Hailed as a significant improvement, the new FIP rules fail to directly address the taxation of foreign partners. Many FIP tax issues remain outstanding pending the release of official rules. China increases information exchange to prevent tax avoidance. Page 1

Transfer Pricing

India enacted a separate code on transfer pricing to cover intra-group cross-border transactions. The applicable regulations describe the various transfer pricing methods, impose extensive annual transfer pricing documentation requirements and contain harsh penal provisions for non-compliance. Page 1

Tax Treaty & Beneficial Owner

China issues guidance on when a person will qualify as a beneficial owner so they can enjoy preferential withholding rates. Page 3

Tax Treaty & Nonresidents

China has clarified when nonresidents may benefit from tax treaties. Page 5

Tax Function – A Prospective from Singapore

In considering the structure of a tax strategy, it is important to cover all aspects of the tax function and its responsibilities. The tax function should have a well-defined tax operating model where roles, responsibilities, reporting lines, competencies and performance management metrics are defined. Page 9