Tag Archive
China – Clarifying When Secondment Creates Chinese Taxable Presence
On 19 April 2013, the State Administration of Taxation (SAT) of the People’s Republic of China (PRC) issued Announcement 19 to provide guidance on when cross-border secondments of expatriates by foreign enterprises into PRC may create a PRC taxable presence.1 Announcement 19 is a welcome development for multinational companies (MNCs) doing business in... »
Denmark: Government Presents Plans to Boost Economic and Job Growth
On 26 February 2013, the Danish government announced the anticipated growth and job stimulus package. The plan, which is entitled “Growth Plan DK” (“Vækstplan DK”)1, was presented by the government not as a mere plan, but as a three-track reform to meet what the government sees as the three main challenges facing Denmark: •... »
United Kingdom: Budget Legislation Promulgated with Royal Assent
The U.K. Finance Bill completed its stages through the House of Lords and received Royal Assent on 17 July 2012, thereby becoming the Finance Act 2012.1 Some of the important measures affecting individuals and their employers are highlighted below. • A new £50,000 Remittance Basis Charge (RBC) for non-U.K.-domiciled individuals who have been resident... »
Japan: New Reporting Requirement for Foreign Stock-Based Compensation
A new reporting requirement for foreign stock-based compensation was introduced in Japan under the 2012 tax reform. While it is the individual’s responsibility to report all taxable compensation, including stock-based compensation, on his or her tax return, a new regulation imposes on employers a new reporting requirement on the stock-based compensation. With the Japanese... »
India: Clarifications Issued for “Tourist Visa on Arrival” Scheme
India’s Ministry of Home Affairs (‘MHA’) has issued detailed guidelines on various aspects of the “Tourist Visa on Arrival” (‘TVOA’) scheme,1 which we highlight below. Background The TVOA scheme was introduced by India’s government in 2010. (For prior coverage, see the following issues of Flash International Executive Alert: 2010-107 (27 May 2010 and 2010-095... »
People’s Republic of China: Simplifying SAFE Registration of Share-Based Incentive Plans
The State Administration of Foreign Exchange (“SAFE”) of the People’s Republic of China (“PRC”) issued Hui Fa No. 7 (“Circular 7”) on 20 February 2012, to replace Hui Zong Fa No. 78 (“Circular 78”) and Hui Zong Fa No. 2 (“Circular 2”). The issuance of Circular 7 helps to clarify the... »
France: New Draft Corrective Finance Law
On 8 February 2012, the French government meeting in the Council of Ministers adopted a proposal for the Corrective Finance Law for 2012 (Projet de Loi de Finances rectificative pour 2012, or “PLFR”). The PLFR is to be submitted to the Parliament for debate and a vote. This draft law comes on the heels... »
United States: IRS Releases New Sec. 911-Related Housing Cost Limitations
On February 13, 2012, the U.S. Internal Revenue Service (IRS) released an advance copy of Notice 2012-19,1 which provides adjustments to the limitation on housing expenses for purposes of section 911 of the U.S. Internal Revenue Code (I.R.C.) for certain specified foreign locations with high housing costs relative to housing costs in the United... »
Russia and Social Security System Reforms
In December 2011, a new federal law1 introducing changes to the Russian social security system passed the final stage of approval. The new regulations, which came into force on 1 January 2012, expand the scope of individuals considered “insured individuals” and will impact the application and collection of insurance contributions to the state pension,... »
Malaysia: Public Ruling on Income for Foreigners Working in Malaysia
A public ruling (“PR”) from Malaysia’s tax authorities explains the tax treatment of employment income derived by foreign nationals exercising employment in Malaysia. What the PR Covers The PR covers the following: i. Introduction; ii. Interpretation; iii. Tax Treatment of Foreign Nationals Working in Malaysia; iv. Tax Treatment of Foreign Nationals from Treaty Counties... »


