The Dutch government released its Budget 2013, containing the Tax Plan 2013 which includes certain amendments to Dutch tax law. The government will discuss the plans the coming weeks in parliament. Further to these discussions, some elements of the Tax Plan may change. Most proposals will become effective on 1 January 2013. The Tax Plan 2013 contains the 2013 Bill (The Bill). The amendments included in The Bill are additions to the amendments to Dutch tax law already adopted by the Senate in July 2012.

The Tax Laws Amendment (Cross-Border Transfer Pricing) Act (No. 1) 2012, which contains new domestic transfer pricing laws, has received Royal Assent.

The new law represents stage one of transfer pricing law amendments and is highly controversial in that it introduces retrospective tax legislation. This is a consequence of recent Court decisions that have negatively impacted some of the Government's long-held views on domestic transfer pricing law.

Most people view Australia as an incredibly tough jurisdiction for tax planning for both residents and non-residents. Yet, surprisingly, Australia has many benign tax rules. For example, expatriates can live in Australia full-time without paying any tax on their investment income, and there has been relaxation of tax rules that have restricted foreign investments by Australian residents. This paper will explain the current status of tax rules in Australia that will affect residents and non-residents.

This is the August / September 2012 edition of China Tax Monthly.

This is the September 2012 edition of the Paris Tax Newsletter.

This is the September 2012 issue of the European Tax Newsletter.

This second edition covers key tax matters and developments in Australia, China, India, Japan, Singapore, Taiwan, Thailand and Vietnam.

A new streamlined filing compliance procedure (Non-Resident US Taxpayer Disclosure Program) is available for non-resident US taxpayers, including dual citizens, who have not previously filed US income tax and information returns and who owe less than USD1,500 in US federal income tax for each of the last three tax years. The new program entered into effect on 1 September 2012. On 31 August 2012, the US Internal Revenue Service (IRS) published instructions for the new program.

Following announcements earlier this year, the Government has issued draft legislation for public consultation proposing to reduce the final withholding tax rate for certain managed investment trusts (MITs) from 15% to 10%. This will apply to circumstances, where the MIT owns newly constructed energy efficient/environmentally sustainable commercial buildings. This change, when enacted, will be relevant not only to proposed MITs, but to all developers and property owners seeking to develop property. It now makes the development of energy efficient/environmentally sustainable commercial buildings a more attractive proposition owing to such buildings' attractiveness to MIT purchasers by virtue of the tax saving the MIT will be entitled to.

Focusing on two recently published model intergovernmental agreements (IGAs) and their impact on the implementation of FATCA, this client alert offers an in-depth analysis of the two models, including similarities and differences between the IGAs and the FATCA regulations proposed in February 2012.

This is the August issue of the Tax News and Developments newsletter.

Tax litigation (along with most other types of litigation) is expensive, time consuming and uncertain for all concerned. Generally, it is in everyone's interest to settle: litigation should be the last option that is only pursued if there are no acceptable alternatives. Unfortunately, recent negative publicity from certain high-profile tax cases may result in the UK tax authorities (HMRC) being less inclined to settle; which makes it even more important for taxpayers to seek advice on the best options available to them, including, where appropriate, the use of alternative dispute resolution.

The Standing Committee of the State Council announced on the afternoon of 25 July 2012 that the Shanghai VAT pilot program will be extended to ten cities/provinces including Beijing, Tianjin, Jiangsu, Zhejiang, Anhui, Fujian, Hubei, Guangdong, Xiamen and Shenzhen by the end of 2012.

In a new consultative document "Lifting the Lid on Tax Avoidance Schemes", the UK tax authorities (HMRC) outline how they plan to reduce tax avoidance. If the proposals are enacted, there could be implications for companies as well as individuals.

On 19 July 2012, the Court of Justice of the European Union (ECJ) delivered its judgment on the Deutsche Bank case (case C-44/11), confirming that discretionary fund management services for individuals (DFM services) are one single supply of a service which is VAT taxable.