Japan

CFC regime, Global miniumum tax, GloBE, Japan

(Nishimura & Asahi (Tokyo))/ /Leave a comment

Some OECD officials have reportedly noted that countries should consider changing or eliminating potentially duplicative anti-avoidance measures, such as CFC legislation when they implement the 15% global minimum tax rules (or the so-called GloBE rules proposed by the OECD).[1] This blog will overview the German approach, which seems in line with this view, and the…

Argentina, DTA, Japan, Royalties

(Director of International Tax Relations, Argentine Ministry of Economy ) and (International Tax Manager at Greentube GmbH and Tax Lecturer at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business)/ /Leave a comment

i.        The problematic In June 2019, the Japanese and Argentine governments signed a Double Tax Convention for the Elimination of Double Taxation on Income Taxes and the Prevention of Tax Evasion and Avoidance (hereinafter Argentina-Japan DTA).[1] Although the goal of this international instrument, like all double tax treaties, is to generate an environment conducive to…