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Dbriefs Conversations

Dbriefs Conversations brings you discussions between Deloitte experts on current tax and business issues

November 2014

In this Dbriefs Conversations:

Tom McClelland (Tax Partner – Deloitte Vietnam) discusses recent tax changes in Vietnam particularly relevant to inbound investment into the country.

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The following specific topics are covered:

 

Time

Topic

01:28

Tax rate changes

03:08

Foreign investments – consumer goods

04:50

New tax incentives

08:50

VAT for the oil and gas industry

10:47

Foreign contractor withholding tax

13:26

Inbound sales of goods

19:36

Reduction in the compliance burden

20:50

Capital gains on exit

28:56

Lobbying the tax authorities


This video will be available until end of April 2015.

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October 2014

In this Dbriefs Conversations:

S.P. Singh (Transfer Pricing Senior Director – Deloitte Delhi) discusses current issues concerning transfer pricing in India. 

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The following specific topics are covered:

Time

Topic

0:32

1.0 Excessive AMP (advertising, marketing, and promotion) expenditure and the Special Bench case

02:19

1.1 Motorola case

08:34

1.2 BMW case

14:57

1.3 The interlink concept

19:11

2.0 Legislative changes made by Finance Act 2014

19:39

2.1 Arithmetic mean to arm's length range

21:58

2.2 Interquartile range

23:40

2.3 Multiple year data

25:05

2.4 Change in selection methodology for audits

26:42

2.5 Rollback mechanism in APA


This video will be available until end of March 2015.

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September 2014

In this Dbriefs Conversations:

Ye Hong (Qin Li Law Firm – Shanghai) discusses Chinese taxation of indirect share transfers. 

*Please note that this is a long video (50 minutes).

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The following specific topics are covered:

Time

Topic

1:26

Circular 698: disclosure requirements

- Transactions covered

- Exceptions

- Who must disclose?

- By when?

- Form of disclosure?

- Penalty for failure to disclose?

- What do we see in practice?

- SAT detection

- Disclosure obligation on purchaser?

14:38

Tax liability on seller

- Is the general anti-avoidance rule (GAAR) the basis for such liability?

- How does GAAR operate in this context?

- Purpose vs. substance

- Regulatory approval

- Listed vehicle

- Resident?

- Penalty for application of GAAR?

24:50

Collection obligation on purchaser

- Is there such an obligation? If so, in what circumstances?

- What happens in practice?

- Negotiations

- Escrow

34:00

Tax reserves

35:15

GAAR: exceptions?

- De minimis exception?

- Application to individuals?

36:35

GAAR and treaties

- Article 13: actual facts vs. recharacterized facts

-  Does recharacterization of facts under domestic law, apply also to a treaty?

- Competent authority

41:40

Expected guidance from SAT

- Internal reorganizations

43:55

Further questions

- Circular 698: share redemptions?

- GAAR: mechanics of calculation

This video will be available until end of February 2015.

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August 2014

In this Dbriefs Conversations:

Nazly Siregar (International Tax Partner – Deloitte Jakarta) discusses tax audits in Indonesia.

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The following specific topics are covered:

Time

Topic

0:30

Who gets tax audited?

6:09

What do the auditors do?

11:17

Role of a tax consultant

13:02

Closing conference

15:30

Types of disputes

17:14

Objection stage

21:30

Tax Court appeal

25:59

Regulation 62

28:23

Indonesia’s new position on exchange of information

30:23

Statute of limitations


This video will be available until end of January 2015.

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July 2014

In this Dbriefs Conversations:

Don Riegger (Asia Pacific Leader – Global Employer Services) discusses tax issues related to deferred compensation for expatriates in Asia.

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The following specific topics are covered:

Time

Topic

0:33

Deferred compensation

1:12

Impact of deferred compensation on employees

6:50

Impact of deferred compensation on employers

11:39

Deductibility for the company

12:48

Deferred compensation arrangements in China

13:38

Deferred compensation arrangements in Japan


This video will be available until end of December 2014.

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June 2014

In this Dbriefs Conversations:

Rohan Solapurkar (Tax Partner – India desk) discusses the new Indian Companies Act. 

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The following specific topics are covered:

Time

Topic

0:30

Importance of the new Indian Companies Act

1:58

Changes between the new and old Companies Act: summary

2:33

Definitions: public vs private company

4:09

Corporate social responsibility

8:10

Directors and mergers

11:12

Year-end

13:06

Basic "building blocks" remain the same

14:37

Start date of the new Companies Act


This video will be available until end of November 2014.

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This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the "Deloitte network") is, by means of this communication, rendering professional advice or services. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.

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Steve Towers

Asia Pacific International Tax Leader

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Dbriefs Bytes

Dbriefs Bytes brings you a weekly summary of the significant international tax developments impacting Asia Pacific. This video is broadcast every Friday afternoon. Stay tuned! 

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Dbriefs微播每周解读影响亚太区的国际税收发展新动向。这视频将于每周二上午播出。

Events

Dbriefs Conversations

Dbriefs Conversations brings you discussions between Deloitte experts on current tax and business issues