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Perspectives

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

Special Edition Webcasts

India Spotlight
Income Computation and Disclosure Standards (ICDS): What Will be the Impact on Your Tax Outgo?

3 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Rajesh Srinivasan
Presenters: Vijay Dhingra, Harsha Rawal, and Sunil Shah

Recently, the Central Board of Direct Taxes (CBDT) has issued Income Computation and Disclosure Standards (ICDS) which will come into effect from 1 April 2015, and apply accordingly for assessment year 2016-2017 onwards. Ten ICDS have been issued in a wide range of areas encompassing accounting policies, inventories, revenue recognition, tangible fixed assets, and effect of changes in foreign exchange rates amongst others. These have far-reaching impact on the tax computation, deferred tax, and Minimum Alternative Tax (MAT) credits. What is the key impact on tax positions that arises out of ICDS? We'll discuss:

  • Effect of ICDS implementation – ICDS mandatory? Impact of ICDS on Act? Impact of ICDS on past judicial precedents?
  • Impact assessment on tax positions and effective tax rate.
  • Specific issues arising from ICDS and practical tips on further evaluations.
  • The way forward to manage the impacts of ICDS.

Stay up to date on the latest developments in ICDS and discover what they could mean for your organization.

International Tax
BEPS Action 7: Revised Discussion Draft on PE Status (and Related Unilateral Measures in the UK and Australia on "Diverted Profits")

10 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Steve Towers
Presenters: Leonard Khaw, Ben Pickford, and David Watkins

On 15 May 2015, the OECD released a revised discussion draft (RDD) on Action 7 (the artificial avoidance of PE status). The RDD provides specific recommendations for changes to Article 5 of the OECD model double tax treaty. These recommendations have been selected from the range of options which the OECD released in late 2014. Also relevant to the avoidance of PE status are two recent examples of unilateral actions: the UK's Diverted Profits Tax (DPT) and Australia's Multinational Anti-Avoidance Law (MAAL). Both the DPT and the MAAL address some of the same issues as the RDD recommendations. In this webcast, we'll discuss:

  • The RDD's specific recommendations in regard to:
        – Dependent agent PE: Article 5(5) & (6)
        – Exceptions from PE status: Article 5(4)
        – Splitting-up of contracts: Article 5(3)
        – Calculating the profits attributable to PEs: Article 7
  • Proposed revisions to the OECD Commentary on Article 5.
  • The UK's DPT and Australia's MAAL: how these two unilateral law changes apply to structures which avoid PE status.

Upcoming Webcasts

M&A Tax
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.

International Tax
Base Erosion and Profit Shifting (BEPS): What's Happened So Far? And What's Next? (Part 1: Transfer Pricing)

2 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Steve Towers
Presenters: Anis Chakravarty and Alan Shapiro

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?

In this Part 1 webcast, we'll focus on the important transfer pricing developments in the last six months:

  • Revisions to chapter I of the OECD's Transfer Pricing Guidelines
  • Intangibles (ownership and "hard to value" intangibles)
  • Special measures
  • Use of profit splits in global value chains
  • Cross-border commodity transactions  
  • Intra-group low value adding services  
  • Cost contribution arrangements  
  • Country-by-country reporting: implementation rules
  • The (expected) way forward

The Part 2 webcast (which will cover the non-transfer pricing developments) is scheduled for 16 June, 2:00 – 3:00 PM HKT (GMT +8). Click here to register.

Indirect Tax
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.

India Spotlight
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: Jatin Arora 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 Spotlight
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.)

International Tax
Base Erosion and Profit Shifting (BEPS): What's Happened So Far? And What's Next? (Part 2: Non-transfer pricing)

16 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Steve Towers
Presenters: Leonard Khaw 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?

In this Part 2 webcast, we'll discuss:

  • Important non-transfer pricing developments in the last six months.

    – Interest deductions

    – CFC rules

    – VAT / GST  

    – Dispute resolution

    – Treaty abuse

    – Harmful tax practices

    – PE status

    – Mandatory disclosure rules

    – Agreed mandate for negotiation of the multilateral instrument  

  • Diverted profits tax (UK) and MAAL (Australia).
  • The (expected) way forward.

The Part 1 webcast (which focuses on transfer pricing developments) is scheduled for 2 June, 2:00 – 3:00 PM HKT (GMT +8). Click here to register.

International Tax 
Annual Review: Double Tax Treaty Update and OECD / UN Developments

18 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: David Watkins
Presenters: 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.

Indirect Tax
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.

Transfer Pricing
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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