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Geography Updates
Hong Kong SAR Budget 2024/2025 Commentary
12 March 2024
Host: Polly Wan
Presenters: Doris Chik, Roy Phan , and Polly Wan
The Financial Secretary for the Hong Kong Special Administrative Region (HKSAR), Mr. Paul Chan, delivered his eighth annual budget on Wednesday, 28 February 2024. The HKSAR Government has recently been rolling out a number of measures and tax incentives on how the city can promote sustainable growth in traditional and emerging industries; and to deploy forward-looking tax policy and incentives in attracting investment for economic recovery in the future. In the webcast, We discussed:
- Tax reduction and relief measures for the public and the business community
- Strengthening Hong Kong's position as an international financial and asset management centre
- Measures to encourage investments to foster sustainable development of Hong Kong
Global Mobility, Talent & Rewards
Reshaping the future: How ESG is redefining the design and operation of Total Rewards
5 March 2024
Host: Jod Gill
Presenters: Jod Gill, Simon Chapman, and Brian Ho
Using Environmental, Social and Governance (ESG) is now mainstream and has quickly become a key framework that investors, employees and the wider community rely on for making critical decisions. Join our leaders for a discussion on how ESG is now significantly influencing how total reward and pay arrangements for executives and employees are designed and operated. In this Dbriefs session, we will explore the impacts of each of the ‘E’, ‘S’ and ‘G’ considerations on Total Reward, including:
- Why ESG is here to stay
- Designing Total Reward offerings that align with your ESG strategies
- Rewarding the “right way”: for your people, society and the environment
- Using pay and incentives to hold executives and employees to account for ESG performance
- Preparing for external scrutiny in how your determine, manage and govern reward arrangements
Geography Updates
2024 Japan Tax Reform Proposals: Inflation, investment, and inhibition
15 February 2024
Host: David Bickle
Presenters: Brian Douglas, Ken Leong, Masaaki Miura, and Fumiko Mizoguchi
In response to global shifts triggered by the pandemic and geopolitical tensions, Japan recognizes the need for bold economic changes. The impact of inflation, the imperative to domestically produce certain goods that are strategic to future economic prosperity and promote IP, and the curtailing of tax abuses are key challenges addressed by the 2024 tax reform. Also, with Japan’s Income Inclusion Rule (part of BEPS’s Global Minimum Tax regime, i.e. Pillar 2) coming into effect in April 2024, Japan continues to modify its tax law to be in line with international standards and is considering to introduce the Qualified Domestic Minimum Top-up Tax in next year’s tax reform. During this Dbriefs session, We discussed:
- Revisions giving consumers greater purchasing power by lowering their tax burden and incentivizing companies to increase wages
- Creation of tax incentives aimed at promoting the production of strategic goods and encouraging IP to be developed in Japan
- Status of Japan’s implementation of Pillar 1 & 2
- A fundamental change in how JCT is collected for non-residents selling via online platform operators
- Changes to the local Enterprise tax regime and impact on effective tax rate
Financial Services Industry
Transfer Pricing Nuances for Private Equity Groups
1 February 2024
Host: Shefali Shah
Presenters: Shefali Shah, Philip Moralee, and Michael Manser
With recent shifts in capital markets and a shrinking public company market, private equity has evolved quickly to become a mainstream investment option in Asia Pacific, leading to strong growth in the industry over the last decade. Against this backdrop, private equity firms and portfolio companies must navigate an increasingly complex, and rapidly changing, transfer pricing landscape across Asia Pacific. During this webcast session, we discussed -
- Typical fund transfer pricing structures.
- Transfer pricing methodologies and policies, including comparables and mark-ups
- Treatment of carried interest
- Current focus of tax authorities and advance pricing arrangements (“APAs”)
- Interest limitation / thin capitalisation rules
Transfer Pricing Special Edition
Interview with Manuel de los Santos, Head of OECD Transfer Pricing Unit
23 January 2024
Host: Anis Chakravarty
Presenters: Ralf Heussner
Anis Chakravarty spoke with Ralf Heussner on his recent interview with Manuel de los Santos, Head of the OECD Transfer Pricing Unit, to discuss latest and upcoming OECD transfer pricing projects including:
- Pillar One Amount A and Amount B.
- Transfer pricing aspects of the Pillar Two global minimum tax rules.
- Upcoming projects, including cross-border remote working and permanent establishments, including attribution of profits and intra-group service.
- Dispute prevention and resolution mechanisms.
Corporate Income Tax
Interpretation of Most Favoured Nations clause - Impact on Non-residents and Action points
16 January 2024
Host: Rakhi Modi
Presenters: Jimit Devani, and Sunil D. Shah
On October 19, 2023, the Apex Court of India issued a ground-breaking verdict that holds significant implications for the interpretation and application of the Most Favored Nation (MFN) clause in the context of Indian tax treaties. An initial analysis of the judgment suggests that (a) foreign taxpayers who, due to the MFN clause, paid lower or no taxes in India, and (b) resident taxpayers who, under the MFN clause, withheld lower or no taxes when making payments to foreign taxpayers, will face increased scrutiny. In this session, we looked into the following key points:
- Understanding the foundation of the Apex Court's Ruling.
- Unpacking the reversal of Lower Court's Stance.
- Assessing Implications and Practical Challenges for foreign taxpayers.
- Exploring the path forward for foreign taxpayers.
Financial Services Industry
Investment Management update: Tax developments in Asia Pacific
14 November 2023
Host: Siew-Kee Chen
Presenters: Mike Barbosa, Cindy Perryman, Roy Phan, and Natalie Yu
Over the past decade, Asia Pacific has witnessed a rapidly growing investment management industry. The double-digit growth in assets under management has been underpinned by global fund managers. Asia Pacific has observed an increasing demand for alternative and multi-asset strategies, investment diversification from insurers, pension and retirement plans, and a maturing appetite from family offices and institutional investors.
However, investment managers are now facing new threats and uncommon opportunities in the post-pandemic business environment. The conditions most likely to play in the immediate horizon include a combination of high interest rates, greater regulatory pressure, and potentially moderating, but still troubling, inflation. Against this background, investment managers will need to navigate a complex, and rapidly changing, tax landscape in Asia Pacific. During the webcast, our experts covered the following aspects:
- State of the market, and trends, in Asia Pacific.
- Fund structuring for investments in Asia Pacific, including the Singapore Variable Capital Company, the Hong Kong Limited Partnership Fund, and the Australian Corporate Collective Investment Vehicle.
- Tax developments impacting investment management in Singapore, Australia, China and Hong Kong.
- Current focus of tax authorities.
Indirect Tax
Ready for the EU Carbon Border Adjustment Mechanism
24 October 2023
Host: Dolly Zhang
Presenters: Daan de Vlieger and Liqun Gao
Starting on October 1, 2023, the European Union’s Carbon Border Adjustment Mechanism (EU CBAM) transition period imposes reporting requirements on EU importers of the goods covered by this new measure fitting withing the EU’s Fit for 55 climate agenda. The first quarterly report is to be submitted by the end of January 2024, which will require manufacturers exporting the covered products to the EU to provide their EU customers with a set of carbon emissions related information about the products they sell.
As such, it is imperative that manufacturers have a clear understanding of the requirements and prepare themselves well for the requests their EU customers will submit. During the webcast, our CBAM experts from EU and AP covered the following aspects:
- Overview of Deloitte’s Green Initiatives and general introduction to CBAM.
- CBAM’ implications- Who in AP is impacted and how will that be?
- Operational and strategic implications.
- How can Deloitte help
Corporate Income Tax
Tax collection at source in India: The conundrum continues!
18 October 2023
Host: Pooja Dhokad
Presenters: Jimit Shah and Sameer Maniar
In 2020, the Indian Government had introduced the provisions for collection of tax at source (‘TCS’) on payments made under Liberalized Remittance Scheme and on overseas tour programme package. The Finance Act, 2023 proposed a slew of amendments to the TCS provisions which further opened a pandora’s box of nuances and practical challenges for the travel and hospitality industry. Although recently, the Reserve Bank of India and the Ministry of Finance issued certain clarifications from a regulatory and tax perspective, companies in this space are still struggling on the applicability of the provisions along with practical challenges to implement.
During the webcast, we discussed:
- Overview of the TCS provisions.
- Applicability of the TCS provisions on certain transactions.
- Nuances and practical challenges.
Transfer Pricing
Treasury Transfer Pricing – Debt Pricing and Cash Pooling
17 October 2023
Host: Trina Maitra
Presenters: Anushree Jagnani, Theppine Kyi, Philip Robert Moralee,
Priscilla Ratilal, Vrushang Seth, and Michael Yishun Sun
Traditional treasury roles are evolving in today’s world. Across regions, the importance of aligning tax and treasury pricing decisions is gaining momentum. In this space, Companies have witnessed major transitions like LIBOR replacements, increased reporting focus on financial transactions, and other market forces that are posing new challenges. Therefore, Treasuries need to revisit treasury policies regularly for capital/funding structure updates; changing investment strategies, to focus on better use of cash, e.g., increased appetite for Cash Pooling Arrangements and other considerations, such as local interest restriction rules (CIR). Additionally, transfer pricing issues revolving the treasury functions are becoming more and more complex given the close scrutiny of the tax offices across jurisdictions.
During the webcast, we discussed:
- The treasury transfer pricing complexity with respect to the intercompany loans and cash pooling arrangements from treasury transfer pricing perspective across industries specifically touching upon the financial services sectors.
- The recent trends of the tax officers with respect to the debt transactions and cash pooling.
- Whether these jurisdictions have included any specific guidance to incorporate the principles of Chapter X of the OECD guidelines? Whether the outlook or focus on assessing these transactions have changed or are anticipated to change for the Chapter X inclusion?
- How the interest limitation rules interacts with the transfer pricing analyses etc.
Geography Updates
Online gaming – Impact of recent changes in Indian regulatory & tax laws
27 September 2023
Host: Madhava Yathigiri
Presenters: Neha Aggarwal, Shilpy Chaturvedi, Nagendra Kumar and Hiren Shah
On 6 April 2023, The Ministry for Electronics and Information Technology (MEITY) notified amendments to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediary Rules, 2021”), to create additional obligations for online gaming intermediaries who enable access to real money games. Certain amendments relating to requirement of having physical contact address and appointment of compliance officers by online gaming intermediary could have tax implications. Having a physical contact address in India and appointment of compliance officers who are resident in India by a non-resident online gaming intermediary may result in Exposure under the Act and PE exposure for non-resident in India, Withholding tax obligations and Impact on equalization levy.
Further, the online gaming industry has been grappling with an unresolved issue of GST, which can impact the industry’s viability and sustainability. The GST council, in its meeting held on July 11, 2023, has recommended uniform rate of 28% on the full value of bets placed (irrespective of whether the activities are a game of skill or chance). The GST Council has recommended legislative changes in its meeting on August 2, 2023. GST Council has decided to bring into effect the proposed changes from 1 October 2023 (formal notification awaited). During the webcast, we discussed:
- Amendment to Intermediary Rules which would be relevant for the online gaming intermediaries and impact of data privacy
- Recent announcements by the GST council and impact on the online gaming industry
- Corporate tax considerations due to the amendment to the Intermediary Rules
- Certain nuances pertaining to withholding tax on winning from online gaming
Global Mobility, Talent & Rewards
Reshaping the future: How generative AI will transform Global Mobility
21 September 2023
Host: Jod Gill
Presenters: Jod Gill and Duleesha Koolasuriya
Generative AI is set to have a profound impact on the world and will transform the Global Mobility landscape. Much of this impact will be positive but many organisations are carefully considering the ethical dimensions of embracing AI. In this session, senior Deloitte technology and Global Mobility leaders will discuss:
- The fundamentals of Generative AI
- How Generative AI is likely to impact Global Mobility
- The ethical dimensions and risks that need to be navigated
- The practical steps that can be taken to start preparing for this significant change
Corporate Income Tax
Australia Tax Updates
10 August 2023
Host: Manu Sriskantharajah
Presenters: Amelia Teng
Australia continues to lead in the Asia Pacific region in implementing the OECD’s international tax reforms and adopting new tax transparency measures. The Australian Taxation Office also has a renewed focus on the taxation of intangibles. In this session the presenters will:
Corporate Income Tax
The path to thrive: M&A strategies for a brave new world
3 August 2023
Host: Jiak See Ng
Presenters: Iain Macmillan, Sriram Prakash, and Mark Purowitz
In the last two years, nearly $8 trillion worth of deals were announced as M&A became a fundamental part of the corporate response to post-pandemic recovery. However, today we are in a vastly different macro-economic environment, not only facing adverse conditions not seen in many decades, but also disruption from the advent of AI-enabled models. In response, we have analyzed 40 years’ worth of M&A data across many cycles and released our findings in a new flagship report - The Path to thrive: M&A Strategies for a brave new world.
We are delighted to invite you for this Dbrief session where we will explore how organizations can use M&A strategically both to weather the crises and to capture new opportunities for growth and value creation in this fast-evolving marketplace. We will specifically discuss:
- The current M&A market themes and how to navigate headwinds and tailwinds
- Demonstrate a fresh set of M&A strategies that can be used both in defense to preserve value and in offense to capture new and unique growth opportunities.
- Ten practical considerations and a strategic framework to help you rethink your M&A strategies.
Corporate Income Tax
Doing business in India from a tax and regulatory perspective
27 June 2023
Host: Rohinton Sidhwa
Presenters: Neha Aggarwal and Hema Lohiya
India is well on its way to become the third largest economy in the world by 2030, and features high on the agenda of almost every global corporation due to the size of its domestic market. Yet it remains a complex jurisdiction, demanding of management bandwidth, where situations can be nuanced and responding to constant change requires agility in decision making. During this session, we will focus on:
- Successful examples of funding, supply chain, cash repatriation and controversy management in India that will help businesses navigate operating in India more effectively.
- The opportunity posed by and the format of, production linked incentives (PLI) that have quickly replaced most tax incentives in India.
Indirect Tax
Export Controls: regional updates and how to deal with transfers of intangibles
13 April 2023
Host: Suzanne Kao
Presenters: Chian Voen Wong, Dolly Zhang
Export controls and sanctions are taking a more prominent place on the global scene. The geo-political tensions tend to employ the use of export controls and sanctions even more across the globe. During this session, we will review the different updates and trends in the key export regimes and how they affect Asia Pacific the introduction of human rights as a reason for export controls, and addressing emerging technologies and how to identify, track and trace strategic intangibles transfers.
The session will close with exploring the actions companies may take to face the raising complexity of the matter. During the webcast, we will discuss:
- China export control development and trends
- SEA export control developments and impact of global export control trends on SEA businesses.
- AUS Export controls extraterritorial impact on Australasia businesses and tips on multinational export controls compliance program development.
Corporate Income Tax
Global Minimum Tax (Pillar Two) with Oracle’s TRCS – the how and what!
28 March 2023
Host: Piyus Vallabh
Presenters: Liew Li Mei, Sarvesararao Madhav, and Kenneth Kramer
Pillar Two, the key components of which are commonly referred to as the "global minimum tax" introduces a minimum effective tax rate of at least 15%. This is calculated based on a specific rule set with various computations involving financial and tax data further modified by certain elections.
This changes the way MNEs pay tax globally and creates a significant data and reporting challenge for MNEs. In this webcast we will share with you a recap of the concepts and rules and how they may impact your existing tax reporting processes. We will also demo Oracle TRCS, as an example, on what you may expect when it comes to compliance and technology. In this webcast, we will discuss:
- What are the latest updates on Pillar Two?
- What are the data and reporting challenges anticipated?
- As one of the technology solution provider, how Oracle TRCS can help in preparing for and complying with Pillar Two requirements.
- What next?
Global Mobility, Talent & Rewards
Deloitte’s global remote work survey
21 March 2023
Host: Sarah Vun
Presenters: Aleysha Azzopardi and Paul Rubinstein
Deloitte surveyed more than 820 tax, HR, finance, mobility, and payroll professionals across the globe who were asked how they have handled and responded to remote and hybrid work practices and policies. We also reached out to HR, tax and mobility leader’s to glean their insights about the global remote work journey. Come and hear the results of the global Deloitte survey, where we will share the following:
- Survey results.
- Key areas of focus to accelerate the operationalization of an organization’s remote work program.
- What’s next on the horizon.
Geography Updates
Hong Kong SAR Budget 2023/2024 Commentary
16 March 2023
Host: Polly Wan
Presenters: Roy Phan, Jackie Wong
The Financial Secretary for the Hong Kong Special Administrative Region (HKSAR), Mr. Paul Chan, delivered his seventh annual budget on Wednesday, 22 February 2023. As an international financial center, the HKSAR Government has recently been rolling out a number of initiatives and tax incentives on how the city can address emerging challenges facing the post-pandemic and global challenges to promote economic diversification for sustainable development in the future. We'll discuss:
- A summary of the Budget highlights and the new Budget measures.
- Measures to attract strategic enterprises and investments to foster sustainable development of Hong Kong enterprises.
- Upholding Hong Kong's position as an international financial and asset management center.
- Tax incentives for specific sectors and Pillar Two implementation timeline.
Geography Updates
2023 Japan Tax Reform Proposals: International tax policy and geopolitics
14 February 2023
Host: David Bickle
Presenters: Fumiko Mizoguchi, Brian Douglas, Brian Mayer, Masaaki Miura, and Nicole Baxter
Lackluster economic growth, ensuring fairness within the tax system, and increasing geopolitical tensions are all contributing factors that shape Japan’s 2023 tax reform proposals. These proposals reflect the Japanese government’s desire to increase domestic investment in markets, industries, and talent, and its commitment to promoting internationally agreed tax standards, such as the OECD/G20 Inclusive Framework’s global minimum tax. They also reflect the Prime Minister’s stated intention to increase Japan’s defense budget to around 2% of GDP. Accordingly, while not scheduled for 2023, the proposals suggest that a portion of the increased budget will be funded through future tax increases. Finally, the proposals include measures to further ease compliance with the Electronic Record Retention Law and the Japanese Consumption Tax (JCT) Qualified Invoicing System, which will come into effect on 1 October 2023. We’ll discuss:
- Revisions to Japan’s tax credit and incentive regimes.
- Status of Japan’s implementation of the global minimum tax under Pillar 2.
- Potential increase to the corporate and individual tax rates.
- Important actions to take by the end of FY23 Q1 in pursuit of readiness for the arrival of JCT qualified invoicing.
Transfer Pricing
Developing an operational transfer pricing framework - practical application
9 February 2023
Host: Mark Carlton
Presenters: Daniel Alexander Laoh and Manmeet Vij
The transfer pricing function has had to deal with a significant increase in external reporting requirements, amongst more complex demands from the business and its need for transfer pricing input. To do this effectively, a transfer pricing function will need to adopt key principles of operational transfer pricing (People, Process, Data and Technology) across more than just the application of the transfer pricing policies, as it looks for opportunities to streamline and automate work undertaken, allowing it to contribute to proactive and strategic decision making of the business. Increased data-driven controversy mitigation strategies and global reporting requirements, as well as competent authorities’ continued focus on transfer pricing governance and their own investments in tax technologies, has made digitalising operational transfer pricing processes as a strategic priority for taxpayers. During our webcast, we will:
- Break down the core framework we apply when operationalising tasks in the transfer pricing function.
- Provide case studies to illustrate how this works in practice.
Geography Updates
Union Budget 2023: India’s spectrum of opportunities
2 February 2023
Host: Karishma Phatarphekar
Presenters: Sanjay Kumar, Sumit Singhania, and Gulzar Didwania
India Budget 2023 will be presented in the Parliament on 1 February 2023, at a critical juncture in the global economy—when geopolitical uncertainty, rising inflation, and sluggish growth are seen to coexist.
Calculated actions to strengthen domestic sources of growth are required to maintain the country's current trajectory of steady economic growth. The Finance Minister, Nirmala Sitharaman, is expected to work out strategies to push India as a production or sourcing hub, amid recession fears in the west. Accordingly, the Budget is likely to continue to focus on capital expenditure as a growth driver and give an impetus to manufacturing while continuing with the post-pandemic fiscal consolidation.
Subject matter experts will share a short, simple, and strategic take on the India Budget 2023, covering:
- The Government's tax initiatives on reviving the industries and boosting optimism.
- Key policy announcements towards making India self-reliant.
- Analysis and impact of new tax proposals on your sectors, and the way forward.
Geography Updates
Investigations and Audits under GST: Strategizing and Preparing the businesses
17 January 2023
Host: Vikram Kulkarni
Presenter: Vikram Kulkarni
The introduction of GST in 2017 brought upon a turbulent period for businesses in India. New legislation replaced most of the prevalent Indirect Tax legislations and introduced a uniform tax regime across the country. While the intent was noble, and provided clarifications, amendments and modifications in the existing legislation, it also led to different interpretations tax authorities. This resulted in variance in tax positions and practices across the country. As the Law and its interpretation have become stabilized in due course, various Intelligence Agencies in the department of revenue swung into action and armed with specific information owing to the advanced technology tools causing businesses to be flooded with Audits, enquiries and investigations. In this webcast, we will discuss:
- Preparing for Audits/Investigations.
- Strategizing the way forward during Audits/Investigations.
- Common issues raised by Revenue authorities.
Geography Updates
Virtual Digital Assets - GST issues
12 January 2023
Host: Hardik Gandhi
Presenter: Shilpy Chaturvedi
Tax authorities in India are struggling to come to grips with this dynamic nature of Virtual Digital Assets (VDA). This makes it difficult for the law makers to understand how VDAs could be included in the traditional definitions and concepts of taxes particularly for GST to be applied. The Indian Government has taken steps to bring clarity to the taxation of VDA’s (such as cryptocurrencies and NFTs) from a direct tax perspective by recognizing them as new asset class and including them in the tax framework. However, clarity is still awaited on the GST front. Through this forum, we will discuss the nuisances around the GST aspects on VDA industry in India.
- Types of VDAs.
- Classification of VDAs under the traditional definition of goods and services.
- Tax implication in cross-border transactions.
