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tax notes international - Tuck School of Business - Dartmouth College

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‘‘We cannot distribute cash to the people. What we<br />

can do is give targeted <strong>tax</strong> cuts to garment factories<br />

and spend more on infrastructure so we can prepare<br />

for economic developments in the future,’’ Hang<br />

Chuon Naron, secretary-general <strong>of</strong> the Ministry <strong>of</strong><br />

Economy and Finance, said in a January 23 interview<br />

with Bloomberg.com.<br />

Despite its problems, Cambodia has experienced<br />

four straight years <strong>of</strong> growth above 10 percent. This<br />

growth has stemmed largely from special deals for foreign<br />

firms, such as <strong>tax</strong> holidays and greatly reduced<br />

import tariffs.<br />

Furthermore, 60 percent <strong>of</strong> that growth has arisen<br />

from just three sectors: tourism, construction, and garment<br />

manufacturing, with the latter accounting for 12<br />

percent <strong>of</strong> GDP in 2007. However, weakening demand<br />

in crucial retail markets like the United States, which<br />

receives 70 percent <strong>of</strong> Cambodia’s textile exports, has<br />

forced Cambodia to close 10 percent <strong>of</strong> its garment<br />

factories, triggering the loss <strong>of</strong> 20,000 jobs, according<br />

to Roger Tan <strong>of</strong> the Garment Manufacturer’s Association<br />

<strong>of</strong> Cambodia.<br />

Hang Chuon Naron anticipates a drop in garment<br />

exports <strong>of</strong> 2 percent. He also foresees a 20 percent<br />

drop in the number <strong>of</strong> tourists visiting Cambodia and<br />

the virtual collapse <strong>of</strong> the construction sector. He<br />

hopes the <strong>tax</strong> breaks will keep businesses afloat<br />

through the difficult times.<br />

The IMF has predicted that Cambodia will grow at<br />

a rate <strong>of</strong> 4.75 percent in 2009, the slowest pace since<br />

1998.<br />

Chile<br />

♦ Randall Jackson, Tax Analysts.<br />

E-mail: rjackson@<strong>tax</strong>.org<br />

Stimulus Package Wins Unanimous<br />

Approval<br />

The Chilean Senate on January 14 unanimously approved<br />

a $4 billion economic stimulus plan presented<br />

by President Michelle Bachelet on January 5. (For<br />

prior coverage, see Tax Notes Int’l, Jan. 19, 2009, p. 212,<br />

Doc 2009-349, or2009 WTD 5-3.)<br />

The plan, which was unanimously approved by the<br />

Chamber <strong>of</strong> Deputies on January 8, still must be<br />

signed by Bachelet, a formality that Finance Minister<br />

Andrés Velasco said would soon be addressed.<br />

Tax measures in the plan include the temporary<br />

elimination <strong>of</strong> the stamp <strong>tax</strong>, a reduction in the<br />

monthly advance <strong>tax</strong> payments made by businesses<br />

(expected to take effect as early as this month), and<br />

provisions to accelerate income <strong>tax</strong> refunds for the<br />

2010 <strong>tax</strong> year and to accelerate the <strong>tax</strong> credit available<br />

for some training costs.<br />

Velasco called the package ‘‘important and urgent’’<br />

and expressed gratitude for the political consensus that<br />

led to the approval <strong>of</strong> the package in a unanimous and<br />

expedited manner.<br />

China (P.R.C.)<br />

CHINA (P.R.C.)<br />

♦ Lisa M. Nadal, Tax Analysts.<br />

E-mail: lnadal@<strong>tax</strong>.org<br />

U.S. Companies Facing Compliance<br />

Burdens in China<br />

U.S. companies with operations in the People’s Republic<br />

<strong>of</strong> China now face much more significant <strong>tax</strong><br />

compliance obligations, according to panelists on a<br />

January 15 PricewaterhouseCoopers International Tax<br />

Services webcast.<br />

The P.R.C. government last year introduced a new<br />

annual enterprise income <strong>tax</strong> return package, new<br />

related-party transaction (RPT) forms, and new contemporaneous<br />

transfer pricing documentation requirements.<br />

The new EIT return package and the new transfer<br />

pricing disclosure rules are very complex, PwC <strong>tax</strong><br />

partner Todd Landau said. ‘‘It is always a common<br />

experience with respect to China that there’s only some<br />

<strong>of</strong> what we need to know that is known today, with<br />

additional information that will clearly need to be<br />

known as time progresses throughout the period prior<br />

to deadlines’’ for the filing <strong>of</strong> returns and the submission<br />

<strong>of</strong> contemporaneous transfer pricing documentation,<br />

he said.<br />

For example, the State Administration <strong>of</strong> Taxation<br />

(SAT) released guidance on the EIT return, plus 45<br />

pages <strong>of</strong> explanatory <strong>notes</strong>, late in 2008, PwC <strong>tax</strong> partner<br />

Michael Ho said. But those <strong>notes</strong> are no longer<br />

valid because a new set <strong>of</strong> <strong>notes</strong> (Guo Shui Han [2008]<br />

No. 1081) released on January 7 has superseded them.<br />

This has left many companies struggling to keep up.<br />

Background<br />

The SAT on October 30, 2008, issued a new annual<br />

EIT return package (Guo Shui Fa [2008] No. 101) for<br />

use by <strong>tax</strong>payers that must file returns under the EIT<br />

law that took effect on January 1, 2008. The return<br />

package includes a main return and 15 schedules, all <strong>of</strong><br />

which must be filed by May 31. (For prior coverage,<br />

see Tax Notes Int’l, Dec. 22, 2008, p. 945, Doc 2008-<br />

24993, or2008 WTD 247-14.)<br />

TAX NOTES INTERNATIONAL FEBRUARY 2, 2009 • 389<br />

(C) Tax Analysts 2009. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.

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