastructure sector as defined under ECB

regulations; and

• the issuing Indian company should have a LRN issued

by RBI.

• The Central Government provides automatic approval for interest

rates which are within all-in-cost ceilings specified under ECB

regulations. In respect of borrowings that do not satisfy the

above conditions, approval for the benefit of section 194LC of

the ITA would be provided by the Central Government on a

case-by-case basis.

Anti-avoidance guidelines

• The second round of GAAR guidelines consultation has not

yet resulted in a final set of guidelines with respect to the

application of the new GAAR (General Anti Avoidance Rule) in

the Indian income tax law.


• UK. Courtesy IBFD it was reported that the India Income Tax

Appellate Tribunal (ITAT) delivered its decision on 21 September

2012 in the case of ADIT v. Maersk Line UK Ltd (ITA No.

2150/Kol/2009) that the exercise of dividend distribution by its

Indian subsidiary, though tax advantageous to the recipient,

cannot be termed as a sham transaction and the receipt of

those dividends cannot be re-characterized as sale consideration

of shares received in advance. The Taxpayer (i.e. Maersk Line

UK Ltd) had earned long-term capital gains on the sale of shares

of its wholly-owned Indian subsidiary to its group company as

a part of a reorganization process. The tax authorities noted

the timing of distribution of dividends by the Indian subsidiary

to the Taxpayer which was immediate prior to sale. The dividends

are tax exempt in the hands of the Taxpayer under the Indian

Income Tax Act 1961 (ITA). However, the Indian subsidiary

will be liable to pay dividend distribution tax (DDT) on the amount

of distribution which is lower than the income tax on long-term

capital gains. The tax authorities contended that the distribution

of dividends is a “colourable transaction” which is in lieu of

capital gains arising to the Taxpayer on the sale of shares. It

further contended that the distribution of dividends reduces the

net worth of the Indian subsidiary which further reduces the sale

consideration as against the sale consideration in the event of

non-distribution of dividends. Accordingly, the tax authorities

recomputed the long-term capital gains and the taxes payable

thereon. The first appellate authority reversed the order and

the tax authorities went in appeal before the ITAT. The ITAT

held that the dividend is not a colourable transaction and cannot

be re-characterized as sale consideration. It justified its decision

by observing the following:

• Every tax advantageous action or inaction cannot be treated

as a colourable device unless and until such inaction or action

is not bona fide or conceals the true nature of a transaction

or is an exercise without any commercial justification.

• Distribution of dividends to the Taxpayer before the sale

transaction resulted in a substantial tax advantage for the

Taxpayer. However, the question to consider is whether such

distribution of dividends could be termed as a “colourable

transaction to avoid tax”.

• The Indian subsidiary had sufficient reserves which were

eligible for distribution as dividends.

• Further, DDT had been paid by the Indian subsidiary and was

accepted by the tax authorities.

• If dividends are not distributed, the undistributed profits will

be regarded as a capital appreciation on value of shares.

Merely because the Taxpayer decides to receive dividends

instead of capital appreciation, the transaction will not be

regarded as a colourable transaction. Also, it cannot be re-

characterized merely because it yields higher tax for the

tax authorities.

• The Netherlands. Ruling that supply of software is not liable

to tax as royalty or fees for technical services. The Authority


of Advance Rulings (AAR) delivered a ruling on 6 August 2010

in the case of GeoQuest Systems B.V. (AAR No. 774 of 2008)

that software transferred without a transfer of intellectual property

rights, including modifications and updates, would neither be

treated as royalty nor as fees for technical services under the

Income Tax Act 1961 (ITA) or under India - Netherlands Income

and Capital Tax Treaty (1988) (the Treaty).

IndonesiaIncrease of general allowances

• On 22 October 2012, effective 1 January 2013, the general

allowances for individual income tax for tax residents of Indonesia

were increased. The basic general allowance is Rp 24,300,000

with an additional Rp 2,025,000 for a married taxpayer.

Dependents (maximum 3) add Rp 2,025,000 to the allowance.

Fixed assets in forestry, plantations and cattlebreeding

• MOF Regulation 126 dated 6 August 2012 prescribes

depreciation that can be claimed in respect of fixed assets

acquired in the abovementioned sectors as per their prescribed

useful life as stipulated in the MOF regulation. Still, as per DGT

Regulation 21 effective 24 October 2012, a taxpayer may, prior

to claiming depreciations, write to the tax office and request the

use the actual useful life of an asset in calculating the depreciation.

Within one month after a complete set of information together

with the request has been submitted to the tax office, the latter

is required to give its decision.

VAT

• A number of MOF regulations have been issued in November

2012 on VAT matters, including a clarification of the VAT position

on labour/manpower services, in which a number of situations

are described which are not subject to VAT as well as a clari-

fication of the verification procedure to be followed in relation

to (1) VAT-able entrepreneur status, (2) revocation of a Tax or

entrepreneur status and (3) issuance of tax assessment letters.

• On 22 November 2012 the Director General of Taxation issued

Regulation 24 as a new administrative regulation regarding

VAT invoices (faktur pajak). The standard format for the

faktur pajak remains the same, but Regulation 24 provides

new procedures regarding systematic invoice numbering.

Based on Reg 24, the DGT also issued Circular 52 to provide

guidance on the new numbering procedure. Both Regulation

24 and circular 52 will be effective on 1 April 2013.


• Hong Kong. The DGT issued circular 50 on 21 November

2012 in which he confirms that as of 1 January 2013 the tax

treaty with Hong Kong has taken effect in Indonesia (from 1

April for Hong Kong tax purposes). The treaty contains the

lowest dividend withholding tax rate (5%) provided that the

Hong Kong shareholder holds at least 25% of the shares of

the Indonesian company and is the beneficial owner of the

dividends. The beneficial ownership requirement is also required

in order to enjoy the reduced withholding tax on interest (10%)

and royalties. An important attention point is the explicit

references to Indonesia being allowed to apply its domestic

anti-treaty shopping legislation and its general anti-avoidance

provision, where appropriate. The treaty will be especially

interesting for investment funds and private equity investors

provided that they satisfy Indonesia’s anti-avoidance tax

provisions. With proper planning in advance this may be feasible.

Japan

Tohoku Earthquake Restoration Surtaximplemented

• On December 2, 2011, “Special Measures to Secure the Financial

Resources to Implement the Restoration from the Tohoku

Earthquake” (“Special Tax Bill”) were promulgated and became

effective on April 1, 2012. It concerns a 10% surtax on the

corporate income tax liability as well as a 2.1% surtax on the

income tax liability as a so-called income surtax and withholding

surtax. It applies with effect from 1 January 2013.

National Tax Agency releases status ofMAP cases

• Courtesy IBFD it was reported that on 15 October 2012, the

National Tax Agency (NTA) released the status of mutual

agreement procedure (MAP) cases as follows:

• The number of MAP cases requested in FY2011 (1 July 2011

- 30 June 2012) was 143, which represents a decrease for


two years in a row. Of the MAP cases requested in FY2011,

the number of advance pricing agreement (APA) cases

comprised 80% (112 cases).

• The number of MAP cases requested in FY2011 has increased

1.6 times from FY2001 (88). The number of APA cases has

increased 2.7 times from FY2001 (42).

• The number of MAP cases closed in FY2011 was 157 (a 4%

decrease from FY2010). Of the MAP cases closed in FY2011,

the number of APA cases was 135 (a 5% increase over

FY2010), which was the largest ever.

• The regional breakdown of the number of closed MAP cases

in FY2011 was 72 with North American countries, 48 with

Asia-Pacific countries and 37 with European countries.

• The number of countries with which the NTA closed MAP

cases in FY2011 was 23, which has remained almost the

same as in recent years.

• The number of MAP cases with non-OECD countries in

FY2011 was 24 (requested cases) and 11 (closed cases).

• The average processing time for MAP and APA cases in

FY2011 was 25.1 months and 23.6 months, respectively.

Korea

Arbitration claim filed against theSouth Korea Government

• On 21 November 2012, the US company Lone Star Funds filed

arbitration claims with the International Centre for Settlement

of Investment Disputes (“ICSID”) against the South Korean

government. Lone Star Funds, a private equity firm head-

quartered in the US, invested in the Korea Exchange Bank

through a Belgium holding company. When the Belgian holding

company sold its 51% stake in the Korea Exchange Bank

in January 2012, the National Tax Service of South Korea

imposed 391.5 billion won as a 10% withholding tax on capital

gains from the sale. Although such gains should be exempt

under the Belgium-Korea tax treaty, the Supreme Court denied

that treaty benefit under the “substance-over-form” principle.

• The claims argued that South Korea violated the Bilateral Invest-

ment Treaty between South Korea and Belgium/Luxembourg.

This case is the first time that South Korea will go through

arbitration trials under the Investor State Dispute mechanism.

Foreign limited partnership ruled as substantiveowner of income

• According to a decision of the Supreme Court on 25 October

2012, a Cayman Islands limited partnership (“LP”) is treated

as a foreign corporation for Korean tax purpose and should be

taxed as the substantive owner of income.

• In the case, a Belgian holding company holds the shares in a

Korean company. The Belgian holding company was held by

a Cayman Islands LP. The Korean company claimed that the

Belgium-Korea tax treaty should apply to the dividends and

capital gains derived by the Belgian holding company from

Korea; alternatively, the ultimate investors of the Cayman LP

should be considered as owner to the income. However, the

Supreme Court rejected the claims and ruled that the Cayman

LP is the real transaction party and should be treated as a

foreign corporation based on its legal features rather than its

tax treatment in its residence state. The court also considered

the Cayman LP as the substantive owner of income rather than

its ultimate investors.

Property acquisition tax cuts approved

• In order to stimulate the property market, on 2 October 2012

the Korean government approved a bill to temporarily reduce

the acquisition tax rate for properties purchased by the end

of 2012:

• to 1% from 2%, for a residential home valued less than KRW

900 million;

• to 2% from 4%, for a residential home valued at between

KRW 900 million and KRW 1.2 billion; or

• to 3% from 4%, for a residential home valued more than KRW

1.2 billion.

• In addition, a total tax exemption will be provided for residential

homes valued less than KRW 900 million if purchased within

this year and sold within the next five years.

Tax incentives for high-tech foreign investments

• It was reported by the Ministry of Strategy and Finance that

newly revised tax incentives are provided to foreign investments

in high-tech businesses and related services as of 4 December

2012. Under these incentives, tax exemptions from corporate,


income and acquisition taxes are available for the first 5 years

and a 50% reduction for another 2 years thereafter.

• The scope of qualifying high-tech businesses is amended in

the revision. 33 new high-tech businesses are added in, such

as large-scale date processing technology and mobile game

technology with cloud computing, while some are removed or

changed according to technology development. Applications

for such tax incentives will be reviewed and decided upon

within 20 days by competent authority.


• Bahrain. On 27 November 2012, Bahrain’s parliament approved

the Bahrain-Korea tax treaty which was signed 1 May 2012.

Under the tax treaty, withholding tax on dividend is reduced to

5%/10%, interest to 5% and royalty to 10%.

• Brazil. A social security treaty was signed by Brazil and Korea

on 22 November 2012.

• China. A new social security treaty was signed by China

and Korea which will replace the current one once it becomes

effective.

• Ecuador. On 8 October 2012 Ecuador announced that the

Ecuador-Korea tax treaty was signed.

• India. On 2 November 2012 negotiations took place in Seoul

to revise the current India-Korea tax treaty.

• Kyrgyzstan. A negotiation for the Korea-Kyrgyzstan tax treaty

was completed on 14 December 2012.

• On 20 November 2012, Korea, China, and Japan agreed to

hold first-round negotiations of a trilateral Free Trade Agreement

in early 2013.

Malaysia

Clarification of reinvestmentallowance rules

• Malaysia’s Inland Revenue Board (IRB) published Public Ruling

(PR) 06/2012 on 12 October 2012 clarifying the reinvestment

allowance (RA) rules.

• A qualifying company or qualifying person may claim an RA

of 60% of the capital expenditure which relates to a qualifying

project in the basis period for a year of assessment (YA).

Qualifying projects are:

• expansion, modernization or automation projects undertaken

by a company for its existing manufacturing business or any

related product within the same industry or to diversify its

existing business into any related product within the same

industry; and

• agricultural projects undertaken by a company to expand,

modernize, or diversify its cultivation and farming business,

excluding the business of rearing chicken and ducks.

• The RA should in principle be deducted against the statutory

income of the business with a limit of 70% of the statutory

income. The RA may be deducted against 100% of statutory

income if the qualifying project has achieved the level of

productivity prescribed by the finance minister. The level of

productivity will be measured by using a process efficiency ratio

and should be compared with the level prescribed by the finance

minister for the same YA. However, deduction up to 100% of

statutory income is not permitted for companies undertaking

qualifying projects in the agricultural sector.

• Any RA not used in a YA as a result of insufficient statutory

income can be carried forward and deducted against the

statutory income of the business in the following YAs until the

RA is fully used. Generally, RA that is carried forward may

be deducted in subsequent years up to 70% of the statutory

income of the business. In cases when the current-year RA is

to be deducted up to 100% of the statutory income, the amount

of RA carried forward may also be deducted up to 100% of the

statutory income.

• Companies may claim the RA for 15 consecutive YAs. The

qualifying period commences from the YA the company first

makes the claim. The RA will be withdrawn if an asset is

disposed of within five years from the date of acquisition of

the asset.

Taxation of real estate investment trusts (REITs)and property trust funds (PTFs)

• The IRB issued guidance on the taxation of unit holders of

REITs and PTFs (PR 7/2012) and on the tax treatment of

REITs and PTFs themselves (PR 8/2012).


• PR 7/2012 explains the tax treatment of the income distributed

by REITs/PTFs to their unit holders. REITs/PTFs distribute three

types of income, and the tax treatment varies accordingly:

• Income that is exempted at the REIT/PTF level. A REIT/

PTF which distributes at least 90% of its total income in

a basis year is exempted from tax for that year. However,

this income would still be taxable in the hands of the unit

holders and there is no credit available to be offset against

the tax imposed.

• Income that has been taxed at the REITs/PTF level.

Such income would also be taxable in the hands of the

unit holders but a credit is available to be offset against the

tax imposed.

• Exempt income. Tax exempt income received by REITs/

PTF which is subsequently distributed to unit holders continues

to be exempt in the hands of the unit holders.

• Unit holders are taxed in the YA the distribution is received

and taxation is based on their residence status. Tax filing

obligations may also vary.

• PR 8/2012 provides a general description of (Islamic) REITs

and PTFs in Malaysia as well as their regulatory framework.

Guidance is provided on the special tax treatment accorded

to the rental income received by REITs/PTFs, the exemption

of REIT/PTF income, and the treatment of rental income of

a unit trust.

Deferral of thin capitalization rules

• The Ministry of Finance issued a statement on 11 December

2012 informing that the implementation of thin capitalization

rules has been deferred to 31 December 2015.


• Ukraine. The Ukrainian Finance Ministry announced on

26 October 2012 that it has initialled an income tax treaty

with Malaysia earlier that month, which is expected to be

signed soon.

• New Zealand. The protocol to amend the income tax treaty

between Malaysia and New Zealand of 19 March 1976, has

been signed on 6 November 2012. The Protocol includes an

update of the exchange of information provision.

Philippines

Taxation of professional services

• On 31 October 2012, the Bureau of Internal Revenue (“BIR”)

released Revenue Memorandum Circular No. 64-2012 clarifying

the tax treatment of self-employed professionals, which provides:

• If the gross professional fees for last 12 months exceed

PHP 1,919,500, a professional is subject to 12% VAT besides

other income taxes. Furthermore, if the gross fees exceed

same threshold again in next 12 months, VAT registration

is required.

• If the gross professional fees for the last 12 months are no

more than the threshold and the professional is not registered

for VAT purpose, he is subject to 3% profit tax.

• Professionals who are not required to register for VAT may

opt to register, however that registration is not allowed to be

cancelled for the next 3 years.

• Once registered for VAT, professionals are subject to 12%

VAT upon registration regardless the amount of gross receipts.

Withholding tax on interest income fromfinancial instruments

• On 7 November 2012, the BIR issued Revenue Regulations

No. 14-2012 clarifying withholding tax levied upon interest

income from financial instruments and similar transactions.

Main points are summarized as below.

• Government debt instruments and securities are treated as

“deposit substitutes”. Interest income derived there from is

subject to a 20% final withholding tax (“FWT”) if earned by a

citizen, a resident alien, a non-resident alien engaged in trade

or business (“NRAETB”), a domestic corporation or a resident

foreign corporation; 25% by a non-resident aliens not engaged

in trade or business in the Philippines (“NRANETB”); or 30%

by a non-resident foreign corporation.

• Long-term time deposits or investment certificates issued by

banks with a maturity of not less than 5 years, are not subject

to FWT if the depositor or investor is a citizen, a resident alien

or NRAETB and other conditions are met; otherwise 20% FWT


applies. Interest income derived by NRANETB is subject to

25% FWT, while the rate is 30% if received by domestic or

foreign corporations. If such instruments are pre-terminated by

the depositor or investor, entire interest income is subject to

different FWT based on the remaining maturity:

• 4 years to less than 5 years: 5%;

• 3 years to less than 4 years:12%; and

• Less than 3 years: 20%.

• Interest income derived from a depository bank under the

expended foreign currency deposit system is subject to 7.5%

FWT if received by a citizen, a resident alien, a domestic

corporation or a resident foreign corporation; or is exempt from

FWT if received by a non-resident (individual/corporation).

• Interest income derived from foreign currency loans granted

to residents other than offshore banking units (“OBUs”) or

local commercial banks is subject to 10% FWT. Interest

income derived by authorized OBUs from foreign currency

transactions with non-residents, other OBUs, local commercial

banks and authorized branches of foreign banks is exempt

from tax.

• Interest income derived from any other debt instrument not

covered within the definition of ‘deposit substitutes’ and the

Regulations No. 14-2012 is subject to 20% creditable with-

holding tax.

VAT on sales of adjacent real properties

• On 12 October 2012, the BIR issued Revenue Regulations

No. 13-2012. It clarifies the threshold amount to levy VAT on

sale of adjacent residential lots, house and lots or other residential

dwellings like condominium units which are actually utilized

as one residential unit.

• The sale is subject to VAT if: (i) the same seller sells two or

more adjacent residential lots, house and lots or other residential

dwellings (“adjacent properties”) in favour of 1 buyer within 12

months; (ii) the purpose is to utilize the adjacent properties as

one residential area; (iii) the aggregate value of the adjacent

properties exceeds PHP 1,919,500 for residential lots and

PHP 3,199,200 for residential house and lots or other residential

dwellings. Adjacent residential lots, house and lots or other

residential dwellings although covered by separate titles and/or

separate tax declarations, when sold or disposed to one and

the same buyer, whether covered by one or separate deeds of

conveyance, shall be presumed as a sale of one residential lot,

house and lot or residential dwelling.

• Sales of the adjacent properties with aggregate value below

the threshold will be exempt from VAT. However, the sale of

parking lots in a condominium units is a separate transaction

and subject to VAT regardless of amount of selling price.


• Armenia. On 4 October 2012, the Armenia-Philippines tax

treaty was approved by Armenia.

• France. The protocol concluded on 25 November 2011 to the

France-Philippines tax treaty was ratified by France on 29

November 2012. Under the protocol, a new exchange of infor-

mation article replaces the previous one.

• Netherlands. In September 2012 it was reported that the

Netherlands intends to revise the current Netherlands-Philippines

social security treaty.

Singapore

High Court decision on anti-avoidancecase AQQ

• In our Summer 2011 edition we announced the first anti-

avoidance case in Singapore, AQQ v Comptroller of Income

Tax, and that appeal against the case had been filed by the

taxpayer. On 18 December 2012 the High Court decided on

the appeal in favour of the taxpayer.

• AQQ is a Singapore incorporated and tax resident company

and used for a group restructuring, issued notes to generate

funds to purchase subsidiaries. As shown in the chart below,

the Notes were subsequently on-sold twice and the final purchase

by the group company was (indirectly) financed by AQQ’s

purchase of the subsidiaries, for which it issued the Notes in

the first place.


• As a result of this financing structure, AQQ’s income tax

computation was as follows:

• Dividend income -/- interest expenses = chargeable income;

• Chargeable income * tax rate = tax liability;

• Tax liability -/- dividend tax credits = negative tax liability =

tax refund.

• Although initially the tax officer accepted AQQ’s tax filings,

after a few years he revised his view and issued additional

tax assessments to retrieve the tax refunds. The additional

assessments were issued based on the anti-avoidance provision

(section 33) in the Income Tax Act (ITA): the tax officer took

the view that the financing arrangement was a scheme put in

place to avoid tax. As a result, he disregarded both the dividend

income (which justified the tax credits under the previous tax

system) and the deduction of interest expenses.

• While the High Court found that the financing arrangement

fell within the scope of section 33 (i.e. it regarded the financing

arrangement as abusive), it was of the view that only the interest

expense incurred and not the dividend income received by

the taxpayer should be disregarded. As such the High Court

found that the tax officer has not fairly applied section 33 ITA.

Consequently, the High Court allowed the appellant's appeal

and ruled to disregard the additional assessments.

High Court ruling denying right toexchange information

• Upon request for an exchange of information about two bank

accounts in Singapore by the Indian tax authority, the Singapore

tax officer filed an application for a court order requiring the

bank concerned to provide the information.

• The information request by the Indian tax authority was made

under the exchange of information clause of the India/Singapore

income tax treaty, and was based on poor evidence (i.e. unsigned

bank transfer instructions for transferring funds to the bank

accounts in Singapore) that an Indian tax national would be

connected to the overseas companies that were the bank

account holders.

• The test applied by the High Court was whether the requested

information was “foreseeably relevant” to the Indian tax authority

for carrying out the treaty provisions. This test requires the tax

officer - on behalf of the requesting state - to show some clear

and specific evidence that there is a connection between the

information requested and the enforcement of the requesting

state’s tax laws.

• In this case there was insufficient evidence provided by the

Indian tax authority to prove the connection between the Indian

national and the two companies, and therefore the application

for the court order was dismissed by the High Court.

Consultation paper on tax crimes

• From 9 October to 9 December 2012 the Monetary Authority of

Singapore (MAS) issued a consultation paper on thedesignation

of a broad range of serious tax crimes as money laundering

predicate offences in Singapore as of 1 July 2013. This would

oblige financial institutions to apply all the Anti-Money Laundering

/ Countering the Financing of Terrorism measures as contained

in the relevant MAS Notices to prevent the laundering of proceeds

from serious tax crimes and would involve the conduct of

rigorous customer due diligence, transactions monitoring, and

proper reporting of suspicious transactions.


• Italy. The amending protocol to the income tax treaty between

Singapore and Italy of 29 January 1977, signed on 24 May

2011, did not enter into force on 30 August 2012 as reported

in our Autumn 2012 Newsletter, but entered into force and

generally applies as of 19 October 2012.

• Germany intends to renegotiate its income and capital tax

treaty with Singapore of 28 June 2004 in relation to the provision

for the exchange of information.

• Poland. The income tax treaty between Singapore and Poland

has been signed on 4 November 2012 and will replace the tax

Holdco

Bank GroupcoAQQ(appellant)

Singaporesubsidiaries

SellsNotes Sells

Notes

Dividend

Notesissuance

Interest

Loan to finance thepurchase of Notes

Purchase price forshares of subsidiaries

Mauritiusbranch


treaty of 23 April 1993. The treaty contains maximum withholding

tax rates of (i) 10% on dividends in general, but 5% if the

beneficial owner is a company (other than a partnership) which

controls directly at least 10% of the capital of the company

paying the dividends on the date the dividends are paid and

has done so or will have done so for an uninterrupted 24-month

period. Dividends paid to certain public bodies are exempt from

withholding tax (currently, one rate of 10% applies); (ii) 5% on

interest, subject to exceptions (currently, 10%); (iii) 5% on

royalties in general, but 2% for the use of, or the right to use

any industrial, commercial, or scientific equipment (currently,

one rate of 10% applies); and for service fees (managerial and

technical), there are no provisions. The dividend, interest and

royalty articles furthermore include anti-avoidance clauses, and

the treaty contains a remittance clause. Capital gains include

gains from the alienation of shares deriving more than 75%

(50% under the OECD Model) of their value directly or indirectly

from immovable property to be taxed in the state where the

property is situated.

• Jersey, Liechtenstein, Belarus. Singapore signed tax treaties

with Jersey (17 October 2012), Liechtenstein (6 December

2012), and Belarus (initialled on 22 November 2012).

• Ecuador, Uruguay. Singapore held negotiations for a tax treaty

and an investment protection treaty with Uruguay on 9 November

2012, and Ecuador intends to start negotiations for a tax

treaty with Singapore.

• Bermuda. Singapore and Bermuda signed an Exchange of

information agreement on 29 October 2012, which entered

into force on 6 December 2012 and generally applies as of 1

January 2013.

• United Kingdom. The second protocol to the income tax treaty

between Singapore and the UK of 12 February 1997, signed

on 15 February 2012 as highlighted in our Summer 2012 edition,

entered into force on 27 December 2012.

TaiwanNew anti-avoidance rules will be introduced

• It has been reported by the Ministry of Finance that on 6

December 2012 the Executive Yuan of Taiwan passed the

amendments to the Income Tax Act which will be further

subject to approval by the Legislative Yuan of Taiwan. In the

amendments, controlled foreign company (“CFC”) rules and

effective management (“EM”) concepts are introduced. They

will enter into force as of 2015 once approved.

• Under the proposed CFC rules, if a Taiwanese profits seeking

enterprise directly or indirectly owns more than 50% capital or

has substantial control over a qualifying associated enterprise

in a tax haven or low tax country, undistributed profits of the

foreign enterprise will be taxable in Taiwan in proportion to the

investment held by the Taiwanese company.

• According to the EM concept, a foreign enterprise with its

effective management in Taiwan will be treated as a tax resident

and thus subject to tax in Taiwan.


• Germany. On 7 November 2012, the Germany-Taiwan tax

treaty entered into force, which will apply as of 1 January 2013.

Under the tax treaty, in general withholding taxes on dividends,

interest and royalties are reduced to 10% and capital gains from

sale of shares are in general protected. A “most-favoured-

nation clause” is included in the dividend article, which may

reduce the 10% Taiwan dividend withholding tax if Taiwan

in future concludes a more beneficial dividend rate with another

OECD member state.

• Thailand. On 30 November 2012, Taiwan and Thailand signed

a tax treaty.

ThailandNo changes to the personal income taxsystem (yet)

• The Revenue Department (RD) will await the results of already-

approved cuts in the corporate tax system before considering

any changes to the personal income tax rates. Thailand

promulgated a reduction of the corporate income tax rate from

30% to 23% this year and 20% as of 1 January 2013.

• The RD will wait to assess the impact of the corporate tax

reductions on the fiscal 2013 budget before considering any

changes to the personal income tax system. The government’s

fiscal year 2013 started October 2012 and will end 30

September 2013.


• The RD had previously floated an idea to expand the current

five-tier personal tax system to offer greater tax relief to middle-

income earners. Currently, personal income tax rates range

between 0% (below 150,000 baht) and 37% (above 4 million

baht). The proposed changes would see rates of 15-25%,

resulting in lower overall taxes for many middle-class taxpayers.


• Thailand recently signed income tax treaties with Estonia

(September 2012) and Taiwan (30 November 2012).

Vietnam

Advance Pricing Agreement introduced

• On 20 November 2012, the National Assembly of Vietnam

approved amendments to the Tax Administration Law introducing

the possibility to obtain an Advance Pricing Agreement (“APA”),

which will take effect as of 1 July 2013.

• Based on the amended law, an APA is a binding written

agreement between the tax authority and taxpayers over a

period of time. Such APA determines the tax calculation basis,

applicable transfer pricing method, or arm’s length price in a

related party transaction, and will be issued before the taxpayers

submit their tax declaration documents.

• The APA can be on an unilateral, bilateral, or multilateral basis

among the Vietnamese tax authority, the taxpayers, and the

tax authorities of foreign jurisdictions. Under the amendments,

the Vietnamese tax authority will apply an APA with taxpayers,

tax authorities in foreign jurisdictions with which Vietnam

concluded a tax treaty. Currently Vietnam has concluded

around 60 tax treaties. Further clarifications will be issued in

the implementation guidance of the amended Law.

Corporate tax reductions proposed

• The Ministry of Finance of Vietnam proposed a draft bill on 12

December 2012 to lower corporate income tax, which will be

submitted to the National Assembly for approval early next year.

Main points of the proposal are summarized below:

• Current corporate tax rate of 25% in Vietnam would be reduced

to 23% from 1 January 2014.

• Small-and-medium-size enterprises, with employees less

than 200 and turnover not exceeding VND 20 billion (about

$960,000), would be subject to a further reduced rate

of 20%.

• Preferential rates of 10 to 20% would be granted to incentivize

specific sectors such as education, healthcare and environment.

• Limitation on allowable deductible expenses for advertising

and promotion would raise from 10% to 15% of all costs of

the enterprise.

• Thin-capitalization rules would be amended to disallow

deduction of interest exceeding debt-to-equity ratios of 4:1

(10:1 for banks and credit institutions), which will enter into

force in 2016.

Foreign contractor tax

• Courtesy IBFD it was reported that the General Department

of Tax recently issued clarifications on the Foreign Contractor

Tax (FTC) as follows:

Purchase of software

• Official letter (OL) 3738/TCT-CS dated 26 October 2012 provides

that where a piece of equipment, with software (and the right

to use that software), is purchased from a foreign supplier,

the purchase of that software will be subject to FCT at 10%

(CIT only). The value of the software and the right to use must

be identifiable and the payment must qualify as a royalty for the

transfer of technology or intellectual property.

Loan interest

• Pursuant to OL 3929/TCT-CS dated 8 November 2012, loan

interest which is incurred before 1 March 2012 (i.e. based on

the loan contract) is subject to the deemed CIT rate of 10%

even if payment is made after 1 March 2012. Therefore, loan

interest arising after 1 March 2012 will be subject to deemed

CIT at 5%.

Re-insurance

• OL 3998/TCT-CS dated 12 November 2012 states that the

applicable deemed CIT rates for payments in respect of re-

insurance contracts depend on when the payments are incurred

and not paid. Thus payments incurred up to 29 February 2012

are subject to a deemed CIT rate of 2%, whereas a deemed

CIT rate of 0.1% will apply to payments incurred from 1 March

2012 onwards.


Although great care has been taken when compiling this newsletter, Loyens & Loeff N.V. does not accept any responsibility whatsoever

for any consequences arising from the information in this publication being used without its consent. The information provided in the

publication is intended for general information purposes and cannot be considered as advice.

Business licence tax

• OL 3639/TCT-KK dated 17 October 2012 clarifies that foreign

contractors who do not have a presence in Vietnam (as per

the Law on Investment and the Law on Commerce), despite

generating income in Vietnam, are not required to pay business

licence tax.


• Morocco. The Morocco-Vietnam tax treaty entered into force

in September 2012 which will take effect as of 1 January 2013.

Under the tax treaty, the withholding tax on dividends, interest

or royalties is reduced to 10%. Capital gain tax may be levied

upon transfer of a shareholding of 10% or more in a company.

• Russia. Russia clarified that bonus (income) received by

employees resident in Vietnam from Russian sources should

be treated as other income under Article 22 of the Russia-

Vietnam tax treaty, rather than employment income in Article

15. Therefore, such bonus income may be subject to Russian

individual income tax at 30%.

• A first round of negotiations for an European Union-Vietnam

Free Trade Agreement (“FTA”) took place in Hanoi from 8 to

12 October 2012. This is the third FTA that the EU currently

negotiates with countries of the Association of Southeast

Nations (“ASEAN”), following Singapore and Malaysia.

w w w . l o y e n s l o e f f . c o m

Offices

BENELUX

AMSTERDAM

Fred. Roeskestraat 100

1076 ED Amsterdam

Netherlands

Telephone +31 20 578 57 85

Fax +31 20 578 58 00

ARNHEM

(OOSTERBEEK)

Utrechtseweg 165

6862 AJ Oosterbeek

Netherlands

Telephone +31 26 334 72 72

Fax +31 26 333 73 42

INTERNATIONAL

ARUBA

ARFA Building (Suite 201)

J.E. Irausquin Boulevard 22

Oranjestad, Aruba

Telephone +297 582 48 37

Fax +297 583 52 14

CURACAO

Landhuis Arrarat

Presidente Romulo Betancourt

Boulevard 2

Berg Altena, Curaçao

Telephone +599 9 465 15 00

Fax +599 9 465 15 18

DUBAI

Dubai International Financial Centre

(DIFC)

Gate Village, Building 10, Level 2

Dubai, U.A.E.

Telephone +971 4 4372 700

Fax +971 4 4255 673

BRUSSELS

Woluwe Atrium

Neerveldstraat 101-103

B-1200 Brussels

Belgium

Telephone +32 2 743 43 43

Fax +32 2 743 43 10

EINDHOVEN

Parklaan 54a

5613 BH Eindhoven

Netherlands

Telephone +31 40 239 44 44

Fax +31 40 239 44 40

GENEVA

Rue du Rhone 59 (1st floor)

CH-1204 Geneva

Switzerland

Telephone +41 22 818 80 00

Fax +41 22 312 02 03

HONG KONG

28th floor, 8 Wyndham Street

Central, Hong Kong

Telephone +852 3763 9300

Fax +852 3763 9301

LONDON

26 Throgmorton Street

London EC2N 2AN

United Kingdom

Telephone +44 20 7826 3070

Fax +44 20 7826 3080

LUXEMBOURG

K-Point Building

18-20, rue Edward Steichen

2540 Luxembourg

Luxembourg

Telephone +352 46 62 30

Fax +352 46 62 34

ROTTERDAM

Blaak 31

3011 GA ROTTERDAM

The Netherlands

Telephone +31 (0) 10 224 62 24

Fax +31 (0) 10 412 58 39

NEW YORK

555 Madison Avenue

27th Floor

New York, NY 10022

USA

Telephone +1 212 489 06 20

Fax +1 212 489 07 10

PARIS

1, Avenue Franklin D. Roosevelt

75008 Paris

France

Telephone +33 1 49 53 91 25

Fax +33 1 42 89 14 60 (legal)

Fax +33 1 49 53 94 29 (tax)

SINGAPORE

80 Raffles Place

# 14-06 UOB Plaza 1

Singapore 048624

Telephone +65 6532 3070

Fax +65 6532 3071

TOKYO

15F, Tokyo Bankers Club Building

1-3-1 Marunouchi, Chiyoda-ku

TOKYO 100-0005

Japan

Telephone +81 3 3216 7324

ZURICH

Dreikönigstrasse 55

CH-8002 Zurich

Switzerland

Telephone +41 43 266 55 55

Fax +41 43 266 55 59

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