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Anticipating tomorrow's complex issues and new strategies is a challenge. Stay tuned in with Dbriefs that give you valuable insights on important developments affecting your business in Asia Pacific

Special Edition Webcast

Special Edition
Transfer Pricing
OECD / G20 Transfer Pricing Documentation and Intangible Guidance

29 September, 2:00 – 3:00 PM HKT (GMT +8)
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.

Upcoming Webcasts

International Tax
Inbound Investment into Japan: The Road Ahead

11 September, 2:00 – 3:00 PM HKT (GMT +8)
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.

온라인 세미나
Korean Language Webcasts

High Net Worth Individual Family 다국적 세무 이슈와 최근 동향

9월 17일, 2:00 – 3:00 PM KST (GMT +9)

진행자: 강 나리
발표자: 김 희술, 김 중래

국제 거래 및 투자의 기회가 증가하는 국제 경제 환경 변화에 따라 고액 자산가 및 가족의 국가간 이동이 증가하여, 이에 따른 국제 조세와 관련된 다양한 이슈가 양산되고 있습니다. 특히, 상속·증여세 과세 강화, 신탁법의 전면 개정, 금융 분야에서는 해외금융계좌 신고제도 강화, FIU 금융정보의 과세당국 제공 증가, 미국과의 조세정보자동교환협정 체결 등으로 인한 국제 조세 이슈는 더욱 심화될 전망입니다.

딜로이트 안진회계법인에서는 Global Presence를 가지고 있는 고액자산가 및 가족들의 국제 조세의 이슈들과 동향을 주제로 온라인 세미나를 개최할 예정이며 아래와 같은 주제가 포함 될 것입니다.  

  • 한국의 세법과 법률 개정의 주요 이슈 사항
  • FATCA와 해외금융자산 신고의 동향
  • 외국인의 한국 자산과 내국인의 해외자산의 상속과 증여의 주요 이슈 사항

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

18 September, 2:00 – 3:00 PM HKT (GMT +8)
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.  

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

23 September, 2:00 – 3:00 PM HKT (GMT +8)
Host: Chris Roberge
Presenters: Aye Cho and Anthony Loh

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. 

Japanese Language Webcasts
BEPS行動計画13成果物:移転価格文書化規定の改訂~新たな移転価格文書化規定の概要および対策~

2014年9月24日, 12:00 – 1:00 PM 日本時間 (GMT +9)
司会進行: 上田 理恵子
講師: 足立 佳寛

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。

改訂された移転価格文書化規定により、新たな移転価格文書の作成が要請されることになります。公表された移転価格文書化規定の概要および、今後日系グローバル企業が取り組むべき課題と対策について、国税庁出身者の見解も交え解説します。

  • 2014年9月公表予定のBEPS行動計画13成果物: 移転価格文書化規定の改訂の概要
  • 国別報告書、マスターファイル、ローカルファイルの必要項目と留意点
  • 今後、日系グローバル企業が取り組むべき課題と対応策 等

Indirect Tax
Managing the Continuous Evolution of China's VAT Reforms: Theory vs. Reality

30 September, 2:00 – 3:00 PM HKT (GMT +8)
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.

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