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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.



Transfer Pricing
BEPS: Implementation of Transfer Pricing Changes (Part 1: Australia, Japan, China, and Korea)

26 November 2015
Host: Paul Riley
Presenters: Yoshihiro Adachi, Brad Edwards, Tae Hyung Kim, and Eunice Kuo

As the OECD / G20 BEPS project has moved into the implementation phase, we will provide an update of domestic legislative activities and timelines to incorporate the various BEPS transfer pricing changes into specific domestic tax regimes. We will also cover harmonization efforts for transfer pricing documentation rules and requirements from local perspectives. In this Part 1 webcast, our focus will be on Australia, Japan, China, and Korea. We'll discuss:

  • Changes to the OECD’s Transfer Pricing Guidelines (TPG): will they be applied by the respective countries?
  • Mechanism for local country adoption of TPG changes: legislation, regulation, administrative ruling, other?
  • Start date / grandfathering.
  • Country-by-country reporting and master file / local file transfer pricing documentation.

Find out how these significant transfer pricing changes will likely be implemented in Australia, Japan, China, and Korea.

Indirect Tax
Recharges, Disbursements, and Reimbursements: Indirect Tax Field of Dreams or Minefield?

24 November 2015
Host: Robert Tsang
Presenters: Anjlika Chopra and Eng Yew Tan

Recharge of expenditure or costs from one entity to another entity is a globally accepted practice and is used to accomplish various objectives. They come under increasing scrutiny given the BEPS developments and changes in Transfer Pricing requirements. What does this mean for Indirect Tax purposes? Are such charges within the scope of Indirect Tax – do you charge VAT or GST? Is a tax invoice required, and if so, what needs to be on the invoice? Is there a tension between Direct Tax / Business Tax and Indirect Tax here? We'll discuss:

  • Recharges, disbursements, and reimbursements – experience in Asia Pacific.
  • Nature of typical inbound and outbound recharges.
  • Typical indirect tax issues and guidelines – Singapore, Malaysia, and India in particular.
  • Case studies on some of the practicalities.

Gain a better understanding of the potential impacts and get input on devising an appropriate strategy and process.

Transfer Pricing
Recent Learnings from Advance Pricing Agreement (APAs): China and India

17 November 2015
Host: Anis Chakravarty
Presenters: Sanjay Kumar and James Zhao

Transfer pricing controversies are growing and tax authorities are adapting their APAs for the increased caseload. We will discuss the key learnings from recently concluded APAs in China and India:

  • Accepted TP methods and specific adjustments by function and industry.
  • Some accepted approaches for dealing with location specific advantages.
  • Deviations from historical globally accepted approaches.
  • Best practices for speedy bilateral resolution.
  • Bilateral and multilateral APAs.

Stay up to date with these latest developments on APAs in these two countries.

International Tax
Base Erosion and Profit Shifting (BEPS): The Final Reports (Part 2: Non-Transfer Pricing)

4 November 2015
*Length of webcast: 75 minutes
Host: Steve Towers
Presenters: Leonard Khaw, Ben Pickford, and David Watkins

With the publication of the final BEPS reports in October, it is now time to consider the significant recommendations (in regard to non-transfer pricing topics) which have been described in the reports. In particular, it is time to focus on the big "judgement calls" which the OECD has made in finalizing the reports. Our discussion will include:

  • Action 2: hybrid mismatch arrangements.
  • Action 4: interest deductions.
  • Action 6: treaty abuse.
  • Action 7: PE definition.
  • "2016 issues".

Find out the important changes to non-transfer pricing topics which have been described in the BEPS final reports.

Special Edition - Transfer Pricing
SAT's Draft Guidance on Transfer Pricing Rules and BEPS Initiatives: A Road Map

29 October 2015
Host: Eunice Kuo
Presenters: Patrick Cheung, Wei Shu, and James Zhao

China's State Administration of Taxation (SAT) has released a discussion draft of "Special Tax Adjustment Implementation Measures" on 17 September 2015 that would comprehensively revise Circular 2, the existing guidance in this area. Circular 2 was issued in 2009 and is China’s main guidance concerning transfer pricing rules, documentation, audits and adjustments, as well as cost sharing arrangements (CSAs), controlled foreign companies (CFCs), thin capitalization, the general anti-avoidance rule (GAAR), etc. This draft incorporates a number of recommendations of the OECD in the context of the base erosion and profit shifting (BEPS) initiative, but it also takes into account China's unique economic environment and factors relevant to this revision of Circular 2. The draft also includes new chapters addressing intangible assets, intragroup services transactions, value chain analysis, and profit level monitoring. We'll discuss:

  • A clear road map to aid you to navigate the draft revised Circular 2.
  • How the provisions will likely impact your business.
  • Comparison with the BEPS report on Actions 8-10.
  • Steps to be taken to prepare your business for its eventual implementation.

Stay up to date on this new draft guidance and find out how it may affect your business.

* The Chinese language webcast is held on 5 November, please click here for more details.

International Tax
Base Erosion and Profit Shifting (BEPS): The Final Reports (Part 1: Transfer Pricing)

28 October 2015
* Length of webcast: 90 minutes
Host: Steve Towers
Presenters: Anis Chakravarty, Samuel Gordon, and Cam Smith

With the publication of the final BEPS reports in early October, it is now time to consider the significant changes to transfer pricing (both technical and practical) which have been described in the reports. In particular, it is time to focus on the big "judgement calls" which the OECD has made in finalizing the reports. Our discussion will include:

  • Allocation of risk between related parties: contracts versus conduct.
  • Intangibles.
  • Cost contribution arrangements.
  • Fragmented activities.
  • Transfer pricing documentation: Country-by-Country Report, Master File, Local File.
  • "Adoption" of the changes by individual countries: issues and challenges.
  • "2016 issues" – in particular, profit splits.

Find out the important changes to transfer pricing which have been described in the BEPS final reports.

International Tax
Inbound Investment into Indonesia: A Primer

30 September 2015
Host: Daniel Ho
Presenters: John Lauwrenz, Carlo Navarro, and Cindy Sukiman

In recent years, Indonesia's economic potential has attracted significant amounts of foreign investment. However, a recent tax complexity survey conducted by Deloitte revealed that most tax executives felt the tax regime of the country has grown more complex in the last three years. What do you need to be aware of and how can you effectively manage potential tax exposures when pursuing investments into Southeast Asia's largest economy? We'll discuss:

  • Recent and proposed changes affecting inbound investments into Indonesia, with a focus on areas such as tax facilities, tax holidays, revenue collection efforts, proposed reduction of corporate tax rate, etc.
  • Recent changes to the transfer pricing regulations.
  • Increased focus on tax audits as a revenue collection measure – challenges and cases.

Discover the latest inbound investment climate in Indonesia and how it affects your investment strategies into Indonesia.

Indirect Tax
How do the New GST Rules Compare: India, Malaysia, and the OECD International VAT Guidelines? Chalk and Cheese?

22 September 2015
Host: Robert Tsang
Presenters: Odile Courjon, Kah Seong Fan, and M.S. Mani

In Asia Pacific, there are many new indirect tax systems being introduced. The Malaysian GST went live on 1 April 2015, and India moves forward with a dual GST that may be in force as early as 2016. What are the latest developments in the two countries? We'll discuss:

  • How do these new rules compare to the framework being developed by the OECD for International VAT / GST Guidelines?
  • Are exports and imports taxed in a similar way in India and Malaysia?
  • Do the OECD Guidelines allow businesses to create a framework where there is no double taxation (or worse) for GST in either country?
  • Are non-resident suppliers of goods or services really subject to GST obligations in India and Malaysia – and what about the corporate income tax implications of a GST registration?

Stay current and find out how this may affect the way your business handles cross-border transactions and in-country transactions in both goods and services.

Industries – Financial Services
Hong Kong Extended Offshore Funds Law for Private Equity Funds: Is There More Than Meets the Eye?

17 September 2015
Host: Patrick Yip
Presenters: Anthony Lau and Davy Yun

The Inland Revenue (Amendment) (No. 2) Ordinance 2015 (the Extended Offshore Funds Law) was enacted on 17 July 2015, extending profits tax exemption to non-resident private equity (PE) funds. This new legislation has been widely anticipated by the PE industry in Hong Kong and is expected to benefit many non-resident PE funds with fund management operations in Hong Kong. How PE funds can benefit from the Extended Offshore Funds Law and what are the potential pitfalls that PE funds should be aware of? We'll discuss:

  • What is an "excepted private company" – practically speaking?
  • What benefits are available to a special purpose vehicle used to hold your investment, and the operational considerations?
  • What is a "qualifying fund" and how might it interact with existing deeming provisions?
  • How might increased operational flexibility impact the fund management group and their remuneration?

Understand the key concepts introduced in the Extended Offshore Funds Law and how they may benefit, or impact, your PE fund.

International Assignments
Business Travelers Go Global: Managing the Risks

15 September 2015
Host: Don Riegger
Presenters: Russell Bird, Daniel Walker, and Hong Ye

For many businesses, the short term business traveler is an essential resource. However, encouraging employees to travel across international borders fulfilling immediate business staffing needs or meeting with overseas colleagues or clients inevitably presents tax compliance risks. Employees working in multiple locations are often senior executives whose cross-border travel is rarely covered by an international assignment policy. They typically do not cease home location tax residence yet can still trigger tax obligations and liabilities in other jurisdictions, both for themselves as employees, and for their employer. In this session, we will explore these risks from an individual tax compliance perspective together with the employer tax costs and permanent establishment (PE) issues. We'll discuss:

  • Who are short term business travelers and what are the key issues which companies struggle with to manage business traveler risk?
  • What are the factors driving companies to take action?
  • What data sources can help companies in managing this population and the associated risk?
  • Case studies of business travelers moving around Asia Pacific creating PE / corporate tax risks, individual and employer tax obligations, and immigration issues.

Discover the risks and possible solutions to ensure employees and employers comply with global tax obligations.

Transfer Pricing
Transfer Pricing Developments in India: Range, Multiple Year Data, Advance Pricing Agreements, and Audits

10 September 2015
Host: Anis Chakravarty
Presenters: Manisha Gupta and Sanjay Kumar

Recent transfer pricing developments in India include proposals from the Government to reduce the extent of audits and litigation. The range and multiple year data concept will soon be incorporated into law. Furthermore, some high profile judgments are ensuring that the path to transfer pricing certainty slowly becomes clear in India. What does this mean for your Indian operations? We'll discuss:

  • Impact of the range and multiple year data concept on intercompany transactions.
  • Latest happenings in audit and tax scrutiny.
  • Status of the Advance Pricing Agreements (APA) program.
  • Review practical implications of key rulings and understand how they affect transactions.

Find out how companies impacted by Indian transfer pricing can navigate the regime with these updates.

International Tax
Inbound Investment into Taiwan: Keeping up with The Changes

8 September 2015
Host: Jun Takahara
Presenters: Arthur Chen and Cheli Liaw

For years, Taiwan has remained as a key location for contract manufacturing and R&D because it has a large talent pool and friendly investment environment. However, what opportunities and challenges should foreign investors consider when entering this vibrant market? We'll discuss:

  • Business and regulatory environment for inbound investment.
  • Foreign investment update.
  • Proposed tax regulation update.
  • Recent tax audit cases.

Gain a clearer understanding of the inbound investment climate in Taiwan and consider ways for your company to make tax-efficient moves there.

Industries – Energy & Resources
The Taxation of Service Providers in Timor-Leste and the Joint Petroleum Development Area (JPDA)

1 September 2015
Host: Francis Thomas
Presenters: Nilesh Sewpal

Investment opportunities abound in Southeast Asia’s youngest country, Timor-Leste, and in the Timor Sea. What do you need to know when investing in this market? We’ll discuss:

  • Tax incentives available to new investors in Timor-Leste.
  • The taxation of service providers in the non-petroleum sector.
  • The taxation of service providers in the petroleum sector in Timor-Leste and in the JPDA.
  • Transfer pricing.

Don’t get left behind: find out what you need to know when investing in Timor-Leste.

India Spotlight
India's New Export Incentive Schemes: A Real Boost for Exporters of Goods and Services

27 August 2015
Host: Prashant Deshpande
Presenters: Monika Arora, Kumar Kandaswami, and Saloni Roy

In line with the Government's vision to make India a manufacturing powerhouse over the next decade and to spur foreign investments in the manufacturing sector, the recently announced Foreign Trade Policy (FTP) contains various measures that will promote growth in the domestic manufacturing sector. As a step further to raise the global competitiveness of the Indian manufacturing and service sectors, the new FTP has revamped various export incentives available to the exporters of goods and services. The two new schemes under the FTP, namely Merchandise Export from India Scheme (MEIS) and the Service Exports from India Scheme (SEIS), aim to provide benefits to all exporters doing business in India. We'll discuss:

  • Overview of the "Make in India" initiative of the Government.
  • Background and challenges under the former schemes under which export incentives were given.
  • Key features and advantages of MEIS and SEIS, and how these will benefit the export sector.

Understand the new policy initiatives and the nuances of the new schemes.

International Tax
Base Erosion and Profit Shifting (BEPS): Likely Impact on Common Business Models in Asia Pacific

18 August 2015
(Length of webcast: 75 minutes)
Host: Steve Towers
Presenters: Leonard Khaw, Ben Pickford, and Cam Smith

Business models need to be re-assessed in the light of the BEPS Project. In this webcast, we will review a number of common business models in Asia Pacific, and identify the likely impact of the BEPS Project. We will also canvass a number of potential responses. In particular, we'll discuss:

  • "Supply chain" structure involving the manufacture and sale of goods, with a Singapore principal.
  • Procurement structure.
  • Digital supplies.
  • Contractual allocation of risk.
  • Payments of royalties to the legal owner of intangibles.
  • Holding company structure.
  • Group finance company.
  • Fund management.

Identify the potential impact of the BEPS Project on common business models in Asia Pacific.

Industries – Financial Services
FATCA and CRS in Asia Pacific: Developments and Next Steps

13 August 2015
Host: Jim Calvin
Presenters: Candy Chan, Sean McGrady, and Alison Noble

The automatic exchange of information is rapidly becoming the global standard. Many countries have committed to implementing the OECD's Common Reporting Standard (CRS) beginning in 2017 and with others following in 2018. At the same time, the U.S. Foreign Account Tax Compliance Act (FATCA) continues to pose challenges. CRS builds upon FATCA, and is intended to provide a global standard for the automatic exchange of financial account information between governments, but there are differences between FATCA and CRS and between jurisdictions. We'll discuss:

  • An update on Intergovernmental Agreements and FATCA guidance.
  • An overview of the current position of jurisdictions in Asia Pacific for CRS, highlighting differences between jurisdictions.
  • The main differences between CRS and FATCA, including concessions.
  • How these differences can affect CRS implementation and current FATCA activity.
  • The road forward.

Learn about the current status of these global standards in Asia Pacific and how you should prepare going forward.

Indirect Tax
VAT and GST Refunds: Is Your Business Taking Maximum Credit?

6 August 2015
Host: Robert Tsang
Presenters: Olivier Hody and Turmanto

VAT, GST, and other indirect taxes are at least a cash flow cost to businesses. With refund mechanisms being available to businesses in Asia Pacific, companies will need to find out if their business is taking maximum credit. Are you doing what you need to help your business recover VAT, GST, or similar taxes in each country in which you operate? How are you ensuring that employee expense reporting and reimbursement systems maximize the potential for recovery of indirect tax? Are you getting the required invoices and other documentation to support your claims to input tax on costs flowing through accounts payable? Most businesses in the region also incur significant overseas VAT or GST – are you allowed to recover this tax and what are the protocols and procedures for recovering these transaction taxes? We will examine this issue with a focus on Australia and Indonesia. We'll discuss:

  • Refund mechanisms, for registered taxpayers and separately for non-resident businesses.
  • Good practices in dealing with VAT / GST incurred outside of the "home" country, drawing on the long-established European Union VAT refund mechanisms.

Understand more on the VAT and GST landscape and find out how your business can manage indirect taxes more effectively.

China Spotlight
Bulletin 16: A Significant China Tax Guideline on Outbound Payments to Related Parties

4 August 2015
Host: Eunice Kuo
Presenters: Victor Li and Aaron Wang

Most MNCs in China have encountered various challenges on outbound payments to related parties in the past, and outbound payments have been listed as one of the top challenges for MNCs doing business in China. To streamline transfer pricing practices in China and in considerations of the BEPS principles, the State Administration of Taxation (SAT) has published Bulletin 16 on 18 March 2015 as a comprehensive guideline regarding outbound payments. We'll discuss:

  • Background of the release of Bulletin 16.
  • Specific tests and principles in determining the tax deduction entitlement of the service / royalty fees.
  • Practices and cases we have seen since the issuance of Bulletin 16.
  • Consistency between Bulletin 16 and the BEPS Project?
  • Our observations and recommendations.

Gain insights on the context of China's focus on tax compliance and protecting its tax base, and how to formulate an effective tax controversy strategy in cases of disputes.

India Spotlight
India's Finance Act and Recent Developments: The Road Ahead

28 July 2015
Host: C.A. Gupta
Presenters: Pritin Kumar and Himanshu Patel

The proposals of the Indian Finance Act 2015 are now in force and there are significant developments for foreign investors. In addition to the amendments in law by the Finance Act, there have been several other developments on the tax front. What are the amendments in law and recent developments you need to be aware of? We'll discuss:

  • Indirect transfer of shares of an Indian company.
  • Tax rate on royalties and fees for technical services and minimum alternate tax on foreign companies.
  • Secondment of personnel to India.
  • New rules relating to place of effective management.
  • Update on India's proposed general anti-avoidance rule.
  • Other updates and emerging tax controversies.

Stay up to date with the latest international tax developments in India.

Transfer Pricing
OECD Transfer Pricing Guidelines: Nearing the Finish Line

23 July 2015
* Length of webcast: 75 minutes
Host: Arindam Mitra
Presenters: Brad Edwards, Vishweshwar Mudigonda, and Alan Shapiro

As of early July, the OECD is in the final stretch of completing its work on the Transfer Pricing Guidelines, in response to its Action Plan on Base Erosion and Profit Shifting (BEPS). What are the latest developments, and what changes are coming? We'll discuss:

  • Recent Discussion Drafts on Cost Contribution Arrangements and Hard to Value Intangibles.
  • Potential changes to Chapter I rules regarding risk and recharacterization.
  • Potential implications of these changes as they relate to Chapter VI rules regarding intangible property.
  • Potential impacts of these changes on multinational companies.

Hear an update on OECD's recent activity and what to expect next.

Transfer Pricing
Market Characteristics or Intangibles: An Analytical Framework

30 June 2015
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.

Indirect Tax
Malaysian Post-GST Evaluation: Have You Achieved the "Pass" Grade?

25 June 2015
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.


主讲人:方建国 ﹑ 祝志筠 ﹑ 宋姣琳及唐晔


  • 有关境外股权转让中涉及间接转让中国应税财产的7号公告在实践中的运用。
  • 各城市在实施关于合格境外投资者从2014年11月7日之前取得收入的79号公告的实务差异。
  • 预计转让定价监管方面的关键变化,特别是地域性优势的运用以及利润分割法的应用推广。
  • 税基侵蚀与利润转移背景下的税收案例。
  • 营改增改革有望在2015年完成,届时将覆盖金融保险业,建筑业,房地产业,及生活类服务业。
  • 即将出台的税收征管法修正案及争议中的纳税人权利保护和相关行政执法程序。


(请收听已于6月11日播放的相关英语讲座。详情请访问 Dbriefs Library 网页。)

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

18 June 2015
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.

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

16 June 2015
*Length of webcast: 75 minutes
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 aired on 2 June 2015. Click here to register.

China Spotlight
China's Hottest Tax Developments: Latest Tax Rules, BEPS, VAT Reform, and Taxpayer Rights

11 June 2015
Host: Hong Ye
Speakers: Candy Tang, Aaron Wang, and Elaine Zhang

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

10 June 2015
*Length of webcast: 75 minutes
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.

India Spotlight
Goods and Services Tax (GST) in India: What's in Store for the Services Sector?

9 June 2015
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.

Indirect Tax
Cross-border Digital Services: A Brave New World for Indirect Tax?

4 June 2015
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
Income Computation and Disclosure Standards (ICDS): What Will be the Impact on Your Tax Outgo?

3 June 2015
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
Base Erosion and Profit Shifting (BEPS): What's Happened So Far? And What's Next? (Part 1: Transfer Pricing)

2 June 2015
*Length of webcast: 75 minutes
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) was aired on 16 June. Click here to register.

M&A Tax
Business Model Optimization (BMO): Opportunities Following a Merger and Acquisition

28 May 2015
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 Assignments
Global Mobility in India: Latest Trends in Tax, Social Security, and Immigration for Mobile Employees and Employers

21 May 2015
Host: Divya Baweja
Presenters: Tapati Ghose and Sudhakar Sethuraman

Over recent years, India has become an increasingly attractive market for businesses looking to increase their global markets when growth in their existing markets has started to decline. At the same time, the economic development of Indian businesses has seen them looking outside India for business opportunities. For foreign businesses trying to enter the India market or for Indian businesses trying to gain prospects overseas, an important component will be the mobility of employees moving into and out of India. What are the tax, social security, and immigration issues impacting businesses that have mobile employees coming to or leaving India to work? We'll discuss:

  • Highlights from the 2015 Indian Budget – what are the impacts likely to be upon employees and employers.
  • Examine year end considerations including procedural changes for employer filings and individual tax returns.
  • Recent updates on important decisions and notifications in the areas of tax, social security, and immigration.

Stay up to date with the latest trends in global mobility with a focus in India.

Industries – Financial Services
Changing Landscape for Financial Service Industry (FSI) Treasury: Liquidity, Funds Transfer Pricing (FTP), and BEPS

19 May 2015
Host: Carl Church
Presenters: Anis Chakravarty, Geoff Gill, Samuel Gordon, and Wei Shu

The FSI treasury requirements have been changing rapidly since the financial crisis and the pronouncement of Basel III. With the release of the OECD Public Discussion Draft on BEPS Action 4 (Interest Deductions and Other Financial Payments) and the expectation of OECD guidance on the transfer pricing of intercompany treasury transactions, FSI multinational corporations expect even more changes. Where is it all headed in Asia Pacific and what are the implications to be aware of in the region? We'll discuss:

  • Tax consideration for Basel III driven Liquidity and FTP.
  • Existing tax environment in the region.
  • The implications of the BEPS guidance.
  • The road forward in the region.

Gain insights into these developments across Asia Pacific and discover how they impact the financial services firms.

Indirect Tax
Goods and Services Taxation in India: A New Beginning

14 May 2015
Host: Robert Tsang
Presenters: Prashant Deshpande and Ramaratnam Muralidharan

The introduction of Goods and Services Taxation (GST) in India has seen numerous delays caused by many factors, such as concerns over the loss of fiscal autonomy enjoyed thus far and issues surrounding which taxes to subsume and which goods to exclude from GST. The new Government has, however, shown serious intent of pushing forward with this important tax reform. The Loksabha (lower house of the Parliament) has passed the Constitution amendment bill with an overwhelming majority on 6 May. As the origin-based Value Added Tax (VAT) system gives way to consumption-based tax systems in the proposed GST in India, all stakeholders will need to gear up to meet the challenges. We’ll discuss:

  • Current state of the indirect taxes and what GST promises.
  • Constitution amendment and proposed structure.
  • Challenges in migrating to the new business procedures and key functional issues.
  • Lessons to be learnt from regional developments on tax reforms, mainly in Malaysia and China.

Gain valuable insights from practical experiences and discover the developments in the exciting journey of this radical reform in India.




  • 股权转让的适用范围。
  • 股权转让收入的确认和核定。
  • 转让双方及被转让企业的纳税申报义务和协助义务。
  • 税务机关的征管措施与最新进展。
  • 相关实务探讨。


한국 관세제도 및 최근 동향

2015년4월 29일
진행자: 정 인영
발표자: 신 승학, 정 진곤

2013년 추진된 '지하경제양성화'의 일환으로 관세청이 심사와 조사 등의 인력을 두 배로 늘리고 심사 대상기업도 세 배로 확대하는 등 세수확보에 총력을 기울이고 있습니다. 올해에도 총 1조 4,000억 원의 세수를 거두겠다는 목표로 많은 기업들이 관세 심사 등의 대상이 되고 있으며, 특히 거래가격이 왜곡될 수 있는 특수관계기업이 타깃이 되어 많은 세액이 추징되어 왔습니다. 이렇듯 관세 관련 위험이 증가하고, 최근 한-호주, 한-캐나다 FTA 등 잇따른 FTA의 발효로 인한 관세 관련 혜택 또한 증가함에 따라 ‘관세’의 중요성은 날로 커지고 있습니다.

딜로이트 덕진관세법인에서는 한국 관세제도의 변천과 최근의 관세 관련 동향을 주제로 온라인 세미나를 개최할 예정이며 아래와 같은 내용이 포함될 것입니다.

  • 한국 관세제도의 변천
  • 2015년 관세법 주요 개정 사항
  • 최근 심사/조사 동향 및 관세 이슈
  • 주요 과세 CASE 및 판결례

M&A Tax
Debt Push Down: Focus on Australia and New Zealand

12 May 2015
Host: Danny Po
Presenters: Hadleigh Brock and Jeffrey Jaw

It has always been a challenge for investors to obtain tax deductions on financing costs incurred in connection with M&A. In the previous quarters, we illustrated case studies in China, Hong Kong, India, Japan, Korea, and various regions of Southeast Asia. In this quarter, we will continue the discussion of this topic with a focus on Australia and New Zealand. We'll discuss:

  • Basic and special debt push down techniques in Australia and New Zealand.
  • Illustrative case studies in Australia and New Zealand applying these techniques; considering how to align interest expense with taxable operating income, taking into account cross-border transfer pricing considerations and beneficial ownership requirements.
  • Other local country specific tax structuring issues / opportunities in relation to debt structuring.

Understand the techniques and challenges on debt push down that might affect your M&A deals.

China Spotlight
Recent Tax Developments Impacting the Funds Industry in China and Hong Kong: Navigating the Uncertainties

7 May 2015
Host: Patrick Yip
Speakers: Agnes Cheung, Johnny Foun, and Natalie Yu

There are various tax developments in China and Hong Kong that would positively, or adversely, impact the funds industry. For example, the State Administration of Taxation's (SAT) clarifications on China enterprise income tax treatment of gains on the disposal of A-shares and / or other equities invested through the Hong Kong-Shanghai Stock Connect and QFIIs / RQFIIs, and the latest developments on the Financial Secretary's proposal to expand the scope of profits tax exemption to cover offshore private equity funds in Hong Kong. What are the key insights to consider when navigating the uncertainties of these changes? We'll discuss:

  • Our views on the commonly asked questions on the PRC tax treatment of gains on
    A-shares or other equities invested through the Hong Kong-Shanghai Stock Connect and QFIIs / RQFIIs.
  • Latest updates on the proposed new offshore funds law.
  • What the funds industry expects to see in 2015 and how to prepare for the changes.

Gain insights into the latest developments on the funds industry in China and Hong Kong.

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