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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 from the menu on the right.
Industries – Financial Services
BEPS Actions 8 and 13 (Transfer Pricing): Implications for the Financial Services Industry
14 October 2014
Host: Michael Velten
Presenters: Patrick Cheung, Samuel Gordon, Giles Hillman, and Robert Plunkett
In September 2014, the OECD met two BEPS action item milestones in providing guidance on intangibles and transfer pricing documentation. What are the implications that financial services firms should evaluate for their operating models and transfer pricing management? We'll discuss:
- Conclusions that financial services firms can draw from the guidance including new or persistent uncertainties.
- Actions that tax authorities are taking or signaling they will take given the OECD level changes.
- Considerations for determining priorities and timing of dealing with the change.
- Potential starting points and frameworks for dealing with the change.
Gain insights into how major changes in global transfer pricing are impacting financial services firms.
Managing the Continuous Evolution of China's VAT Reforms: Theory vs. Reality
30 September 2014
Host: Robert Tsang
Presenters: Sarah Chin and Li Qun Gao
Since the pilot reform program was introduced in Shanghai on 1 January 2012, the Chinese National VAT Reform has been introducing significant changes to the old VAT and business tax regimes. Taxpayers have witnessed continuous policy changes and implementation challenges. Although the planned completion date of the reform, the end of 2015, is only 18 months ahead, there are many sectors to be covered in the reform. What are the latest changes and what is expected in the next batch of changes? We'll discuss:
- Announcements for the latest sectors, including the telecommunications industry announcement in early May 2014.
- Developments in the implementation of the reform including the exemption of cross-border services.
- Practical steps to be taken by businesses, suppliers, and customers to handle the new reality of China's VAT system.
Understand the latest changes and developments in China's National VAT reform and how you can address them.
OECD / G20 Transfer Pricing Documentation and Intangible Guidance
29 September 2014
* Length of webcast: 75 minutes
Host: Arindam Mitra
Presenters: John Bland, Eunice Kuo, and Alan Shapiro
The G20 finance ministers are meeting on 21-22 September 2014 to approve the output from several Actions under the OECD / G20 Base Erosion and Profit Shifting (BEPS) project. Prior to the meeting, the OECD will publish new guidance on the transfer pricing documentation requirements, including country-by-country information for tax authorities. What are the proposals, how have they changed from earlier drafts, and how might they affect your organization? We'll discuss:
- The common template for providing country-by-country information to tax authorities.
- Master file and local file documentation requirements.
- Definition and new methods to value intangibles.
- Timetable and Areas that remain to be finalized.
- Potential impact of the new guidance on your organization and the action steps you should consider.
Keep up to date with these significant changes to transfer pricing under BEPS.
講師：足立 佳寛、坂本 安孝
2014年9月16日に公表予定のBEPS行動計画（Action Plan）13により、OECD移転価格ガイドライン第5章： 移転価格文書化規定が改訂されます。
- 2014年9月公表予定のBEPS行動計画13成果物： 移転価格文書化規定の改訂の概要
- 今後、日系グローバル企業が取り組むべき課題と対応策 等
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.
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.
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.
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.
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 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.
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.
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.
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.
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'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 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.
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.
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.
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.
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.
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
5月21日 12:00 – 1:00 PM (日本時間、GMT+9)
講師：村中 靖、 白澤 賢
- 株式報酬制度と海外勤務者の税務上の留意点 等
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.
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.
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