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Webcasts archived in the last 6 months can be accessed on this page
Webcasts archived in the last 6 months can be accessed on this page. For a complete program schedule and topic information on upcoming webcasts, select the Program Guide.
Advance Pricing Agreements (APAs): Update on Developments across Asia Pacific
24 March 2015
Host: Arindam Mitra
Presenters: Eunice Kuo, S.P. Singh, and Michael Tabart
With increasing volume and complexity of cross-border transactions, multinationals need to gain a comprehensive understanding on APAs and keep transfer pricing disputes out of their way. What are the key insights multinationals should consider to get the best out of APAs? We'll discuss:
- An update on the recent developments in the area of APAs.
- Recent challenges and comparison of APA programs within the region, including Japan, China, and India.
- Impact of local intangibles and location specific advantages on APA programs.
- Influence of BEPS on APA programs.
- Key takeaways from recently concluded unilateral and bilateral APAs.
Stay up-to-date on these latest developments with APA programs across the region and what they could mean for your organization.
Inbound Investment into India: BEPS Perspective
19 March 2015
Host: Anis Chakravarty
Presenters: Pritin Kumar, Deepa Nanda, and Rohinton Sidhwa
Emerging global trends in taxation have impacted India's tax policy and raised numerous challenges. India is aiming to reduce BEPS as part of the G20 member countries supporting the OECD's BEPS project, which is expected to have significant implications on cross border arrangements used by multinational companies (MNCs). What are the important considerations for MNCs when doing business in India from a BEPS perspective? We'll discuss:
- Key deliverables that may have immediate impacts on MNCs doing business in India.
- View of the Indian authorities on BEPS matters.
- Emerging trends and what is likely to come.
Be updated on the latest developments on the OECD's BEPS project with specific insights on the implications from an Indian perspective.
Customs Audits in China: Are You Keeping Pace with the Latest Changes?
17 March 2015
Host: Sarah Chin
Presenters: Liqun Gao and Dolly Zhang
China Customs has been aggressive on audits in the recent years, especially towards the end of 2014. Since 2013, China Customs authorities have been stepping up on their investigation activities, but now with a new emphasis on "national" audits, covering all affected Chinese companies within a group. We will analyze a number of case studies to prepare you for the road ahead. We'll discuss:
- Highlights of Customs target areas, focuses, and approaches adopted based on our observation of Customs audits in the past 24 months.
- What can be expected in the to-be-introduced Customs audit rules, and observations of the trends and forecasts of the rules.
- How multinationals can prepare in advance to control the risks.
Stay current on the latest developments on Customs audits in China and find out ways to manage risks when doing business in China.
Establishing Headquarters in Asia Pacific: Tax and Operational Considerations
12 March 2015
Host: Tom Ewigleben
Presenters: Jie Liang, Sharfudeen Shamsudeen, and Patrick Yip
Companies are recognizing the vast potential for growth in Asia Pacific as a supply base with increasing growth in demand for products, and a key source of talent to meet needs from a growing pool of well-educated talent. Many companies have established headquarters (HQ) in Asia Pacific and many others are actively deliberating such a move. Despite many opportunities, what are some significant challenges companies need to be aware of? We'll discuss:
- Tax and potential considerations for the choice of the HQ location.
- Types of HQ models and tax and operational considerations.
- Considerations around setting up and remunerating the HQ.
- Pros and cons of regional vs. global HQs.
- Lessons learned and pitfalls to avoid.
Gain insights into factors you should consider when setting up an HQ in Asia Pacific.
New Indirect Transfer Rules in China: Substantially Upgraded
6 March 2015
Host: Vicky Wang
Presenters: Anthony Lau, Hong Ye, and Julie Zhang
The Chinese State Administration of Taxation (SAT) just released the long-awaited Bulletin 7 on 3 February 2015. This circular is a comprehensive regulation that addresses the indirect transfers of Chinese taxable assets by foreign nonresident enterprises, and is to replace the relevant articles in the well-known Circular 698 and Bulletin 24 on indirect transfers. Bulletin 7 provides a set of guidance on assessing taxability of the transactions and exceptions, and clarifies some unresolved issues. We'll discuss:
- Applicable scope of the bulletin.
- Elimination of mandatory reporting obligations.
- Safe harbor and "black list" transaction criteria.
- General assessment of taxability criteria.
- Calculation of taxable income.
- Respective penalties and interest on both buyer and seller for noncompliance.
- Our observations and insights on the Bulletin 7, as well as recommendations.
Learn how this new rule will affect your existing and future investments and future divestments involving China assets.
Japan's 2015 Tax Reform Proposals: For Better or for Worse?
5 March 2015
Host: Jun Takahara
Presenters: David Bickle, Mark Brandon, and Brian Douglas
Japan's 2015 tax reform proposals continue to support the government's policies specifically intended to enhance Japan's international competitiveness, promote direct investment into Japan, and encourage domestic economic growth. Weak economic results following the April 2014 Japanese consumption tax rate increase has led the government to postpone the second planned rate increase and reflects the government's need to prioritize economic growth over reducing the public debt. We'll discuss:
- The 2015 tax reform proposals and the expected impact to corporations and individuals.
- Expected changes to the consumption tax rules, including an update on the rate increase, treatment of cross-border digital services, and what the delay in the second consumption tax rate increase means to businesses and consumers.
- Tax audit trends.
- BEPS and potential impact on inbound Japanese investment.
Keep abreast on direct and indirect tax matters affecting companies and individuals in Japan.
India’s Budget 2015: Will the Promised Land of Tax-friendly Reforms Finally Exist?
2 March 2015
Host: Rajesh Srinivasan
Presenters: Anis Chakravarty, C.A. Gupta, and Saloni Roy
Budget 2015 is seen as the apt platform for the Finance Minister to set a larger context and introduce a strong reform and growth-focused agenda. Clearly, creating a more
tax-friendly and investment savvy business environment and managing the deficit more effectively are top priorities. At the same time, the government has articulated that the tax net needs to be broadened. Will the much awaited reforms finally see the light of day in 2015? We'll discuss:
- Emerging opportunities in Budget 2015.
- Direct and indirect tax proposals: will a rational and reasonable tax regime for global investors and Indian businesses be a reality?
- The implications in detail that may impact you.
- Optimal next steps in the context of proposed changes to get you prepared.
Gain insights from the Deloitte experts with an in-depth analysis of the 2015 India's Budget.
Tax Compliance: Getting the Model Right
12 February 2015
Host: Richard Mackender
Presenters: Piyus Vallabh and Rony Wuytjens
The increasing pressure on companies to manage tax effectively and efficiently is driving tax directors to look closely at their tax management structures. They have to make sure they are able to deliver against all of the key performance indicators (KPIs) expected of today's tax function. What factors do tax directors need to consider to get the model right? We'll discuss:
- The balancing act and different ways to achieve the right balance.
- Analysis of recent market research findings.
- The evolving approach to the resourcing models for tax, with case studies.
- Challenges and future trends.
Gain insights into the latest trends for companies and understand the success factors to get your tax compliance model right.
International Tax: What Can We Learn from the Top Tax Cases of 2014?
10 February, 2:00 – 3:00 PM HKT (GMT +8)
*Length of webcast: 75 minutes
Host: Steve Towers
Presenters: Claudio Cimetta, Leonard Khaw, Sunil Shah, and David Watkins
Fascinating court decisions have emerged in 2014 involving the interpretation of double tax treaties and other international tax issues. What do these cases reveal? We'll discuss:
- Permanent establishment cases in India, as well as an important case in Australia on partnerships and double tax treaties.
- Cases dealing with the non-discrimination article and with "most favored nation" provisions.
- Korean cases on beneficial ownership and entitlement to treaty benefits.
- Indirect share transfer cases in China and India.
- A landmark VAT case in Europe.
Understand technical and practical implications of key rulings and discover how they apply to your company's international tax planning.
OECD / G20 Discussion Drafts on Risk, Recharacterization, and Profit Splits
30 January 2015
* Length of webcast: 75 minutes
Host: Arindam Mitra
Presenters: Anis Chakravarty, Fiona Craig, and Alan Shapiro
In December 2014, the OECD released Discussion Drafts on Risk, Recharacterization, and Profits Splits as part of its work on the BEPS project. The Discussion Drafts provide useful insight into the potential direction of the BEPS project on these important issues. What are the proposals and how might they affect your organization? We'll discuss:
- New rules on the role of contracts and identifying risk.
- New rules on managing and controlling risk.
- New rules on non-recognition of transactions.
- Discussion points for recharacterization of transactions.
- Examples on when profit split may be considered to be the best method.
- Discussion points on the profit split method.
Keep up to date with these significant proposed changes to transfer pricing under BEPS.
Global Mobility: Keeping Pace with Developments and Trends in Immigration
29 January 2015
Host: Sarah Lane
Presenters: Gus Kang and Mark Wright
For many businesses, an internationally mobile workforce is a key component of their business strategy for enabling growth, entering new markets, and talent and leadership development. However, managing the immigration requirements of moving employees across borders raises a number of challenges. If it is not managed effectively, it can expose both the company and the individual to, at best, a delayed start to an assignment or transfer and, at worst, penalties for non-compliance which may include jail terms. We'll discuss:
- Latest immigration developments in Asia Pacific including countries that are tightening their immigration processes.
- A focus on immigration issues in China.
- Broader trends in immigration and increasing connectivity between immigration and tax authorities in the same country and across borders.
- How global mobility can support business in getting through the immigration maze and staying compliant.
- The increasing role that mobility, including immigration, plays with talent development and work force management.
Stay up to date with the developments in immigration and strategies on how to stay compliant and meet business needs when moving people around the world.
OECD VAT / GST Rules: New Guidelines Out
28 January 2015
Host: Robert Tsang
Presenters: Rob Dalla Costa, Odile Courjon, and Robert Tsang
In December 2014, the OECD released two Discussion Drafts on VAT / GST aspects of Action 1 in relation to BEPS, addressing the tax challenges of the digital economy. The OECD is developing international VAT / GST Guidelines to address issues of double taxation and unintended non-taxation resulting from inconsistencies in the application of VAT / GST to international trade. How these new rules may affect your business in Asia Pacific and elsewhere? Should your business provide input on the draft Guidelines, specifically on the place of taxation of B2C supplies of services and intangibles, and provisions to support the application of the Guidelines in practice? We’ll discuss:
- The new draft rules.
- How these rules stack up against the current framework in a number of selected Asia Pacific countries.
- Examples of the rules in practice.
- Discussion points and feedback opportunities to the OECD.
Keep up to date with these new VAT / GST Guidelines under BEPS.
Industries – Financial Services
OECD's Common Reporting Standard: Are You Ready?
27 January 2015
Host: Michael Velten
Presenters: Alison Noble, Markus Weber, and Ivan Zasarsky
The OECD has released detailed commentary on the Common Reporting Standard (CRS) on 21 July 2014. The CRS will establish a new global standard for the automatic exchange of financial account information between governments. More than 90 jurisdictions have already publicly committed to the implementation of CRS, with 58 jurisdictions adopting the "early adopter" status and 51 jurisdictions signing a multilateral agreement to implement the CRS on 29 October 2014. An ambitious timeline will need to be adhered to – early adopters have pledged to work towards launching their first exchange of information by September 2017, while others are expected to follow in 2018. We'll discuss:
- What is the CRS?
- An overview of the current position for jurisdictions in Asia.
- Getting ready – the requirements for compliance.
- Comparing CRS to FATCA.
- The immediate next steps.
Learn about this new standard and what you should prepare going forward.
Indian Withholding Tax Obligations: How Do You Get it Right? And What Happens if You Don't?
9 December 2014
Host: Neeru Ahuja
Presenters: Enwright DeSales and Pritin Kumar
The Tax Department in India is recently placing more emphasis on revenue generation through withholding tax, as withholding tax collection accounts for almost 40% of total collection of direct taxes. A Centralised Processing Cell for withholding tax has been set up, and monitoring is being automated. Non-compliance with the withholding tax provisions is a double whammy as it not only encompasses recovery of tax, interest, and penalty, but also the corresponding expenditure is not tax deductible in the hands of the payer. What do you need to know about the major developments with regard to withholding taxes? We'll discuss:
- Recent changes in law.
- How corporate disallowances are triggered.
- Penalties and prosecution.
- Issues being faced by corporates and how to handle them practically.
- Actions being taken by the Tax Department.
Understand recent changes in this important area and what they mean to you.
Malaysian GST: Accelerating down the Final Stretch
4 December 2014
Host: Robert Tsang
Presenters: Sylvia Chong, Rob Dalla Costa, and Kah Seong Fan
The implementation of the Malaysian GST remains a hot topic. To be introduced on 1 April 2015, businesses and Customs are now in the final stages of readiness for GST. Are there still areas that are confusing or difficult to interpret? We'll discuss:
- Latest news including rules, guidance, rates, timelines, and developments
- Analysis of the zero-rating and exemption orders.
- Latest protocols and procedures for securing rulings, clarifications and confirmations of GST treatment from Royal Malaysia Customs, as Customs reorganizes into industry-specific and technical groups at headquarter level.
- What businesses, beyond the new Indirect Tax framework, should be doing to understand the challenges of the new Anti-Profiteering Law and Guidelines.
- Case study examples across a number of industry groups.
Tune in to learn all the many complexities of this revolutionary new tax implementation and find out what your business needs to do and fine-tune by 1 April 2015.
BEPS: What's Happened So Far? And What's Next?
2 December 2014
* Length of webcast: 90 minutes
Host: Steve Towers
Presenters: Anis Chakravarty, Leonard Khaw, Peter Madden, and David Watkins
The BEPS project is the most important review of the world's international tax architecture in decades. Since its official launch by the OECD and G20 in July 2013, what have been the key developments, both globally and in Asia Pacific? We'll discuss:
- What has been achieved in regard to the first tranche of "deliverables" (September 2014): country-by-country reporting, transfer pricing documentation, the transfer pricing aspects of intangibles, the tax aspects of the digital economy, prevention of tax treaty abuse, hybrid mismatch arrangements, and progress reports on harmful tax practices and the multilateral instrument.
- Work currently being undertaken by the OECD in regard to the second tranche of "deliverables" (September 2015), including CFC rules, permanent establishment, interest deductions, the transfer pricing aspects of risk and capital, disclosure of aggressive tax planning, and dispute resolution.
- Areas of friction amongst OECD / G20 countries.
- 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.
BEPS: Discussion Draft on Action 7 (Artificial Avoidance of PE Status)
26 November 2014
* Length of webcast: 90 minutes
Host: Steve Towers
Presenters: Claudio Cimetta, Leonard Khaw, Ben Pickford, and David Watkins
On 31 October 2014, the OECD released a discussion draft on BEPS Action 7 (artificial avoidance of PE status). This paper describes various proposals to significantly widen the definition of "permanent establishment" (PE) in Article 5 of the OECD model treaty – and thus broaden source country taxing rights. We'll discuss:
- Proposed changes to the dependent agent PE in Article 5(5) & (6).
- Proposed changes to the exceptions from PE status in Article 5(4).
- Splitting-up of contracts and insurance.
- Practical examples illustrating the impact of the proposed changes.
The BEPS project is the most important review of the world's international tax architecture in decades. Learn about the recent proposals to expand the PE definition, which is central to the BEPS initiative.
Asia Pacific Share Plans: Practical Considerations for Implementation in Hong Kong, India, and Japan
25 November 2014
Host: Tony Jasper
Presenters: Russell Bird, Vivian Lam, and Aarti Raote
As share plans continue to be a popular form of incentive compensation for employers, despite the challenges which could arise with a mobile employee population, what are the regulatory issues and common pitfalls that employers should be aware of or consider? We'll discuss:
- Why share plans remain relevant as a form of reward for employers.
- Changes in the regulatory environment and trends around the world which may impact upon employers and employees specifically in Hong Kong, India, and Japan.
- Common pitfalls encountered in the operation of share plans in these locations, for example, differences in tax treatment across jurisdictions such as potential for exit taxes prior to an option actually vesting or local rules on sourcing resulting in double tax charges.
- Critical linkages in implementing a share plan and maintaining compliance including interaction between tax, human resources, and payroll teams.
Gain insights into optimizing the implementation and operation of share plans by your company.
Swiss Corporate Tax Reforms: Has a New Era Arrived?
18 November 2014
Host: Sarah Chin
Presenters: Jacqueline Hess, Jacques Kistler, and Rene Zulauf
In order to strengthen its tax competitiveness as an international location for corporations and adjust to the changing OECD / BEPS and EU tax landscape, Switzerland is undertaking the most comprehensive corporate tax reform in 50 years. Existing special tax regimes, such as the holding or mixed company regimes, will be phased out and be replaced by other measures. What challenges and opportunities will these reforms bring to your businesses? We’ll discuss:
- A “license box” for income arising from the exploitation and use of intellectual property.
- A notional interest deduction on equity.
- A general reduction of the headline corporate tax rate.
- Other measures that are being proposed, including a step up for tax purposes for existing regimes and companies migrating to Switzerland, the abolishment of the 1% capital issuance tax on equity contributions, the reduction of the annual capital tax or the introduction of an unlimited loss carry forward period, etc.
Learn how your company can best profit from these significant changes.
Transfer Pricing in India: Much Awaited Changes
13 November 2014
Host: Vishweshwar Mudigonda
Presenters: Rakesh Alshi and S.P. Singh
Transfer pricing litigation has been one of the major areas of concern for multinationals doing business in India. There were expectations that the new government would take steps in reducing unwarranted litigation and simplifying procedures to enhance the business environment. The Finance Minister has brought in changes in the transfer pricing regulations including the use of multi-year data and the introduction of a range for determining the arm's length price. Have the proposed changes addressed some of the concerns of taxpayers? What are the other changes in transfer pricing that impact an organization? We'll discuss:
- Effect of using multi-year data in reducing litigation.
- Ramifications of the use of a range for determining the arm's length price.
- The third party transactions that need to be reported after the amendment in the definition of deemed international transactions.
Explore the latest changes in transfer pricing in India and what they could mean for your organization.
Debt Push Down: Focus on India and Southeast Asia
11 November 2014
Host: Danny Po
Presenters: Walter Jr. Abela, Kwang Gek Sim, Wanna Suteerapornchai, Anil Talreja, and Chee Ming Wong
It has always been a challenge for investors to obtain tax deductions on financing costs incurred in connection with M&A. Given the rapid development of BEPS in Asia Pacific, the structuring of debt push down will become even tougher. In the last quarter, we illustrated case studies in China, Hong Kong, Japan, and Korea and in this quarter, we will continue the discussion of this topic with a focus on India and Southeast Asia. We'll discuss:
- Basic and special debt push down techniques in India and Southeast Asia.
- Illustrative case studies in India and Southeast Asia 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.
Understand the techniques and challenges on debt push down that might affect your M&A deals.
Transfer Pricing in a BEPS Environment: Australia's Approach
6 November 2014
Host: Arindam Mitra
Presenters: Fiona Craig, Colin Little, and Graeme Smith
With Australia's presidency of the G20 fuelling increased government debate on the taxation of multinationals, activity around the OECD's BEPS project has gained an additional dimension through the ATO's (Australian Tax Office) policing of the BEPS phenomenon. What is the ATO's approach that you should be aware of? We'll discuss:
- The ATO's recent and future compliance efforts, in the name of BEPS, focused on international structuring and profit shifting of multinationals.
- New ATO approaches and protocols in undertaking these compliance activities.
- Points to consider in determining a strategy for how to deal with this growing ATO scrutiny.
- The response from other revenue authorities.
Hear our practical insights and remain up-to-date on these current transfer pricing developments as the BEPS environment keeps multinationals on their toes.
Inbound Investment into China: BEPS Perspective
4 November 2014
Host: Vicky Wang
Presenters: Patrick Cheung, Martin Lin, and Andrew Zhu
On 16 September 2014, OECD released the first 7 deliverables on BEPS. Some of these deliverables will have significant impacts on cross border structures and arrangements currently used by multinational companies. What are the important considerations for MNCs when doing business in China from a BEPS perspective? We'll discuss:
- Key highlights of 3 deliverables that may have immediate impacts on MNCs doing business in China, specifically Action 6 (Prevent Treaty Abuse), Action 8 (Intangibles), and Action 13 (Re-examine Transfer Pricing Documentation).
- Impacts of these 7 deliverables on China and the SAT's (State Administration of Taxation) view.
Get updated on the latest developments on the OECD's BEPS project with specific insights on the implications from a China perspective.
Inbound Investment into Korea: A Clear View of the Recent Developments
30 October 2014
Host: Leonard Khaw
Presenters: Gyung Ho Kim, Sunny Kim, and Tom Kwon
Significant developments in Korea have caused an impact on inbound investment into the country. What are the tax implications and risks associated with the investment process into Korea, and how can foreign investors proactively manage them? We'll discuss:
- Insights into the proposed introduction of new tax legislation to stimulate the economy and promote fairness, which may impact foreign investors.
- Recent Supreme Court and other cases on the beneficial ownership issue and the eligibility of foreign investors for tax treaty benefits.
- Latest trends and issues raised by auditors in tax audit cases from various industries.
Discover the latest inbound investment climate in Korea, and what might affect your benefits when investing in Korea.
Industries – Financial Services
BEPS Actions 8 and 13 (Transfer Pricing): Implications for the Financial Services Industry
14 October 2014
Host: Michael Velten
Presenters: Patrick Cheung, Samuel Gordon, Giles Hillman, and Robert Plunkett
In September 2014, the OECD met two BEPS action item milestones in providing guidance on intangibles and transfer pricing documentation. What are the implications that financial services firms should evaluate for their operating models and transfer pricing management? We'll discuss:
- Conclusions that financial services firms can draw from the guidance including new or persistent uncertainties.
- Actions that tax authorities are taking or signaling they will take given the OECD level changes.
- Considerations for determining priorities and timing of dealing with the change.
- Potential starting points and frameworks for dealing with the change.
Gain insights into how major changes in global transfer pricing are impacting financial services firms.
Managing the Continuous Evolution of China's VAT Reforms: Theory vs. Reality
30 September 2014
Host: Robert Tsang
Presenters: Sarah Chin and Li Qun Gao
Since the pilot reform program was introduced in Shanghai on 1 January 2012, the Chinese National VAT Reform has been introducing significant changes to the old VAT and business tax regimes. Taxpayers have witnessed continuous policy changes and implementation challenges. Although the planned completion date of the reform, the end of 2015, is only 18 months ahead, there are many sectors to be covered in the reform. What are the latest changes and what is expected in the next batch of changes? We'll discuss:
- Announcements for the latest sectors, including the telecommunications industry announcement in early May 2014.
- Developments in the implementation of the reform including the exemption of cross-border services.
- Practical steps to be taken by businesses, suppliers, and customers to handle the new reality of China's VAT system.
Understand the latest changes and developments in China's National VAT reform and how you can address them.
OECD / G20 Transfer Pricing Documentation and Intangible Guidance
29 September 2014
* Length of webcast: 75 minutes
Host: Arindam Mitra
Presenters: John Bland, Eunice Kuo, and Alan Shapiro
The G20 finance ministers are meeting on 21-22 September 2014 to approve the output from several Actions under the OECD / G20 Base Erosion and Profit Shifting (BEPS) project. Prior to the meeting, the OECD will publish new guidance on the transfer pricing documentation requirements, including country-by-country information for tax authorities. What are the proposals, how have they changed from earlier drafts, and how might they affect your organization? We'll discuss:
- The common template for providing country-by-country information to tax authorities.
- Master file and local file documentation requirements.
- Definition and new methods to value intangibles.
- Timetable and Areas that remain to be finalized.
- Potential impact of the new guidance on your organization and the action steps you should consider.
Keep up to date with these significant changes to transfer pricing under BEPS.
講師：足立 佳寛、坂本 安孝
2014年9月16日に公表予定のBEPS行動計画（Action Plan）13により、OECD移転価格ガイドライン第5章： 移転価格文書化規定が改訂されます。
- 2014年9月公表予定のBEPS行動計画13成果物： 移転価格文書化規定の改訂の概要
- 今後、日系グローバル企業が取り組むべき課題と対応策 等
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