International Tax Asia Pacific and MENASA December 2018 - January 2019

This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Europe and Africa Regions between 1 December 2018 and 15 January 2019.

Australia India Thailand
China Japan Vietnam
Hong Kong New Zealand  


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International Tax Newsletter - Asia Pacific & MENASA


  Tax area concerned Relevant date Description of measures and publication link
Proposed legislation Withholding tax  January 2019

The draft ruling consolidation TR 2005/5DC seeks to clarify the definition of a ‘financial institution’ under the treaty interest withholding tax exemption for non-resident lenders.

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Administrative and case law GST 1 October  2018

The Australian Taxation Office updated its website to notify taxpayers of two new guidance products targeting contentious areas of GST compliance within the retail banking sector.

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Tax legislation approved and regulatory update E-commerce 1 January 2019

The State Council announced revisions to the rules concerning the policy for cross-border e-commerce transactions involving imports of retail goods. The new regulations increase the transition limits and add more taxable items.

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Tax legislation approved and regulatory update Individual income tax  January 2019

The State Council and the State Administration of Taxation released implementation rules and supplementary guidance notes concerning individual income tax measures in China.

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Hong Kong

Proposed legislation Corporate income tax January 2019    

Legislation has been proposed to provide a profits tax exemption for private funds operating in Hong Kong.

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Administrative and case law GST January 2019

The Central Board of Indirect Taxes and Customs issued guidance that generally reflects recommendations made with respect to GST issues.

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Administrative and case law Various tax areas December 2018

KPMG in India has prepared reports on the following tax developments:

  • Registration not required, location where goods are imported. The case is: Sonkamal Enterprises Private Limited.
  • No penalty on account of human error. The case is: M/s Rai Prexim India Pvt. Ltd.
  • Telecom license-related fee. The case is: Telenor (India) Communications Pvt Ltd. 
  • Tax treatment on conversion of private limited company into LLP. The case is: Celerity Power LLP.
  • Extension of certificate of coverage, social security agreements.

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Administrative and case law Various tax areas December 2018

KPMG in India has prepared reports on the following tax developments:

  • tax of income related to shares received for no or inadequate consideration under section 56(2)(viia)
  • foreign direct investment in e-commerce
  • Provisions of section 56(2)(vii)(c) do not apply to the proportionate issue of “right shares:”. The case is: Shri. Subhodh Menon.
  • Tax withheld at source when there are joint buyers of immovable property. The case is: Vinod Soni.
  • Reduction in share of capital amounts is “transfer” of capital asset: The case is: Jupiter Capital Pvt Ltd.

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Proposals  Tax reform

14 December 2018

The ruling coalition agreed to an outline of tax reform proposals that include corporate and international tax measures. The corporate tax proposals include:

  • tax credits for research and development (costs as enhanced incentives
  • expanded definition of “large scale companies” for purposes of the preferential tax measures available for small and medium-sized companies
  • rules for tax treatment of virtual currencies
  • changes to rules on taxation of reorganizations including “squeeze-out transactions” and triangular reorganizations.

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Treaties  Economic Partnership Agreement 1 February 2019 The EU-Japan Economic Partnership Agreement will enter into force 1 February 2019, following completion of the agreement’s ratification by the EU Parliament and Japan’s National Diet. Read more

New Zealand

Proposed legislation  GST  December 2018

New Zealand’s government introduced a bill that includes measures GST rules for low-value imports and the tax treatment of residential rental properties.

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Tax legislation approved and regulatory update Corporate income tax  December 2018

Additional requirement for CIT reduction or exemption on royalty income under the International Headquarters regime.

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Administrative case law  VAT January 2019

The General Department of Taxation issued an “official letter” to all provincial tax departments addressing the VAT rules for electronic and paper invoices.

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