International Tax Asia Pacific April 2022

This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Asia Pacific Regions between 1 April and 30 April 2022.

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

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

To register for the International Tax webcasts, click here.

Australia

 

Tax area concerned

Relevant date

Description of measures and publication link

Australia

KPMG Publication

Transfer pricing

11 April 2022

Taxpayers need to consider whether IBOR reform-related changes to their financial arrangements have tax consequences Read more.

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Cambodia

 

Tax area concerned

Relevant date

Description of measures and publication link

Cambodia

Tax legislation approved and regulatory update

Income tax

29 April 2022

Taxpayers that voluntarily adjust their accounting records and tax returns and make payments of the amount of underpaid tax prior to a tax audit, are provided some relief from the 10% additional tax. Read more.

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Hong Kong

 

Tax area concerned

Relevant date

Description of measures and publication link

Hong Kong

Administrative and case law

Income tax

29 April 2022

Profits found to be offshore-sourced, not subject to profits tax (court decision). Read more.

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India

 

Tax area concerned

Relevant date

Description of measures and publication link

India

Administrative and case law

Income tax

20 April 2022

Reassessment notice emailed on last day of limitation period held valid (court decision). Read more.

Administrative and case law

Income tax

19 April 2022

Payments to subcontractor in China taxable as "fees for technical services" under India-China treaty (tribunal decision). Read more.

Tax legislation approved and regulatory update

Income tax

14 April 2022

Australia agreed to stop the taxation of offshore income of Indian companies providing technical services to Australian clients. Read more.

KPMG Publication

Various tax topics

14 April 2022

KPMG in India has prepared reports on recent tax developments:
  • Validity of assessment order issued in the name of amalgamating company post amalgamation
  • Computation of taxability of interest on excess contribution made by employee to their provident fund account Read more.

KPMG Publication

Various tax topics

11 April 2022

KPMG in India has prepared reports on recent tax developments:
  • Subscription fees for customer relationship management services under the India-Singapore income tax treaty
  • Tax relief on income arising from foreign retirement funds
  • CBDT notifies e-Dispute Resolution Scheme, 2022 Read more.

Administrative and case law

Income tax

07 April 2022

Payments for online advertisements not taxable in India (tribunal decision). Read more.

Administrative and case law

Income tax

07 April 2022

No dependent agent permanent establishment under India-Mauritius tax treaty (tribunal decision). Read more.

Administrative and case law

Various tax topics

05 April 2022

KPMG in India has prepared reports on recent tax developments:
  • Appellate procedure; additional argument cannot initially be raised before appellate tribunal
  • Tax withheld at source and inability to deduct related expenses when not able to identify payees
  • Foreign tax credit available in India on taxes withheld on commission income in Singapore Read more.

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Indonesia

 

Tax area concerned

Relevant date

Description of measures and publication link

Indonesia

Tax legislation approved and regulatory update

Income tax

25 April 2022

The government issued guidance concerning the taxation of income from construction services which, among other changes, introduces a new construction service category. Read more.

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Malaysia

 

Tax area concerned

Relevant date

Description of measures and publication link

Malaysia

KPMG Publication

Various tax topics

28 April 2022

Finance Act 2021 introduced several amendments that would change tax landscape for unit trust funds in 2022. Read more.

Tax legislation approved and regulatory update

Income tax

15 April 2022

The Malaysian Inland Revenue Board has issued the tax corporate governance framework (TCGF) and guidelines to assist organizations in designing and operating their TCGF and encourage voluntary participation in the TCGF program. Read more.

Tax legislation approved and regulatory update

Income tax

07 April 2022

The Ministry of Finance announced that foreign source income received in Malaysia during the second six months of the 2022 assessment year (i.e., from 1 July 2022) is excluded from the computation of the prosperity tax. Read more.

Tax legislation approved and regulatory update

Tax compliance

04 April 2022

The Malaysian Inland Revenue Board has introduced a new e-telegraphic transfer system that will generate a unique account number per transaction and will assist the MIRB to trace the electronic transfer of funds by taxpayers to its accounts and to identify the taxpayers.  Read more.

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Philippines


Tax area concerned

Relevant date

Description of measures and publication link

Philippines

Tax legislation approved and regulatory update

Tax compliance

20 April 2022

The deadline for submission of attachments to the 2021 annual income tax return is on or before 31 May 2022. Read more.

Tax legislation approved and regulatory update

Various tax topics

13 April 2022

Guidance clarifies deadline for filing annual income tax returns for the 2021 tax year. Read more.

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Thailand

 

Tax area concerned

Relevant date

Description of measures and publication link

Thailand

Tax legislation approved and regulatory update

Tax compliance

01 April 2022

The Minister of Finance has extended to 30 May 2022 the deadline for filing the transfer pricing disclosure form for fiscal years starting on or after 1 January 2020 to 31 December 2020. Read more.

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