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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.



India Spotlight
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.

Indirect Tax
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. 

International Tax
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.

International Tax
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.

International Assignments
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.

International Tax
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.

India Spotlight
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.

M&A Tax
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
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.

China Spotlight
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.

International Tax
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.

Indirect Tax
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.

Special Edition
Transfer Pricing
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.


司会進行:上田 理恵子
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
  • 国別報告書、マスターファイル、ローカルファイルの必要項目と留意点
  • 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

Industries – Energy & Resources
Oil & Gas in Myanmar: Issues, Challenges, and Opportunities

23 September 2014
Host: Chris Roberge
Presenters: Aye Cho and Steven Yap

Myanmar has attracted significant interest from foreign investors as it has the 10th largest gas reserves in the world plus significant oil reserves – most of which remains largely unexplored. Moreover, oil and gas has been identified by the Myanmar Government as a focus industry to drive national economic progress. What should you know as an international company interested in delving into this market? We'll discuss:

  • New social and economic reforms that have allowed for more international companies to enter this market.
  • Oil and gas developments.
  • Key tax incentives and regulatory matters such as Production Sharing Contract (PSC) with Myanmar Oil and Gas Enterprise (MOGE) and Foreign Investment Law (FIL) with Myanmar Investment Commission (MIC).
  • Practical tax strategies including appropriate holding company locations to minimize Myanmar tax exposures for investing into this market.

Gain insights on the latest oil and gas developments in Myanmar. 

Transfer Pricing
Profit Split Analysis and the Role of Intangibles, Capital, and Risk

18 September 2014
Host: Arindam Mitra
Presenters: Jun Sawada and Jacques Van Rhyn

The profit split method is receiving renewed attention as tax authorities look to apply this method in innovative ways to challenge existing transfer pricing methodologies. The OECD's BEPS initiative is likely to provide added impetus to this trend, especially in the context of location savings, hard to value intangibles, and transactions that rarely occur between third parties. We'll discuss:

  • The regulatory foundations for the application of this method.
  • The economic foundations of this method including the role of intangibles, capital and risk.
  • Some recent approaches taken by tax authorities – for example, functional profit split.
  • Guarding against formulary or subjective approaches.

Explore important details of this rapidly changing area of transfer pricing and recent developments.  

International Tax
Inbound Investment into Japan: The Road Ahead

11 September 2014
Host: Jun Takahara
Presenters: David Bickle, Mark Brandon, and Brian Douglas

Japan's ruling party continues to look to tax reform as a way to support its efforts to engineer sustainable economic growth. Pushing on the one hand for tax incentives and a reduction in the headline rate of corporation tax, the government must also decide whether to proceed with its plans for a second hike in the consumption tax rate from 8% to 10% in October 2015. But what will the impact of these proposals be for companies and individuals? We'll discuss:

  • The impact of the consumption tax hike in April 2014, and the increase planned for next year.
  • BEPS and the potential impact of Japan's response.
  • Recent tax audit experience and focus in respect to inbound investments.
  • Highlights on what to expect in Japan's 2015 tax reform.

Gain valuable insights on the latest Japan tax issues – what to expect and how to prepare.

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.

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