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Webcasts archived in the last 6 months can be accessed on this page

Indirect Tax
Malaysian GST in April 2015: Final Preparations

28 August 2014
Host: Robert Tsang
Presenters: Bruce Hamilton, Eng Yew Tan, and Poh Geng Wong

As the Malaysian Government and businesses get into the final flush of preparations for GST in April next year, it is important to find out about the latest developments in law, regulations, guides, and practice in this fast changing area. What should Malaysian businesses be doing in the 6 month countdown to April 2015? We’ll discuss:

  • The latest rules.
  • How industry bodies are getting on with clarification requests of Customs and the Ministry of Finance.
  • Case studies and the latest thinking on GST implementation approaches or methodologies.

Find out what Malaysian business should be doing to prepare for the introduction of GST in Malaysia.

International Assignments
Global Employment Companies: Old Vehicle, New Driver?

26 August, 2014
Host: Don Riegger
Presenters: Rohit Shah and Jill Storey

Global Employment Companies (GECs) have been around for a while, but in the past their creation was often a vehicle for global talent management and maintaining equity among assignees. Now the business drivers for setting up a GEC are more focused on the corporate issues associated with a mobile employee population rather than the needs of the employees themselves. We'll discuss: 

  • What is a GEC and how are they structured, including any GST / VAT implications.
  • The latest business drivers for implementing GECs.
  • The latest worldwide attention to BEPS impact upon the GEC.
  • The PE issues associated with GECs.
  • Examples of GECs including best practices and service delivery models and from specific countries in Asia Pacific – Singapore and India.

Discover why GECs remain an enduring and attractive structure for handling mobile employees. 

Private Business
Private Wealth Structuring for Individually-Owned Thai Companies

21 August 2014
Host: Michael Pfaar
Presenters: Mark Kuratana and Anthony Loh

Recent transactions, such as the battle for a well-known food and beverage company, have shown the skills and resourcefulness of Thai business families. Many individually-owned Thai businesses include the 2nd or 3rd generation in leadership positions, demonstrating how developed the intergenerational transfer of wealth has become in Thailand. However, it is still unclear from a Thai tax point of view how companies can efficiently hold assets and businesses, particularly those involving overseas trusts and companies. We'll discuss:

  • Common structures.
  • Respective legal and tax treatments for common structures.
  • Commentary on open issues.

Find out how private wealth structures are developing in Thailand.  

International Tax 
Inbound Investment into Australia: Do You Have a Complete Picture?

19 August 2014
Host: Vik Khanna
Presenters: Claudio Cimetta and Colin Little

Australia is currently experiencing an increase in M&A activity with significant investment flows coming from Asia Pacific. As the world's international tax architecture is evolving, legislative changes are occurring in Australia and the Australian Taxation Office (ATO) is refining its approach to managing risk to the Government. What are the tax risks associated with the investment process into Australia, and how can you proactively manage them? We'll discuss:

  • The main industries into which investments are being made and typical tax issues that arise.
  • Important legislative tax changes, enacted and proposed, as well as recent ATO rulings.
  • Typical inbound investment structures and issues.
  • Tax risks that the ATO is focusing on.

Hear about the latest inbound investment climate in Australia, and what might affect your benefits when investing in Australia.

International Tax
Road-testing BEPS Action 6 (Prevent Treaty Abuse): Case Studies

13 August 2014
*Length of webcast: 80 minutes
Host: Steve Towers
Presenters: Claudio Cimetta, Leonard Khaw, Ivan Strunin, and David Watkins

BEPS Action 6 (prevent treaty abuse) involves the insertion, into double tax treaties, of a range of anti-abuse provisions. In this webcast, we will analyze a number of case studies which will illustrate the operation of these provisions. Issues covered in the case studies will include:

  • The "limitation on benefits" (LOB) article, including the operation of the "qualified person" definition, the "active trade or business" test, and the "derivative benefits" provision.
  • The "main purpose" provision: scope and evidentiary support.
  • Several of the "specific anti-abuse" provisions, such as exclusion of third country permanent establishments, the "saving clause", and the dual resident "tie-breaker" provision.

Learn how these new treaty anti-abuse provisions will likely operate in various practical situations.

Industries – Financial Services 
Operational Taxes in Asia Pacific: Are You Keeping Pace?

12 August 2014
Host: Carl Church
Presenters: Sarah Chin, Johnny Foun, Richard Lapres, Michael Velten, and Martin Walker

Operational taxes, including technical aspects, governance, compliance considerations, and reviews, are affecting financial institutions based in Asia Pacific. What do you need to know to stay updated on operational taxes and related risk management in the region? We'll discuss:

  • Financial transaction tax (FTT) – an update on latest developments.
  • Qualified Foreign Institutional Investors (QFII) / Renminbi Qualified Foreign Institutional Investors (RQFII) / Shanghai-Hong Kong Stock Connect – where do we currently stand in relation to capital gains tax and withholding tax on China securities?
  • Philippines Tax Identification Numbers, specifically custodian requirements, options, and solutions.
  • Update on China VAT for the banking industry.

Understand the implications of the latest developments and management of operational taxes in Asia Pacific. 

M&A Tax 
Debt Push Down in Asia Pacific: Techniques and Case Studies

31 July 2014
Host: Danny Po
Presenters: Tom Kwon, Jun Takahara, and Davy Yun

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. What are the techniques and challenges to overcome in order to push down the interest costs to the operating entities? We'll discuss:

  • Basic debt push down techniques.
  • How to overcome regulatory and tax restrictions such as thin capitalization rules and exchange control measures.
  • Illustrative case studies in China, Hong Kong, Japan, and Korea 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.

China Spotlight 
Earmarked Investments in Shenzhen Qianhai and Zhuhai Hengqin: What do You Need to Know?

24 July 2014
Host: Lillian Xiao
Presenters: Ellen Tong and Caesar Wong

The Qianhai Shenzhen-Hong Kong Modern Service Industry Cooperation Zone (Qianhai) and the Zhuhai Hengqin New Area (Hengqin) are two key economic zones in China. As of May-end 2014, more than 12,000 entities were approved to register. As the two key constituent zones in the pending Guangdong-Hong Kong-Macau Free Trade Zone (FTZ), what are the opportunities available? We'll discuss:

  • The developments within the two zones, and how they are strengthening the international competitiveness of China, Hong Kong, and Macau.
  • The business and market opportunities available including Individual Income Tax equalization subsidies for qualified expatriate employees, and the reduced Enterprise Income Tax rate of 15% on qualified income.
  • The differences among Qianhai, Hengqin, and other parts of China. 

Join us as we discuss how zones such as Qianhai and Hengqin will help to mitigate China tax risks and enhance cost efficiency of non-resident companies.  

India Spotlight
India
's Budget 2014: Great Expectations?

11 July 2014
*Length of webcast: 90 minutes
Host: Neeru Ahuja
Presenters: Anis Chakravarty, N. C. Hegde, Krupa Venkatesh

The recent Indian elections have brought in a new government with a strong growth focused agenda. Expectations are riding high as India prepares for a crucial Budget in July 2014. At the top of the new government's agenda will be ensuring an amiable business environment for investors both in India and abroad, and reining in inflation. It is expected that the Government will look at reducing regulatory uncertainty and simplifying procedures to enhance the business environment. What about a roll-back on retrospective tax laws? Any anticipated moves to revive the investment climate and any intentions to introduce GST in the near future? We'll discuss:

  • Impact of key budget proposals to the business environment.
  • The larger ramifications from a direct and indirect tax perspective for organizations.
  • Given the new changes, what can organizations do to plan more effectively.

Tune in to keep up with the latest changes being considered in India's Budget 2014.

Transfer Pricing
Transfer Pricing Issues in the Context of Mergers and Acquisitions

26 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Shanto Ghosh
Presenters: Samir Gandhi, Tae Hyung Kim, and Danny Po

Multinational enterprises often rely on inorganic growth to expand their global footprint. As mergers and acquisitions (M&A) activity becomes prevalent, transfer pricing issues have come to play an important role in the pre- and post-acquisition process. We'll discuss:

  • Key characteristics of M&A activity across the globe with specific emphasis on Asia Pacific.
  • Transfer pricing issues in the due diligence phase of an M&A deal, including possible risk from lack of documentation or support for pre-existing transfer pricing policies, and suitable reserves for uncertain tax positions.
  • Post-acquisition transfer pricing issues such as aligning pre- and post-acquisition transfer pricing policies in the integrated group, and transfer pricing issues related to business restructuring in the post-acquisition phase.

Gain insights from an in-depth discussion on the importance of transfer pricing issues in the context of M&A.

Indirect Tax
VAT / GST on Cross-border Digital Services and Intangibles: What next for B2B and B2C Rules in Asia Pacific?

19 June 2014
Host: Robert Tsang
Presenters: Aili Nurk, Chikara Okada, and Chandran Ramasamy

A number of Asia Pacific countries, namely China, Japan, and Malaysia, are implementing new indirect tax rules over the next 18 months and all are focused on new ways of tackling taxation of cross-border services and intangibles. Concurrently with the BEPS project, the OECD is also taking steps on the indirect tax front to develop the next set of OECD VAT / GST International Guidelines focusing on the “challenges of taxing the digital economy”. We’ll discuss:

  • The rules for indirect taxation of electronic or digital B2C supplies in step with BEPS recommendations.
  • Soon to be finalized OECD rules on B2B supplies and where the B2C work is likely to be headed.
  • How Asia Pacific tax authorities are approaching this, particularly in Japan with the increase in consumption tax rate and scope starting in April this year, in China as part of the ongoing VAT Reform Program, and in Malaysia as part of the GST rollout in April 2015.

Explore more about how the VAT / GST rules are shaping and developing across the region.

India Spotlight
E-commerce Transactions in India: The Final Frontier

12 June 2014
Host: Prashant Deshpande
Presenters: Rajesh Gandhi and Rohinton Sidhwa

Electronic commerce in India is poised to grow significantly, as traditional infrastructure is outpaced by the feverish growth of India's cities. As the consumption based tax systems in India struggle to keep pace with these technological developments, what can e-commerce companies do to meet the challenges? We'll discuss:

  • Current state of the market, projections for growth, and policies concerning opening up the market to foreign investors.
  • Indian judicial precedent on various models such as cloud services, server space, and webserver as a PE.
  • Impact, in India, of the OECD discussion paper on “Tax Challenges of the Digital Economy” released for public comment in March 2014.
  • Impact of Indian indirect taxes on e-commerce transactions related to sale of goods such as e-tailing and electronically supplied services such as digitized content.

Gain insights from practical experiences and case studies on e-commerce transactions in India.

International Tax
Business Model Transformation in Asia Pacific: Lessons Learned

10 June, 2:00 – 3:00 PM HKT (GMT +8)
Host: Tom Ewigleben
Presenters: Korneeka Koonachoak, Nazly Siregar, and Paul Zanker

Pioneering companies in Business Model Transformation have transformed their operating models, resulting in improved financial performance through, for example, lower effective tax rates (ETR), better operational efficiency, and better leverage on economies of scale. What exactly did they do and what could have been done differently? We'll discuss:

  • What caused them to rethink their operating models – tax, operations, or both?
  • Critical decisions made during design and implementation.
  • Tax and operational benefits realized.
  • Lessons learned from recent case studies.

Understand the experiences and lessons learned from these pioneering companies in the region.

Industries – Financial Services
The Countdown for FATCA Compliance: Where are We Now and What to Do after the Deadline Has Passed?

5 June 2014
Host: Jim Calvin
Presenters: Marie Gervacio and Alison Noble

Foreign Account Tax Compliance Act (FATCA) will go live on 1 July 2014. Many financial institutions, however, will be unprepared or under-prepared due to late starts or failure by governments to have timely signed intergovernmental agreements (IGA) with the U.S. What can financial institutions do to prepare for FATCA? We'll discuss:

  • Uncertainties such as whether and which model of IGA will be signed in jurisdictions relevant to a financial institution in the compliance landscape within the time remaining.
  • How to deal with non-compliant counterparties – when and how it becomes relevant.
  • Reconciliation and upgrading processes from the U.S. regulations in order to meet IGA standards such as automated onboarding and reasonableness checks, and local compliance program requirements and enforcement under an IGA.

Learn how financial institutions can prepare themselves for FATCA, leading up to and beyond 1 July 2014.

International Assignments
Waiting for Lightning to Strike: How do Employers Evaluate Risk in Tax Compliance?

29 May 2014
Host: Russell Bird
Presenters: Tony Jasper, Jill Lim, and Paul Tyler

These days it seems that the question is not if an audit will strike but when. Tax authorities are scrutinizing information gathered to ensure individual and employer tax returns are aligned with current tax laws. Where are the particular areas of risk for employers in the Asia Pacific region, and how can we evaluate risk and take action? We'll discuss:

  • Trends in audit activity and information gathering across the region.
  • Techniques that employers can use to evaluate the tax risk in their compliance process.
  • Specific areas of risk, such as business travelers, that employers should focus on and what they should do when "lightning strikes".

Learn how employers are addressing specific areas of risk in tax compliance across the region.

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

27 May 2014
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:

  • Work currently being undertaken by the OECD, including 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, and hybrid mismatch arrangements.
  • Areas of potential "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.

Japanese Language Webcasts
戦略的な経営幹部報酬制度
~設計および税務上の留意点を踏まえて~

5月21日 12:00 – 1:00 PM (日本時間、GMT+9)
司会進行:川井 久美子
講師:村中 靖、 白澤 賢

日本企業のグローバル化に伴い、人材の多国籍化、海外勤務者の増加、外国人幹部役員の採用など、グローバルな視点での人材マネジメントの重要性が認識され始めています。国際競争が激化する環境下において、グローバル人材の育成や海外における高いスキルやノウハウを持った人材の重要性は増しており、日本本社は自社の海外進出状況に応じて、ビジネスを適切にサポートする戦略的な報酬制度の体系を整備することが必要になってきています。

今回は、最近のトレンドであるグローバル役員報酬や海外経営幹部報酬に係る報酬制度の動向、制度設計について、事例を踏まえて解説を行います。また、海外勤務者が株式報酬など長期インセンティブを付与された場合の税務上の留意点についても併せて解説します。

  • グローバル役員報酬と海外経営幹部報酬
  • 経営幹部報酬の見直しの必要性とその背景
  • 海外勤務役員の場合の費用負担と税務上の留意点
  • 株式報酬制度と海外勤務者の税務上の留意点 等

India Spotlight
Deepening Links: Transfer Pricing and Indirect Tax in India

8 May 2014
Host: Samir Gandhi
Presenters: Manisha Gupta and M.S. Mani

The debate on the linkages between transfer pricing (TP) and indirect taxes (IDT) is not new, though several recent developments in India have signified deeper ties are being formed between the two. How should you accommodate the TP and IDT issues on the same platform, in order to avoid adopting a silo approach to the growing complexities in these taxes? We'll discuss:

  • Concept of related party in terms of transfer pricing regulations and indirect tax laws.
  • Expanding TP legislation, including coverage of Specific Domestic Transactions.
  • New perspectives on Customs Valuation for related party transactions based on two recent Customs decisions.
  • The link between TP and service taxes, in light of the recent changes in the service tax legislation including the provision for a mechanism to compare the cost of providing services.
  • Importance of documentation and reporting requirements suitable for TP and IDT.

Gain new insights on the deepening interplay between transfer pricing and indirect taxes.

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

29 April 2014
* Length of webcast: 75 minutes
Host: Steve Towers
Presenters: Leonard Khaw 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 China, Japan, Korea, and other countries.
  • Important cases on treaty interpretation, including the "permanent establishment" (PE) definition and anti-avoidance rules.
  • Proposed amendments to the OECD Commentary.
  • China's Bulletin 19 on employee secondments and PEs.
  • The UN's initiative in regard to services income.
  • Update on the OECD / G20 "base erosion and profit shifting" (BEPS) project.

Learn about the important developments in the last 12 months in regard to double tax treaties and OECD / UN projects.

税务
新海关审价办法:机遇与挑战并存

2014年4月23日
主持人:周翊
主讲人:张少玲及杨永毅

海关总署于2013年底公布了《中华人民共和国海关审定内销保税货物完税价格办法》(211号令)和新修改的《中华人民共和国海关审定进出口货物完税价格办法》(213号令)。在原海关审价办法148号文实施近8年后,中国海关对其做出了较大的调整。为了使企业更好地了解法规变化,应对法规变化可能带来的影响,此网络讲座将重点讨论211号令和213号令对进出口货物以及保税货物的价格审核所做出的调整及其影响。我们将讨论:

  • 新颁布的两个海关审价办法的出台背景以及与原审价办法相比的主要变化。
  • 新审价办法可能给企业带来的影响分析。
  • 如何更好有效应对海关审价。
  • 案例分享。

请参与此网络讲座,了解更多新海关审价办法带来的影响。

International Tax
BEPS: Discussion Draft on Action 1 (Digital Economy)

4 April 2014
* Length of webcast: 75 minutes
Host: Steve Towers
Presenters: Leonard Khaw, Richard Mackender, Ben Pickford, and David Watkins

On 24 March 2014, the OECD issued, for public comment, its long-awaited discussion draft on BEPS Action 1 ("address the tax challenges of the digital economy"). What does the document say and how might it impact your organization? We'll discuss:

  • The OECD's view that other actions within the BEPS project will significantly restrict BEPS tax planning in regard to the digital economy.
  • The OECD's list of possible options to fully address the tax challenges of the digital economy.

- Modifications to the PE definition, to restrict the exceptions in Article 5(4).     
- New nexus based on the notion of "significant digital presence".
- A "virtual fixed place of business PE", a "virtual agency PE", and a "virtual on-site business presence PE".
- Withholding tax on digital transactions.
- VAT options, in regard to: (i) exemptions for imports of low valued goods, and (ii) remote digital supplies to consumers.

  • Reading between the lines: what the discussion draft tells us about the "behind the scenes" conflict within the BEPS project.

Keep up to date with significant changes in international taxation under the BEPS project.

International Tax
BEPS: Discussion Drafts on Action 2 (Hybrid Mismatch Arrangements)

2 April 2014
* Length of webcast: 80 minutes
Host: Steve Towers
Presenters: Mark Brandon, Peter Madden, and Jun Takahara

On 19 March 2014, the OECD issued, for public comment, two related discussion drafts as part of Action 2 (hybrid mismatch arrangements) of the BEPS project. One discussion draft deals with recommendations for domestic law changes, whilst the other discussion draft covers treaty issues. What are the proposals and how might they affect your organization? We'll discuss the OECD's recommendations in regard to:

  • Hybrid financial instruments (such as deferred payment structures) and hybrid transfers (such as repos).
  • Hybrid entity payments, such as payments by disregarded entities under the U.S. "check the box" rules and by permanent establishments.
  • Imported mismatches and reverse hybrids, where the effect of the bilateral hybrid structure is effectively "imported" into a third country.
  • Ordering rules in regard to which country should have the primary responsibility for the relevant law change.
  • Proposed amendments to the OECD model treaty in regard to hybrid transactions and entities.

Keep up to date with significant changes in international taxation under the BEPS project.

International Tax
BEPS: Discussion Draft on Action 6 (Prevent Treaty Abuse)

28 March 2014
* Length of webcast: 75 minutes
Host: Steve Towers
Presenters: Claudio Cimetta, Alyson Rodi, and Rohinton Sidhwa

On 14 March 2014, the OECD issued, for public comment, a discussion draft called: "Preventing the granting of treaty benefits in inappropriate circumstances". The discussion draft is part of Action 6 ("prevent treaty abuse") of the BEPS project. What are the proposals and how might these affect your organization? We'll discuss:

  • Proposed U.S.- style "limitation-on-benefits" and "savings clause" provisions, and a UK-style "main purpose" rule.
  • A proposal to exclude from treaty benefits income derived via third country permanent establishments.
  • A proposal to change the corporate residence tie-breaker test in Article 4(3).
  • Proposed clarification that tax treaties are not intended to be used to generate double non-taxation.
  • Inclusion of new treaty provisions into existing double tax treaties via a multilateral instrument (BEPS Action 15).

Keep up to date with significant changes in international taxation under the BEPS project.

Indirect Tax
Malaysian GST: Turning Promises into Hard Realities by April 2015

27 March 2014
Host: Robert Tsang
Presenter: Kah Seong Fan

In its October 2013 budget, the Malaysian government announced a new goods and services tax (GST) with an implementation date of April 2015. Since then, many revisions have been made to the law, along with industry and sector specific implementation guidance. What should multinationals know about the new law and guidance? We'll discuss:

  • Insights into the government's new online registration portal, including the latest on industry guides (particularly in the banking and consumer business sectors).
  • The latest updates on special schemes and industry-focused rules – for example, how will the requirements of the Approved Trader Scheme work in practice?
  • Important issues businesses should begin to prepare for now – what pitfalls are there lurking in systems work undertaken by businesses for the new GST? What are the ramifications for businesses of the anti-profiteering rules and GST – where is the burden of proof and what level of evidence is required?

Hear the latest details on Malaysia's new GST program and how you should be preparing for implementation in 2015.

International Tax
"Permanent Establishment" Definition: Current "Frictions" in Interpretation

25 March 2014
Host: Steve Towers
Presenters: Claudio Cimetta, Leonard Khaw, and Julie Zhang

The "permanent establishment" (PE) definition in double tax treaties continues to be subject to changing, and conflicting, interpretations, quite apart from any redrafting of the definition under the OECD's BEPS Project. What are the current areas of "friction" in the interpretation of this important determinant of source country entitlement to tax business profits? We'll discuss:

  • The "at the disposal" condition in Article 5(1) and its application in toll manufacturing, logistics, visiting employees, and other situations.
  • The "furnishing of services" PE in Article 5(3)(b) of the UN model treaty.
  • The "binding" condition in Article 5(5).
  • The circumstances, if any, in which a non-contract-concluding dependent agent can cause a PE for its principal.

Understand the current "friction" areas in the interpretation of the PE definition in double tax treaties.

Industries – Financial Services
Cash Pooling among Banks and Corporate Clients: The Tide is Rising?

20 March 2014
Host: Michael Velten
Presenters: Leon Cane, Ian Clarke, Frederic Bertholon-Lampiris, and Natalie Yu

Across Asia, banks and their corporate clients are increasingly focused on cash and liquidity management, as well as financial supply chain solutions. Why is cash pooling such a focus now and what are important considerations for your organization? We'll discuss:

  • Factors driving the development of cash pooling in Asia, including bank and corporate perspectives and the prevalence of cash pooling in Asia.
  • Recent Asia Pacific regulatory changes impacting cash pooling, including developments in China that are expected to prompt further development of cash management products in China.
  • Transfer pricing issues and considerations, including allocation of the interest savings from cash pooling.

Gain insights into this developing trend and what it could mean for your organization.

Industries – Financial Services
Financial Services Update: Developments in the China (Shanghai) Pilot Free Trade Zone

18 March 2014
Host: Steve Towers
Presenters: Patrick Cheung, Hal Davis, Johnny Foun, and Jeff Tao

Potential internationalization of the RMB, introduction of market interest rates, and facilitation of cross-border trade and investment flows are a few of the sweeping financial markets reforms possible with establishment of the China (Shanghai) Pilot Free Trade Zone (the Zone) in September 2013. What could these and other development mean for financial services providers? We'll discuss:

  • Current status of market reforms in the Zone and steps Chinese and foreign businesses are taking to benefit from them.
  • What financial institutions are doing in the Zone, including liquidity management, risk trading and cross-border investment flows.
  • Tax considerations for Zone participants and potential entrants, including transfer pricing and transaction tax management.

Understand the financial services implications of developments in this important Chinese experiment with market reforms and related tax considerations.

Transfer Pricing
Pricing Intercompany Financial Transactions: Controversies on the Rise

13 March 2014
Host: Shanto Ghosh
Presenters: Ian Clarke and Geoff Gill

Transfer pricing issues surrounding pricing of intercompany debt and guarantees remain at the forefront of discussions and controversies across Asia Pacific. What are the latest developments multinationals should consider? We'll discuss:

  • Issues related to the arm's length pricing of intercompany debt and financial guarantees, including the classification of loan arrangements, implementing practical intragroup financing policies, and anticipating potential guarantee pricing issues.
  • Passive association and the latest OECD thinking on group synergies.
  • Debt quantum, terms, and other commerciality considerations.
  • Learnings from recent transfer pricing audits, including approaches to determine credit rating, guarantee recognition (distinguishing financial from non-financial), supporting financial transactions where local comparables are preferred, and establishing core components of comparability for financial transactions.

Gain the latest insights on this contentious area of transfer pricing and recent developments across the region.

India Spotlight
Tax on Services Rendered under Global Arrangements: Perspective and Challenges in India

11 March 2014
Host: Prashant Deshpande
Presenters: Jatin Arora and Debasis Ghosh

Indian tax authorities continue to challenge multinationals that provide services from India under global agreements and claim them as export services, despite a number of decisions upholding the position of export. What recent developments should multinationals consider? We'll discuss:

Types of business models being adopted when performing services in India under global arrangements, including arrangements for soliciting orders for global parent and providing after sales service to customers in India.

  • Service tax provisions that have prevailed, including export of service and point of taxation and their implications.
  • Judicial precedents and pending litigation in a significant matter.
  • Recent experiences when seeking input credit refunds on export claims.

Learn how multinationals might approach planning and documentation to reduce negative business consequences of challenges to global arrangements.

Indirect Tax
Indirect Tax: Update on China's Business Tax and VAT Regime

6 March 2014
Host: Robert Tsang
Presenters: Sarah Chin and Li Qun Gao

The comprehensive VAT reform in China marches on, with an announcement or change nearly every week. What recent news and changes should multinationals be aware of? We'll discuss:

  • Whether the China Business Tax is really on its way out and, if so, what it means, particularly in the transition phase to the comprehensive national VAT promised by 2015.
  • Requirements of the new VAT regime and multinationals' options for managing compliance and risk, including transition rules from Business Tax and revised national VAT return formats, potentially in simplified form.
  • Software and other tools that can help multinationals address new VAT requirements effectively and efficiently – what is out there to help businesses monitor compliance and simplify VAT return obligations in the context of the Golden Tax System?

Learn the latest news about the new national VAT regime.

并购
中国海外投资 并购:中俄投资之兴

2014年3月5日
主持人:朱桉
主讲人:陶然及蒋俊

中俄投资者投资俄罗斯的热潮已然到来。这位能源巨人正张开双臂,欢迎境外投资者参与其经济自由化和开放运动,藉此通过长期投资项目分享所带来的好处。这一变化会带来什么样的机会?投资者的担忧是什么?他们应该采取什么样的投资策略?我们将讨论:

  • 开放的俄罗斯市场纵览,包括面向境外投资者的政策红利所带来的各种投资机会、如特别经济区、远东和西伯利亚地区的发展大潮、国企私有化运动,繁荣的基础设施建设以及依靠快速成长的中产阶级的新兴消费市场。
  • 详细的行业分析,主要集中在具有过往出众表现和强劲潜力的行业,如能源资源业、制造业和农业。
  • 细致的当地投资环境介绍,包括外国投资者风险,政府近期关于提高营商环境所做的努力,以及在跨境并购过程中,中国投资者在税务、会计和产权方面应注意的事项。
  • 中俄投资的案例分析。

请参与此网络讲座,了解更多中国投资者投资俄罗斯的活动及重点。

(请收听于2月26日播放的相关英语讲座。详情请访问 Mergers & Acquisitions 网页 。)

International Tax
Centralized Procurement and Shared Services: Emerging Issues and Opportunities

4 March 2014
Host: Tom Ewigleben
Presenters: Rohinton Sidhwa and Paul Zanker

Greater competition, an increasingly complex global business environment, and pressures to squeeze more profits out of the value chain are driving companies to consider shared services and procurement as functions which can drive value creation and operational performance. What are specific operational and tax considerations for setting up and operating procurement companies (Procos) and shared services centers (SSCs)? We'll discuss:

  • Proco and SSC models' best practices being adopted in various industries and how they may fit into regional operating models.
  • Potential operational benefits of operating under a Proco or SSC model.
  • Transfer pricing issues arising around these models in Asia Pacific jurisdictions and supporting deductions for related payments.
  • Asia Pacific incentive opportunities for Procos and SSCs.
  • Direct tax, indirect tax, and customs considerations of Procos in the region.
  • Conversion considerations around the transformation to a Proco or SSC model.

Learn about opportunities and issues associated with centralized procurement and SSCs, and how multinationals are addressing them across the region.

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