PwC Financial Services Tax News

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Withholding tax rate on dividends [PDF 98KB]
This Financial Services Tax News discusses withholding tax rates on dividends and the application of tax treaties following scheduled increases in tax rates.
OECD releases revised discussion draft on beneficial ownership [PDF 131KB]
On 19 October 2012, the OECD released its revised proposals on the topic of beneficial ownership. This contains some modifications from its earlier discussion draft (released in April 2011) which proposed various changes to the Commentary to the OECD Model Tax Treaty in order to clarify the beneficial owner test.
Consumption tax update:Real estate related transitional rules [PDF 108KB]
The Consumption Tax Hike Law was approved on June 26, 2012 by the lower house and subsequently by the upper house of the Japanese Diet on August 10, 2012. Under the reform, the consumption tax rate will be increased gradually; and the reform includes transitional rules with regard to the planned increase applicable to specific types of contracts.
This newsletter provides a summary of the transitional rules as related to the real estate industry.
Outline of FSA’s FY 2013 tax reform submissions [PDF 127KB]
The FSA announced its submission to the Cabinet Office for the fiscal year 2013 tax reform proposals. This Newsletter outlines the FSA’s submission.
2012 Tax Reform Key Points of Earnings Stripping Rules [PDF 132KB]
Under the 2012 Tax Reform, earnings stripping rules have been introduced. This Newsletter highlights key points of these rules.
Summary of restrictions on the use of exempt enterprise system for consumption tax purposes [PDF 112KB]
This newsletter provides a summary of the restrictions on the use of the exempt enterprise system for consumption tax following recent reforms.
Private Equity - A transfer pricing evolution [PDF 121KB]
This newsletter summarises the survey work undertaken looking at transfer pricing issues being faced by private equity firms.
Taxation of J-Sukuk Q&A [PDF 132KB]
This Newsletter summarises the outline of taxation of J-Sukuk Q&A released by the Financial Services Agency on 16 April 2012.
2012 Tax Reform Impact on financial services industry & real estate business in Japan [PDF 140KB]
This Newsletter summarizes the main changes arising from the 2012 Tax Reforms affecting the financial services industry and real estate business in Japan.
2011 Tax Reform Main changes applicable on or after April 1, 2012 [PDF 120KB]
This newsletter summarizes the main changes arising from the 2011 Tax Reforms which will be effective for tax years of corporations beginning on or after April 1, 2012.
Limitation of the use of net operating loss carried forward [PDF 119KB]
2011 Reform Amendment Tax Law was promulgated on December 2, 2011, and includes reform on carry forward of net operating loss.
Special Editon: The Financial Transactions Tax Latest developments [PDF 265KB]
This Newsletter provides an update on the ongoing debate regarding the proposed introduction of a Financial Transactions Tax (FTT) within the EU. In this Newsletter we focus on how the debate has developed since December at the level of the EU, including the latest position across the Member States.
Special Editon: Long-awaited proposed FATCA regulations issued [PDF 204KB]
On February 8, 2012, the Department of Treasury and Internal Revenue Service issued the proposed FATCA regulations. This Tax News summarises guidance provided in the proposed regulations.
Restriction of bad debt allowance [PDF 138KB]
2011 Reform Amendment Tax Law was promulgated on December 2, 2011, and includes specific restriction of tax deductions for bad debt allowance.
Special Editon: Revised Japan-Switzerland Tax Treaty becomes effective [PDF 101KB]
A revised Protocol to the Japan-Switzerland tax treaty (the “Protocol”) became effective on 1 January 2012.This newsletter summarises the principal changes in the revised Protocol.