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International Tax
Japan's 2016 Tax Reform Proposals: Gaining Momentum

4 February 2016
Host: Jun Takahara
Presenters: David Bickle, Brian Douglas, and Sam Gordon

Consistent with the prior year, Japan's 2016 tax reform proposals support the government's policies specifically intended to enhance Japan's international competitiveness, promote direct investment into Japan, and encourage domestic economic growth. There is a continuous push to reduce the corporate tax rate while broadening the tax base and significant amendments to the consumption tax regime. We'll discuss:

  • The 2016 tax reform proposals and the expected impact to corporations and individuals.
  • BEPS and potential impact on inbound Japanese investment.
  • Introduction of the multi-rate consumption tax system and lessons learned so far from the 1 October 2015 implementation of new consumption tax rules affecting cross-border digital services.
  • Recent court decisions and important updates to Japan's treaty network.

Keep abreast on direct and indirect tax matters affecting companies and individuals in Japan.

(Tune in to the Japanese version of this webcast. Please visit the Japanese Language Webcasts website for program details.)

International Tax
BEPS Reports: Impact on Common Business Models

2 February 2016
(Length of webcast: 90 minutes)
Host: Steve Towers
Presenters: Leonard Khaw, Alyson Rodi, and Cam Smith

Business models need to be re-assessed in the light of the BEPS Reports which were issued in October 2015. In this webcast, which is an update of our webcast from August 2015, we will review a number of common business models in Asia Pacific, and identify the likely impact of the BEPS Reports. We will also consider 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 structures.
  • Digital supplies.
  • Management 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 Reports on common business models in Asia Pacific.

Industries – Financial Services
Hong Kong Corporate Treasury Centre Regime: Could it Benefit Your Company?

29 January 2016
Host: Patrick Yip
Presenters: Anthony Lau, Samantha Tan, and Davy Yun

The Inland Revenue (Amendment) (No. 4) Bill 2015 (the Bill), which was introduced into the Legislative Council on 16 December 2015 for First Reading, contains draft legislation that will provide tax concessions to qualifying corporate treasury centres (CTCs) in Hong Kong on qualifying corporate treasury profits, and deductions on interest paid to overseas associated corporations. This new legislation is designed to attract foreign companies and companies from the Mainland China to establish their CTCs in Hong Kong to provide centralized treasury management services for their group companies. How can a company benefit from the new legislation? We'll discuss:

  • The overview of the new CTC rules – what is a "qualifying CTC", what corporate treasury activities qualify for tax concessionary treatment?
  • What are the limitations and potential practical issues of adopting the CTC rules?
  • What is the longstanding constraint on interest deductibility in Hong Kong and how would the new interest deductibility rules lift that constraint?
  • Possible impact of the BEPS project.

Understand the key concepts introduced in the Bill and how they may benefit, or impact, your company.

India Spotlight
Masala Bonds: Alternative Funding Route for Indian Companies?

21 January 2016
Host: Hemal Zobalia
Presenters: Pravin Agarwal, Pooja Balachandar, and Harsha Rawal

Recently, Indian companies have been permitted to issue Rupee-denominated bonds overseas to broaden avenues of foreign funding. Overseas debt is usually subject to various restrictions, however, issuance of these bonds is offered relaxations such as widened scope for end use, availability to all kinds of investors, possibility of listing overseas, etc. Furthermore, there is a proposed low withholding tax of 5% to be introduced for these bonds along with the exemption from capital gains tax. What do you need to know about this new type of bonds? We'll discuss:

  • How this bond is taken as an alternative funding route from a regulatory perspective.
  • Comparison with other existing debt instruments.
  • Interpretational issues including end-uses, etc.
  • Implications under other regulations such as Companies Act.

Understand more about this tax-efficient new instrument that might open up more possible structuring opportunities.

China Spotlight
Discussion on Enhanced R&D Super Deduction and Focused Inspections on High and New Technology Enterprises (HNTEs)

19 January 2016
Host: Patrick Yip
Presenters: Clare Lu, Jessie Wang, and Xun Wang

On 3 November 2015, the PRC government issued a new guidance on Enhanced Super Deduction for Research & Development (R&D) Expenses (Circular 119) to encourage more businesses to invest in R&D activities. The guidance expands the scope of the super deduction for R&D expenses incurred by domestic enterprises and streamlines the related administrative procedures relating to the super deduction. Prior to Circular 119, the PRC government published another circular, Guokefahuo [2015] No.299 (Circular 299), announcing the results of inspections conducted in 2014 in eight provinces and municipalities that focused on verifying the status of HNTEs. Circular 299 indicated that the authorities want to ensure only qualifying enterprises benefit from such incentives, and, as such, verification of HNTE status likely will become increasingly pervasive and regular. This warrants the attention of enterprises that are in the process of applying for HNTE status, as well as those that currently enjoy HNTE status. We'll discuss:

  • Enhanced super deduction for R&D expenses
    • Highlights of the new super deduction rules
    • Major changes from current rules
    • Areas of focus in practice
    • Expected implications and suggested responses 
  • Incentives for HNTEs
    • Background and key points of Circular 299
    • Focus areas and key trends of the inspections to verify HNTE status
    • Expected implications and suggested responses

Staying on top of the latest regulatory developments in these areas would help you understand the potential implications on your R&D activities and capture the maximum benefits for your business.

(Tune in to the Putonghua version of this webcast. Please visit the Chinese Language Webcasts website for program details.)

Global Mobility, Talent & Rewards
Global Mobility: No More Secrets!

15 December 2015
Host: Tony Jasper
Presenters: Alok Agrawal, Irene Atmawijaya, and Frances Somerville

Recently, we have seen trends emerging globally and in Asia Pacific as tax authorities seek to deal with maintaining revenue in more turbulent economic times by finding ways to ensure the correct tax revenues can be collected. As business, and especially commerce, is undertaken without regard to borders, how can authorities share better information and develop strategies to deal with the new borderless business environment? We'll discuss:

  • Trends around increased information gathering, such as India's "Black Money" reporting and Japan's asset reporting, and dealing with strategies to prevent tax loss across borders.
  • Impact of authorities' latest thinking for tax strategy and their goals on the tax environment in Asia Pacific along with global initiatives.
  • How does tax governance impact employers and mobile employees in Asia Pacific and what is the future outlook?

Listen to what the tax authorities are thinking and what this can mean for the tax environment for employers and mobile employees.

Indirect Tax
Brave New VAT World: Guidelines on Business-To-Consumer (B2C) Transactions

10 December 2015
Host: Robert Tsang
Presenters: Bruce Hamilton, Aili Nurk, and Jun Takahara

In November 2015, the OECD is planning to release the final agreed version of Indirect Tax guidelines on B2C transactions as part of an ongoing initiative to standardize international VAT/GST rules. Input has been sought not just from the tax authorities of the 34 member countries of the OECD (including Australia, Japan, Korea, and New Zealand in Asia Pacific), but also from a broad range of businesses and VAT/GST authorities of India, Malaysia, Singapore, and other countries in Asia Pacific. How might a standard set of international VAT/GST B2C rules play out locally across the region? How will the guidelines work and how might you and your business benefit? We'll discuss:

  • What do the new consolidated guidelines contain, including how digital or electronically supplied services will be taxed – these indirect taxes should not be a burden to businesses, and can the consistent application of taxability and place of supply rules be achieved to eliminate double taxation?
  • Highlights of the OECD Global Indirect Tax meeting in November 2015, including worldwide perspectives on implementing VAT/GST, designing efficient and equitable indirect tax systems, and applying VAT/GST to international trade.
  • Potential practical implications for businesses operating in Asia Pacific, with highlights in Japan, Malaysia, and Singapore.

Explore the latest developments of these guidelines and identify potential prospects for your business.

Transfer Pricing
BEPS: Implementation of Transfer Pricing Changes (Part 2: India and Southeast Asia)

8 December 2015
Host: Paul Riley
Presenters: Anis Chakravarty, Carlo Navarro, and Stuart Simons

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 2 webcast, our focus will be on India and Southeast Asia. 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 India and Southeast Asia.

India Spotlight
Decoding Regulatory Changes: Preparing You for Doing Business in India

3 December 2015
Host: Hemal Mehta
Presenters: Mehul Modi and Sanjeev Shah

Recent times have seen a number of changes being made in Indian Corporate Laws and Regulations to attract investments into India and also to facilitate doing business in India. What are these changes and how would it change the approach of doing business in India including other developments you need to be aware of? We'll discuss:

  • Changes to the Foreign Direct Investment Policy and related Foreign Exchange Regulations.
  • Simplification announced for implementing the Companies Act 2013.
  • Other regulatory measures for ease of doing business in India.

Stay up to date with these regulatory changes to find out what you need to prepare when doing business in India.

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.

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