October 20, 2022

Asia Tax Bulletin – Autumn 2022


This edition of the Asia Tax Bulletin contains a host of topics on tax matters which took place in Southeast Asia, the PRC, India, Japan and Korea during the past few months, including:

  • Multilateral Tax Treaty (MLI) has now entered into force for both the PRC and Hong Kong and consequently their double tax treaties covered by the MLI are now subject to the agreed MLI anti-avoidance provisions. Does MLI affect holding structures such as Hong Kong holding companies which do not have a strong business purpose?
  • Hong Kong has enacted new tax facilities for ship agents, ship brokers and ship managers in Hong Kong. 
  • Korean tax reform proposals announced recently, which will be scheduled to take effect on 1 January 2023. The proposed changes will reduce the corporate tax rate, facilitate the possibility for Korean companies to earn tax exempt foreign dividend income, and enhance the ability to claim foreign tax credits. 
  • Malaysia has issued the exemption orders which stipulate the condition that foreign income remitted to Malaysia will be taxable. There is however an exception when it concerns dividends paid by a foreign company based in a country whose headline income tax rate is at least 15 percent. 
  • Thailand, which has now signed up to the multilateral treaty to exchange financial account information (CRS).

These and other news items are discussed in this edition of the Bulletin. 

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