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International Tax Newsletter - Asia Pacific & MENASA

Asia Pacific & MENASA

International Tax Newsletter

International Tax Asia Pacific and MENASA October 2019

This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Asia Pacific & MENASA Regions between 1 October and 31 October 2019.

Australia

Kazakhstan

Taiwan

China Malaysia  
Hong Kong Myanmar  
Indonesia

New Zealand  


For a full summary of global tax developments, visit home.kpmg/TaxNewsFlash.

To contact the International Tax Team email internationaltax@kpmg.com.

To register for the International Tax webcasts, click here.

International Tax Newsletter - Asia Pacific & MENASA

Australia

  Tax area concerned Relevant date Description of measures and publication link

Tax legislation approved and regulatory update

GST

October 2019

The Australian Taxation Office announced that offshore sellers of Australian commercial accommodation need to add goods and services tax when selling Australian-based accommodation, when these sales exceed AUD 75,000 in a 12-month period.

Proposed legislation

Capital gains

October 2019

The Australian Taxation Office released a draft taxation determination that may result in reduced foreign income tax offset.

Proposed legislation

Corporate income tax

October 2019

The Australian Taxation Office released drafts of two taxation determinations that may have the effect of bringing non-residents into the Australian “tax net”—notwithstanding that there is no gain sourced in Australia.

Administrative and case law

Thin capitalisation

October 2019

The Australian Taxation Office has set out its administrative treatment for income tax returns affected by legislative changes to the thin capitalisation asset valuation rules.

 

China

  Tax area concerned Relevant date Description of measures and publication link

Tax legislation approved and regulatory update

Foreign insurance companies’ regulations

October 2019

The State Council issued an order to expand the availability of the financial industry to foreign insurance companies and foreign-funded banks.

Treaties

Application of treaties

January 2020

China’s state tax administration released administrative guidance with regard to the application of China’s network of income tax treaties, effective January 2020.

 

Hong Kong

  Tax area concerned Relevant date Description of measures and publication link

Tax legislation approved and regulatory update

Deduction of foreign taxes

October 2019

Guidance from Hong Kong’s tax authority reflects a new position that foreign income taxes imposed on gross income (for instance, withholding tax imposed on gross royalties, service fees, and management fees) are no longer deductible under the general deductibility rule.

 

Indonesia

  Tax area concerned Relevant date Description of measures and publication link

Tax legislation approved and regulatory update

Oil and gas / Tax incentives

October 2019

A regulation relating to upstream oil and gas activities, sets forth measures about the tax treatment for shared facilities and for claiming head office cost allocations.

 

Kazakhstan

  Tax area concerned Relevant date Description of measures and publication link

Tax legislation approved and regulatory update

CFC / VAT

October 2019

Changes to the tax law during 2019 reflect the following items:
  • CFC
  • Large taxpayers’ definition
  • A new system of “control VAT accounts” is available as an incentive for certain taxpayers.

 

Malaysia

  Tax area concerned Relevant date Description of measures and publication link

Tax legislation approved and regulatory update

Budget 2020

October 2019

The budget for 2020, presented in October 2019, includes tax-related items, including:

  • Expenses incurred on listing on certain stock exchange markets qualify for tax deduction of up to RM1.5 million
  • An income tax exemption of 100% for up to 10 years on IP income
  • An investment tax allowance on qualifying capital expenditures
  • Extension of the 100% accelerated capital allowance for automation equipment
  • Extension of renewable energy tax incentives and a new income tax exemption for solar leasing companies.

 

Myanmar

  Tax area concerned Relevant date Description of measures and publication link

Tax legislation approved and regulatory update

Advance income tax system

October 2019

Revisions in 2019 to the advance income tax system in Myanmar removed exemptions for taxpayers under the jurisdiction of the “large taxpayers’ office” and the “medium taxpayers’ office” sections of the tax authority.

 

New Zealand

  Tax area concerned Relevant date Description of measures and publication link

Proposed legislation

Land ‘holding costs’

October 2019

A consultation document considers the tax treatment of “holding costs” (such as interest, rates, insurance, and repairs and maintenance) associated with owning land that is taxable on sale, and considers the tax deductibility of these costs for a range of “use” scenarios.

Treaties

Double tax treaties

30 September 2019

Earlier this year, representatives of the governments of New Zealand and the People’s Republic of China signed a new income tax treaty. New Zealand completed its domestic procedures to give effect to the new income tax treaty with China.

Taiwan


Tax area concerned Relevant date Description of measures and publication link

Tax legislation approved and regulatory update

Tax relief under “deemed profit” approach

October 2019

The Ministry of Finance announced relief measures available for certain foreign companies not having a permanent establishment in Taiwan but that receive Taiwan-sourced income.

Tax legislation approved and regulatory update

VAT

1 January 2020

Beginning 1 January 2020, foreign e-commerce suppliers that fail to issue “cloud government uniform invoices” will be considered to be in violation of the invoice rules, and penalties can be imposed for non-compliance.

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