Dbriefs Asia Pacific Tax Webcasts
Anticipating tomorrow's complex issues and new strategies is a challenge. Reach new heights with Dbriefs that give you valuable insights on important developments affecting your business in Asia Pacific
Recent Tax Developments Impacting the Funds Industry in China and Hong Kong: Navigating the Uncertainties
7 May, 2:00 – 3:00 PM HKT (GMT +8)
Host: Patrick Yip
Speakers: Agnes Cheung, Johnny Foun, and Natalie Yu
There are various tax developments in China and Hong Kong that would positively, or adversely, impact the funds industry. For example, the State Administration of Taxation's (SAT) clarifications on China enterprise income tax treatment of gains on the disposal of A-shares and / or other equities invested through the Hong Kong-Shanghai Stock Connect and QFIIs / RQFIIs, and the latest developments on the Financial Secretary's proposal to expand the scope of profits tax exemption to cover offshore private equity funds in Hong Kong. What are the key insights to consider when navigating the uncertainties of these changes? We'll discuss:
- Our views on the commonly asked questions on the PRC tax treatment of gains on
A-shares or other equities invested through the Hong Kong-Shanghai Stock Connect and QFIIs / RQFIIs.
- Latest updates on the proposed new offshore funds law.
- What the funds industry expects to see in 2015 and how to prepare for the changes.
Gain insights into the latest developments on the funds industry in China and Hong Kong.
Debt Push Down: Focus on Australia and New Zealand
12 May, 11:00 AM – 12:00 PM HKT (GMT +8)
Host: Danny Po
Presenters: Hadleigh Brock and Jeffrey Jaw
It has always been a challenge for investors to obtain tax deductions on financing costs incurred in connection with M&A. In the previous quarters, we illustrated case studies in China, Hong Kong, India, Japan, Korea, and various regions of Southeast Asia. In this quarter, we will continue the discussion of this topic with a focus on Australia and New Zealand. We'll discuss:
- Basic and special debt push down techniques in Australia and New Zealand.
- Illustrative case studies in Australia and New Zealand applying these techniques; considering how to align interest expense with taxable operating income, taking into account cross-border transfer pricing considerations and beneficial ownership requirements.
- Other local country specific tax structuring issues / opportunities in relation to debt structuring.
Understand the techniques and challenges on debt push down that might affect your M&A deals.
Industries – Financial Services
Changing Landscape for Financial Service Industry (FSI) Treasury: Liquidity, Funds Transfer Pricing (FTP), and BEPS
19 May, 2:00 – 3:00 PM HKT (GMT +8)
Host: Carl Church
Presenters: Anis Chakravarty, Geoff Gill, Samuel Gordon, and Wei Shu
The FSI treasury requirements have been changing rapidly since the financial crisis and the pronouncement of Basel III. With the release of the OECD Public Discussion Draft on BEPS Action 4 (Interest Deductions and Other Financial Payments) and the expectation of OECD guidance on the transfer pricing of intercompany treasury transactions, FSI multinational corporations expect even more changes. Where is it all headed in Asia Pacific and what are the implications to be aware of in the region? We'll discuss:
- Tax consideration for Basel III driven Liquidity and FTP.
- Existing tax environment in the region.
- The implications of the BEPS guidance.
- The road forward in the region.
Gain insights into these developments across Asia Pacific and discover how they impact the financial services firms.
Global Mobility in India: Latest Trends in Tax, Social Security, and Immigration for Mobile Employees and Employers
21 May, 2:00 – 3:00 PM HKT (GMT +8)
Host: Divya Baweja
Presenters: Tapati Ghose and Sudhakar Sethuraman
Over recent years, India has become an increasingly attractive market for businesses looking to increase their global markets when growth in their existing markets has started to decline. At the same time, the economic development of Indian businesses has seen them looking outside India for business opportunities. For foreign businesses trying to enter the India market or for Indian businesses trying to gain prospects overseas, an important component will be the mobility of employees moving into and out of India. What are the tax, social security, and immigration issues impacting businesses that have mobile employees coming to or leaving India to work? We'll discuss:
- Highlights from the 2015 Indian Budget – what are the impacts likely to be upon employees and employers.
- Examine year end considerations including procedural changes for employer filings and individual tax returns.
- Recent updates on important decisions and notifications in the areas of tax, social security, and immigration.
Stay up to date with the latest trends in global mobility with a focus in India.
Business Model Optimization (BMO): Opportunities Following a Merger and Acquisition
28 May, 2:00 – 3:00 PM HKT (GMT +8)
Host: Tom Ewigleben
Presenters: Neil Pereira, Danny Po, and Sharfudeen Shamsudeen
The best possible merger not only depends on identifying the right target company, but also on successful integration of the two businesses after the deal closes. Often, synergies and efficiencies gained by integrating the two business models drive a significant amount of ongoing value generated by the deal. While operational efficiencies and cost reductions are typically the main focus of business model integration efforts, taxes should also be a key component of integration activities and will invariably contribute to, or detract from, the benefits promised to shareholders and analysts. It is therefore critical that both direct and indirect tax impacts be fully considered and planned as part of the post-merger operation model integration. What are the BMO considerations and opportunities generated by M&A transactions? We'll discuss:
- How to assess tax impact and balance tax planning with operating model integration.
- Direct and indirect tax considerations and opportunities around integration of business models.
- Tax alignment of business models to be combined and integrated.
- How to manage cultural and change management issues.
Gain new perspectives on factors that should be considered based on our practical experience from assisting clients with integrating acquired operations.
Base Erosion and Profit Shifting (BEPS): What's Happened So Far? And What's Next?
2 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Steve Towers
Presenters: Anis Chakravarty, Leonard Khaw, Alan Shapiro, and David Watkins
The BEPS project is the most significant event on the international tax stage for 50 years. Since its official launch by the OECD and G20 in July 2013, what have been the key developments, both globally and in Asia Pacific? And what has happened in the last six months? We'll discuss:
- The current status of the September 2014 "deliverables".
- Important transfer pricing developments in the last six months.
– New discussion drafts (and related public consultation)
- Use of profit splits in global value chains
- Cross-border commodity transactions
- Intra-group low value adding services
- Revisions to chapter I of the OECD's Transfer Pricing Guidelines (including the "real deal", risk, recharacterization, and special measures)
- Cost contribution arrangements
- Intangibles (ownership and "hard to value" intangibles)
– Country-by-country reporting: implementation rules
- Other important developments in the last six months.
– New discussion drafts (and related public consultation)
* Interest deductions
* CFC rules
* VAT / GST
* Dispute resolution
– Public consultation
* Treaty abuse
* PE status
– Agreed mandate for negotiation of the multilateral instrument
- Updated "BEPS scorecard" for Asia Pacific countries: current legislative position, perspectives of governments and the public, and unilateral BEPS actions.
- The (expected) way forward.
Find out the current position on this very important international tax initiative.
Cross-border Digital Services: A Brave New World for Indirect Tax?
4 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Robert Tsang
Presenters: Hong Seok Han, Chikara Okada, Jun Takahara, and Robert Tsang
Following the release of the draft OECD International VAT / GST B2C Guidelines in December 2014 for consultation, a number of countries in Asia Pacific are gearing up to introduce new rules to tax inbound digital services. How are VAT and GST rules likely to evolve and change in the region? We'll discuss:
- How do these rules work – a spotlight on Japan and Korea.
- Can a non-resident supplier really be subject to consumption tax, GST or VAT obligations?
- What would this mean for direct tax or business tax purposes?
Understand more about how the VAT / GST rules are shaping across the region and how it may affect your business.
Goods and Services Tax (GST) in India: What's in Store for the Services Sector?
9 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Prashant Deshpande
Presenters: L Sayee Mohan and Krupa Venkatesh
In the 2015 India Budget presented on 28 February, there has been a reaffirmation that GST will be introduced with effect from 1 April 2016. An introduction of a national level GST is aimed at subsuming the majority of the existing indirect taxes. In view of the development and progression towards GST, what are the important factors businesses have to be aware of? We'll discuss:
- Background and overview of India's GST introduction.
- Latest news on the structure of GST and the rates and methodology.
- Highlights of the indirect tax implications to the services sector, which comprises of almost 59% of India's GDP.
- Emerging impacts and concerns from the services sector.
Tune in to learn more on the introduction of GST in India and what businesses should be doing to prepare for it.
China's Hottest Tax Developments: Latest Tax Rules, BEPS, VAT Reform, and Taxpayer Rights
11 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Hong Ye
Speakers: Nora Fu, Candy Tang, Aaron Wang, and Natalie Yu
Over the past six months, the SAT has issued a number of important rules to further strengthen China's tax base, particularly in the areas of disposing of investments in China and transfer pricing. The VAT reform has entered into the final phase and the reform of the tax collection law is underway, and this will cause profound impacts on taxpayer rights. What are the key developments in China's tax landscape you need to be aware of? We'll discuss:
- How Bulletin 7, the rule concerning the indirect transfer of Chinese taxable assets, is being applied in practice.
- How cities vary in applying Bulletin 79 on the income of QFIIs / RQFIIs arising from the period before 17 November 2014.
- Expected key transfer pricing changes, in particular, the application of location specific advantages, and the greater use of profit split methods.
- Tax cases in the era of BEPS.
- The continuing VAT reform, which is expected to conclude by 2015, to cover financial services, construction, real estate, and consumption related services.
- Reform of the tax collection law and debates on certain key issues affecting taxpayer rights and administrative procedures.
Stay tuned to the latest developments on these hottest topics and how to prepare for the changes.
(Tune in to the Putonghua version of this webcast on 24 June at 11:00 AM – 12:00 PM HKT (GMT +8). Please visit Chinese language webcasts page for program details.)
Annual Review: Double Tax Treaty Update and OECD / UN Developments
18 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: David Watkins
Presenters: Claudio Cimetta, Jun Takahara, and Vicky Wang
We will review the important new double tax treaties in Asia Pacific, major case law and administrative developments concerning the interpretation of double tax treaties, and significant OECD / UN developments relating to double tax treaties and other international tax topics. We'll discuss:
- New double tax treaties signed or ratified by key Asia Pacific countries.
- Important cases on treaty interpretation.
- Updates to the OECD Commentary, including in respect of "beneficial owner".
- Developments affecting the UN model treaty.
Learn about the important developments in the last 12 months in regard to double tax treaties and OECD / UN projects.
Malaysian Post-GST Evaluation: Have You Achieved the "Pass" Grade?
25 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Robert Tsang
Presenters: Senthuran Elalingam, Bruce Hamilton, and Eng Yew Tan
The implementation of the Malaysian GST has come and gone. What are the latest updates and how have businesses, industries, and Customs coped? Has your business passed the GST test? We'll discuss:
- Latest updates on evolution and change in the GST law and practice – post 1 April 2015, through the end of calendar 2015, and beyond.
- Price control and anti-profiteering – what is the latest news from the Ministry of Domestic Trade and Customs?
- Latest protocols and procedures for securing rulings, dealing with appeals, and Tribunal processes.
- Compliance do's and don'ts – what are the key learnings so far? What are the issues and common mistakes to avoid, and good practices to follow?
Tune in to learn all the many complexities of this new tax implementation and find out what your business needs to do beyond the go-live in April 2015.
Market Characteristics or Intangibles: An Analytical Framework
30 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Arindam Mitra
Presenters: Anis Chakravarty, Eunice Kuo, and Stuart Simons
The OECD recognizes that comparability issues can arise in connection with consideration of local market advantages or disadvantages that may or may not directly relate to location savings. It requires conditions such as geographic market in which products are manufactured or sold, the purchasing power and product preferences of households in that market, growth characteristics of the market, the nature and degree of competition, etc., to be analyzed for assessing comparability. These local market conditions are not intangibles. However, it cautions that contractual rights, government licenses, or know-how to exploit a particular market may be intangibles. We'll discuss:
- The views of China and India on this important area.
- Practical issues faced in differentiating between local market conditions and intangibles.
- What taxpayers can do to best navigate this dichotomy.
Gain insights from an in-depth discussion and explore the distinction between market characteristics and intangibles.
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