PwC Financial Services Tax News

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2011

December
Highlights of the November 2011 tax changes and 2012 tax proposals for the financial services industry in Japan [PDF 124KB]
This newsletter reviews the principal effects the recent reforms will have for the financial services industry in Japan on corporation tax rates, the limitation of loss deductibility, the new interest deductibility rules and effective date of Islamic Finance incentives.
Special Editon The Financial Transactions Tax - Where are we now? [PDF 241KB]
This Newsletter provides an update on the ongoing debate regarding the introduction of a financial transactions tax (FTT) within the EU following the release of the draft EC Directive on 28 September 2011.
November
Special Editon OECD releases new discussion draft on the meaning of ‘Permanent Establishment’ [PDF 121KB]
On October 12, 2011, the OECD released a discussion draft on the meaning of ‘Permanent Establishment’ in the OECD Model Tax Convention.
New Japan – Netherlands Tax Treaty [PDF 116KB]
New Japan – Netherlands Tax Treaty expected to be effective as of 1 January 2012.
October
Dividend deductibility requirements for J-REITs under roll-over relief [PDF 137KB]
This newsletter is provided for a general introduction to the effect of the reserve method approach for roll-over relief on the 90% distribution rule for J-REITs.
August
Response to the OECD’s discussion draft on the meaning of ‘beneficial owner’ [PDF 137KB]
On April 29, 2011, the OECD released a discussion draft on the meaning of ‘beneficial owner’ in the OECD Model Tax Convention.
June
2011 tax reforms impact on the real estate fund business [PDF 107KB]
Enforcement Order and Enforcement Regulation for 2011 tax reform are issued on June 30, 2011.
May
OECD releases new discussion draft on the meaning of ‘beneficial owner’ [PDF 101KB]
On April 29, the OECD released a discussion draft which sets out proposed changes to the Commentary on Articles 10, 11 and 12 of the OECD Model Tax Convention concerning the meaning of the term ‘beneficial owner’.
April
Foreign Account Tax Compliance Act (“FATCA”) Update [PDF 101KB]
On April 8, 2011, the IRS issued Notice 2011-34 (the “Notice”), which provides guidance in response to certain priority concerns identified by commentators following the publication of Notice 2010-60 and with respect to specific issues involving the implementation of information reporting and withholding tax under FATCA.
March
Cayman Islands / Japan Tax Agreement[PDF 107KB]
On May 26, 2010, the Governments of the Cayman Islands and Japan reached agreement in principle, and subsequently on February 7, 2011, the Ministry of Finance announced that the Agreement was signed by the Governments of the Cayman Islands and Japan.
February
Draft bill 2011 Japanese tax reforms: New procedures for payment records [PDF 104KB]
According to the draft Bill for amending taxation laws submitted to the Japanese Parliament on January 25, 2011, requirements to submit records through e-Tax or in electronic format will be introduced.
January
Draft bill for 2011 Japanese tax reforms impacting real estate business [PDF 173KB]
On January 25, 2011, a draft bill for amending taxation laws was submitted to the Japanese Parliament. This Newsletter provides a summary of the proposed changes specifically affecting Japan’s real estate industry.