Japan Tax News

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Treaty between Australia and Japan – details

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OECD released discussion draft on transactional profit methods

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Tax reform proposals for year 2008

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Treaty between Japan and United Kingdom (1969) – Japan's NTA uncovers treaty-shopping scheme

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New treaty between Japan and Pakistan – details

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Protocol to treaty between France and Japan enters into force – details

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Amending protocol between Japan and France enters into force

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Proposals for possible inclusion in 2008 tax reform announced

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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

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Amending protocol to France-Japan treaty ratified

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

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New treaty between Australia and Japan – agreement on general terms

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

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Non-discrimination and group income elections

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

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Ministry of Finance releases triangular merger regulations

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Revised Commentary on Article 7 of OECD Model released

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

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Tokyo Court

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Final Report on Improving the Resolution of Tax Treaty Disputes

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

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

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Report on Attribution of Profits to PEs released

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Protocol to treaty between Japan and France signed

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Treaty between Japan and Australia - negotiations

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Protocol to treaty between Japan and Philippines signed

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Tax reform proposals for 2007

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Treaty between Australia and Japan to be renegotiated

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Treaty between Japan and UK to enter into force

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Treaty between Pakistan and Japan to be signed

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