Vietnam_ Free trade zone

 Vietnam has signed 17 bilateral or multilateral free trade agreements, including the Comprehensive and Progressive Agreement for Trans-Pacific Partnership and Regional Comprehensive Economic Partnership Agreement, plus pacts with the European Union, Japan and South Korea. It has no free trade deal with the United States.

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TP_ Benchmark_ Mexico

 S - Changes to the mark-up percentages that are identified in this email based on further work with PWC?  Or, do these percentages still stand?  We expect that this should reconcile to the trial balance. O- The CIP write off and the success fee expense did not move the markup %'s after PwC recommended adjustments. However, there is one small amounts  related to regular fixed asset disposal operation that can slightly reduce the %'s.  S- Do you have the new #s now, or are they still in process?  If still in process, do you have an idea on timing? O- However, to be consistent with prior years where these same fixed assets disposals were not included in the markup % for the TP Study, I have not included them this year for the TP Study either.  I reported yesterday 4.58% for Mfg vs 4.44% that yo can see in the chart S-  Will these totals tie to the financial statements?  Do you expect any other changes at this point?(I would guess you are going ...
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Pillar 2

Concept:  The Pillar 2 rules generally apply to MNEs with consolidated group revenues of €750 million or more in at least two of the preceding four fiscal years.     In essence, Pillar 2 creates a global minimum tax safety net, ensuring that even if an MNE's income is taxed at a low rate in one jurisdiction, other jurisdictions can apply these rules to collect additional tax and bring the overall effective tax rate on that income up to the 15% minimum. This requires complex calculations of effective tax rates on a jurisdictional basis, often differing from traditional financial accounting or local tax calculations   For a branch of a US company in Singapore, Australia, Timor-Leste, Papua New Guinea, and Japan, the applicable description for Pillar 2 related tax returns, based on the provided options and general tax principles, would be as follows: (A) A place of business (including a deemed place of business) situated in a jurisdiction and treated as a permanent es...
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Treaty analysis _ Germany & Thailand _ Technical services rendered by Thailand people in Germany

Q- What is tax implications for technical services performed by Thailand people in Germany? Duration of the work; 2-3 months, US entity is a benefiting entity from this work. US entity and Thailand entity are related parties and Thai company will invoice for their people's work in Germany to the US company.  1. German Withholding Tax (WHT) or Corporate Tax Exposure Even though the Thai company invoices a US entity, German tax authorities may tax the income earned from activities physically performed in Germany. • If the Thai company has a taxable presence (“permanent establishment” or PE) in Germany due to its employees working there for 2–3 months, Germany may tax the income attributable to that PE. • The presence of employees physically performing services in Germany, even temporarily, can trigger a PE under German law if: • There is a fixed place of business (e.g. office, project site); or • The work involves a “service PE”, potentially triggered under Germany–Th...
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