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Tuesday, 14 October 14
THE NEW CHINESE TRANSPORTATION TAX LAW: WHAT DOES IT MEAN FOR GREEK SHIPPING? - DELOITTE
China has recently promulgated a new law which imposes tax on profits from freights of inbound routes. The objective of the new tax law titled “Provisional Measures on the Collection of Tax on Non-Resident Taxpayers Engaged in International Transportation Business” (Bulletin of the State Administration of Taxation 2014, No. 37) is to strengthen the tax administration of foreign companies operating international transportation business with China.
What has changed?
Until recently, China had only been taxing international outbound routes with an effective tax rate of 1.25% on the gross revenue. The new rules extend the scope of the tax to inbound routes, and increase the tax rate. As of August 1st, 2014, freights of non-resident shipping companies operating in international routes towards Chinese ports are expected to pay a new tax rate (Enterprise Income Tax – EIT) of 25% on profit. The tax is levied on freights on voyage charters and time charters.
How will the new tax be collected?
Currently there are three options for collection, however further clarification is expected:
1. Tax registration in China: Non-resident shipping companies will have to register with Chinese tax authorities and comply with local bookkeeping and tax rules. The tax at the rate of 25% will be levied on the declared net profit, or
2. Tax on deemed profit: where the enterprises are unable to calculate and report taxable income accurately, they can register and pay tax on a deemed profit. The profit rate cannot be less than 15% and the tax rate will be 25%. Therefore, for a freight of $100, it will be deemed that there is a $15 profit, for which a 25% tax will be due (therefore an effective tax rate of 3.75%), or
3. Have tax withheld by an agent: instead of registering with the Chinese authorities, a company can pay the tax at the rate of 25% on the assumed 15% profit, by having the tax withheld by the customer or other persons designated by the local tax authorities as withholding agents.
How does this impact Greek shipping?
The Double Taxation Agreement (“DTT”) and the Merchandise Franchise Agreement (“MFA”), which Greece and China have in place, protect Greek shipping companies or non-Greek shipping companies that are managed by Greek management offices by exempting them from any tax on freight transportation income in Chinese ports. It is important to note that the exemption is not automatic; once the Chinese authorities finalize the filing requirements, close attention shall need to be paid to the completion of necessary documentation in order to secure the exemption.
Additionally, the Greek Government is in the process of setting up further safeguards by amending laws related to tax residency certificates in order to ensure that the Greek shipping companies will be exempted from this new levy. In this case, the impact of the new law could only be compliance requirements and not actual tax costs. However, it is still unclear if the DTT and the MFA mentioned above and the submission of the necessary tax residency certificate will have the power to secure shipping companies exemption from this tax law. Deloitte is following closely any development and will keep its clients informed on any news.
Deloitte’s global shipping leader, George Cambanis, commented, “Provided the proposed amendments to the current Greek law enable management offices to obtain the tax residency certificates which would then exempt Greek shipping companies from this new Chinese tax law the only downside to Greek shipping would be the administrative cost of compliance.”
Source: Deloitte / Hellenic Shipping
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Wednesday, 19 November 14
SHIPPING MARKET INSIGHT - BY KATERINA RESTIS
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CHEAP OIL PRICES COULD RESHAPE GLOBAL OIL EXPORTING MAP - HELLENIC SHIPPING
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- Australian Coal Association
- Neyveli Lignite Corporation Ltd, - India
- Georgia Ports Authority, United States
- Petron Corporation, Philippines
- London Commodity Brokers - England
- Bukit Baiduri Energy - Indonesia
- Ind-Barath Power Infra Limited - India
- Central Electricity Authority - India
- Alfred C Toepfer International GmbH - Germany
- Energy Link Ltd, New Zealand
- Standard Chartered Bank - UAE
- Mercator Lines Limited - India
- Bhoruka Overseas - Indonesia
- India Bulls Power Limited - India
- Dong Bac Coal Mineral Investment Coporation - Vietnam
- Holcim Trading Pte Ltd - Singapore
- Africa Commodities Group - South Africa
- PowerSource Philippines DevCo
- Vedanta Resources Plc - India
- Cement Manufacturers Association - India
- Sojitz Corporation - Japan
- ASAPP Information Group - India
- SMC Global Power, Philippines
- Orica Australia Pty. Ltd.
- Kepco SPC Power Corporation, Philippines
- White Energy Company Limited
- International Coal Ventures Pvt Ltd - India
- Gujarat Sidhee Cement - India
- The State Trading Corporation of India Ltd
- Rashtriya Ispat Nigam Limited - India
- Posco Energy - South Korea
- Rio Tinto Coal - Australia
- Thiess Contractors Indonesia
- The University of Queensland
- Indika Energy - Indonesia
- Global Green Power PLC Corporation, Philippines
- AsiaOL BioFuels Corp., Philippines
- Wilmar Investment Holdings
- Maheswari Brothers Coal Limited - India
- Directorate General of MIneral and Coal - Indonesia
- Larsen & Toubro Limited - India
- Wood Mackenzie - Singapore
- Bahari Cakrawala Sebuku - Indonesia
- Makarim & Taira - Indonesia
- Indian Energy Exchange, India
- Jindal Steel & Power Ltd - India
- Commonwealth Bank - Australia
- Australian Commodity Traders Exchange
- Trasteel International SA, Italy
- Iligan Light & Power Inc, Philippines
- Merrill Lynch Commodities Europe
- Baramulti Group, Indonesia
- Siam City Cement PLC, Thailand
- PetroVietnam Power Coal Import and Supply Company
- Binh Thuan Hamico - Vietnam
- PNOC Exploration Corporation - Philippines
- Medco Energi Mining Internasional
- Petrochimia International Co. Ltd.- Taiwan
- Bukit Asam (Persero) Tbk - Indonesia
- Interocean Group of Companies - India
- Indonesian Coal Mining Association
- TNB Fuel Sdn Bhd - Malaysia
- Sinarmas Energy and Mining - Indonesia
- Bulk Trading Sa - Switzerland
- Thai Mozambique Logistica
- Attock Cement Pakistan Limited
- Formosa Plastics Group - Taiwan
- Tamil Nadu electricity Board
- Mjunction Services Limited - India
- SN Aboitiz Power Inc, Philippines
- Bhatia International Limited - India
- Chettinad Cement Corporation Ltd - India
- MS Steel International - UAE
- Filglen & Citicon Mining (HK) Ltd - Hong Kong
- IEA Clean Coal Centre - UK
- Coalindo Energy - Indonesia
- Energy Development Corp, Philippines
- Karaikal Port Pvt Ltd - India
- Minerals Council of Australia
- IHS Mccloskey Coal Group - USA
- Tata Chemicals Ltd - India
- Timah Investasi Mineral - Indoneisa
- CNBM International Corporation - China
- Mintek Dendrill Indonesia
- GN Power Mariveles Coal Plant, Philippines
- Agrawal Coal Company - India
- Barasentosa Lestari - Indonesia
- Lanco Infratech Ltd - India
- Straits Asia Resources Limited - Singapore
- Intertek Mineral Services - Indonesia
- Economic Council, Georgia
- ICICI Bank Limited - India
- Kapuas Tunggal Persada - Indonesia
- Sree Jayajothi Cements Limited - India
- Bank of Tokyo Mitsubishi UFJ Ltd
- Banpu Public Company Limited - Thailand
- Jaiprakash Power Ventures ltd
- Meralco Power Generation, Philippines
- Toyota Tsusho Corporation, Japan
- Kumho Petrochemical, South Korea
- Asmin Koalindo Tuhup - Indonesia
- Carbofer General Trading SA - India
- Heidelberg Cement - Germany
- Kalimantan Lumbung Energi - Indonesia
- Bhushan Steel Limited - India
- Independent Power Producers Association of India
- Kobexindo Tractors - Indoneisa
- Mercuria Energy - Indonesia
- Dr Ramakrishna Prasad Power Pvt Ltd - India
- Coal and Oil Company - UAE
- Price Waterhouse Coopers - Russia
- Power Finance Corporation Ltd., India
- Semirara Mining and Power Corporation, Philippines
- Kohat Cement Company Ltd. - Pakistan
- Metalloyd Limited - United Kingdom
- Chamber of Mines of South Africa
- Ministry of Mines - Canada
- SMG Consultants - Indonesia
- Malabar Cements Ltd - India
- Central Java Power - Indonesia
- Cigading International Bulk Terminal - Indonesia
- Bharathi Cement Corporation - India
- Essar Steel Hazira Ltd - India
- Ambuja Cements Ltd - India
- Karbindo Abesyapradhi - Indoneisa
- Oldendorff Carriers - Singapore
- Borneo Indobara - Indonesia
- Kaltim Prima Coal - Indonesia
- Jorong Barutama Greston.PT - Indonesia
- OPG Power Generation Pvt Ltd - India
- Ministry of Finance - Indonesia
- Deloitte Consulting - India
- Indo Tambangraya Megah - Indonesia
- Parliament of New Zealand
- Anglo American - United Kingdom
- CIMB Investment Bank - Malaysia
- Renaissance Capital - South Africa
- GMR Energy Limited - India
- Videocon Industries ltd - India
- Kartika Selabumi Mining - Indonesia
- Eastern Energy - Thailand
- Gujarat Mineral Development Corp Ltd - India
- Edison Trading Spa - Italy
- Bayan Resources Tbk. - Indonesia
- Uttam Galva Steels Limited - India
- Salva Resources Pvt Ltd - India
- Sarangani Energy Corporation, Philippines
- Ministry of Transport, Egypt
- Sakthi Sugars Limited - India
- Dalmia Cement Bharat India
- Grasim Industreis Ltd - India
- Savvy Resources Ltd - HongKong
- Krishnapatnam Port Company Ltd. - India
- Globalindo Alam Lestari - Indonesia
- Truba Alam Manunggal Engineering.Tbk - Indonesia
- Global Business Power Corporation, Philippines
- New Zealand Coal & Carbon
- Aditya Birla Group - India
- Gujarat Electricity Regulatory Commission - India
- Directorate Of Revenue Intelligence - India
- VISA Power Limited - India
- GVK Power & Infra Limited - India
- Samtan Co., Ltd - South Korea
- Miang Besar Coal Terminal - Indonesia
- Semirara Mining Corp, Philippines
- Maharashtra Electricity Regulatory Commission - India
- Singapore Mercantile Exchange
- Xindia Steels Limited - India
- Kideco Jaya Agung - Indonesia
- Vizag Seaport Private Limited - India
- Sindya Power Generating Company Private Ltd
- European Bulk Services B.V. - Netherlands
- Pipit Mutiara Jaya. PT, Indonesia
- GAC Shipping (India) Pvt Ltd
- Riau Bara Harum - Indonesia
- Siam City Cement - Thailand
- Aboitiz Power Corporation - Philippines
- Bangladesh Power Developement Board
- Simpson Spence & Young - Indonesia
- Billiton Holdings Pty Ltd - Australia
- Global Coal Blending Company Limited - Australia
- Electricity Generating Authority of Thailand
- The Treasury - Australian Government
- Eastern Coal Council - USA
- Vijayanagar Sugar Pvt Ltd - India
- Sical Logistics Limited - India
- Marubeni Corporation - India
- Orica Mining Services - Indonesia
- McConnell Dowell - Australia
- Asia Pacific Energy Resources Ventures Inc, Philippines
- Port Waratah Coal Services - Australia
- Meenaskhi Energy Private Limited - India
- TeaM Sual Corporation - Philippines
- Pendopo Energi Batubara - Indonesia
- South Luzon Thermal Energy Corporation
- Bukit Makmur.PT - Indonesia
- Goldman Sachs - Singapore
- Star Paper Mills Limited - India
- Romanian Commodities Exchange
- PTC India Limited - India
- LBH Netherlands Bv - Netherlands
- Offshore Bulk Terminal Pte Ltd, Singapore
- Planning Commission, India
- San Jose City I Power Corp, Philippines
- Altura Mining Limited, Indonesia
- Therma Luzon, Inc, Philippines
- Electricity Authority, New Zealand
- Leighton Contractors Pty Ltd - Australia
- Coastal Gujarat Power Limited - India
- Parry Sugars Refinery, India
- Manunggal Multi Energi - Indonesia
- Ceylon Electricity Board - Sri Lanka
- Latin American Coal - Colombia
- Madhucon Powers Ltd - India
- Indogreen Group - Indonesia
- Antam Resourcindo - Indonesia
- Indian Oil Corporation Limited
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