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Japan Tax News

Treaty between India and Japan – Indian decision on whether losses incurred by PE of Indian company in Japan could be reduced from taxable income in India

4 November 2007
Proposals for possible inclusion in 2008 tax reform announced

4 November 2007
Japanese Supreme Court decision – Japanese parent company cannot deduct losses of Panamanian CFC

4 November 2007
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments

2 September 2007
New treaty between Australia and Japan – agreement on general terms

2 September 2007
Non-discrimination and group income elections

2 July 2007
Ministry of Finance releases triangular merger regulations

18 June 2007
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details

18 June 2007
Tokyo Court

28 May 2007
Revised Commentary on Article 7 of OECD Model released

28 May 2007
New case law on Japan-Singapore tax treaty and Japanese CFC provisions

28 May 2007
Treaty between United States and Japan – US court dismisses claims for relief for information exchanged under treaty

24 March 2007
Final Report on Improving the Resolution of Tax Treaty Disputes

24 March 2007
Tax reform proposals for 2007 – further details (withholding tax, corporate reorganizations, transfer pricing, tax havens, leasing, trusts)

24 March 2007
Treaty between Japan and Australia - negotiations

24 February 2007
Protocol to treaty between Japan and France signed

24 February 2007
Report on Attribution of Profits to PEs released

24 February 2007
Tax reform proposals for 2007

15 January 2007
Protocol to treaty between Japan and Philippines signed

15 January 2007
Treaty between Australia and Japan to be renegotiated

17 December 2006
Treaty between Japan and UK to enter into force

12 November 2006
Treaty between Pakistan and Japan to be signed

14 October 2006
Treaty negotiations between France and Japan finalized

12 September 2006
Treaty between United Arab Emirates and Japan – negotiations

13 August 2006
Protocol to treaty between Japan and Philippines – negotiations

13 August 2006
Treaty between Japan and Philippines – negotiations

14 June 2006
IRS releases list of qualified investment banks under MoU defining investment bank for interest withholding under 2003 Japan-US treaty

14 May 2006
Protocol between Japan and India signed

9 April 2006
Treaty between United Kingdom and Japan signed

16 March 2006
It has been reported that France will begin official negotiations with Japan on 25 January 2006 to revise the France-Japan income tax treaty of 3 March 1995. The main purpose of the revision is to encourage more bilateral investments by lowering the withholding tax rates which are currently fixed at 15% for dividends (5% for qualifying companies), 10% for interest and 10% for royalties

19 February 2006
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