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Q&A

What types of categories are tax treaties divided into?

What types of categories are tax treaties divided into?

The United Nations Conference on Trade and Development divides tax treaties into categories based on their applicability, primarily on their income, income and capita, protocol and transportation (air, water, or both). 

Q&A

What happens when investors are subject to two different tax systems?

What happens when investors are subject to two different tax systems?

Confusion about international taxation can arise when investors are subject to two different and potentially conflicting tax systems. For example, Hong Kong and Singapore adopt a “territorial source” principle of taxation, which means tha...

Q&A

What is Double Taxation Avoidance (DTA) ?

What is Double Taxation Avoidance (DTA) ?

Double Taxation avoidance agreements aim to prevent the same income from taxation by two or more states, while also eliminating tax evasion and encouraging cross-border trade efficiency.

Q&A

What are the taxes covered under the Double Taxation Agreement (DTA) between Chi...

What are the taxes covered under the Double Taxation Agreement (DTA) between Chi...

According to Article 2 of the DTA, the taxes covered are individual income tax (IIT) and corporate income tax (CIT) in China, income tax in singapore and according to Circular 75, these taxes can be levied directly by the government or withheld at so...

Q&A

Can an ?agent of independent status? operating on behalf of an enterprise of one...

Can an ?agent of independent status? operating on behalf of an enterprise of one...

According to the Article 5 of the DTA, an “agent of an independent status” acting in the ordinary course of their business will not be deemed to be a PE. Circular 75 provides that the activities of an agent should meet the below two crit...

Q&A

Will income derived by a resident of a Contracting State from immovable property...

Will income derived by a resident of a Contracting State from immovable property...

Will income derived by a resident of a Contracting State from immovable property situated in the other Contracting State be taxed in that other State (China and Singapore DTA Agreement)?

Q&A

In which case are the business profits of an enterprise in one Contracting State...

In which case are the business profits of an enterprise in one Contracting State...

According to Article 7 of the DTA, the profits of an enterprise of a Contracting State can be taxed in the other Contracting State when the enterprise carriers on business in the latter through a PE situated therein. In this case, the profits of the ...

Q&A

How will dividends paid by a company resident in a Contracting State to a reside...

How will dividends paid by a company resident in a Contracting State to a reside...

According to Article 10 of the DTA, if the beneficial owner of the dividends is a resident of the other Contracting State, the tax should not exceed: 5% of the gross amount of the dividends if the beneficial owner is a company (other than a partne...

Q&A

What is the situation in China for foreign companies wishing to obtain Double Ta...

What is the situation in China for foreign companies wishing to obtain Double Ta...

The determination of beneficial owner requires the disclosure of a good amount of business information, including information about the number of employees, information about revenue, and so on.  In addition, there is always the possibility tha...

Q&A

How is Corporate Income Tax (CIT) paid in India?

How is Corporate Income Tax (CIT) paid in India?

Income tax must be paid by all types of foreign-invested entities, except for liaison offices, which are not permitted to earn income. A tax return must be sent to the income tax authorities by September 30. In case of liaison offices, the foreign co...

Q&A

What taxes are applicable to companies in India, other than corporate income tax...

What taxes are applicable to companies in India, other than corporate income tax...

The applicable taxes would depend on the type of companies or the industry they are in: Companies that sell a product must file annual sales tax or submit their value-added tax returns. Companies located in states where professional tax registrat...

Q&A

How should a foreign-owned subsidiary bring money to India for expenses in its e...

How should a foreign-owned subsidiary bring money to India for expenses in its e...

Money should be brought to India through normal banking channels either as share capital or against service invoices. Many new entrants bring petty cash from outside India and use that cash for expenses in the subsidiary company. However, this violat...

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