Dbriefs Asia Pacific Tax Webcasts
Anticipating tomorrow's complex issues and new strategies is a challenge. Sparking innovative ideas with Dbriefs that give you valuable insights on important developments affecting your business in Asia Pacific
Minimizing Taiwan income tax exposure on outbound service fees
27 February, 2:00 – 3:00 PM HKT (GMT +8)
Host: Arthur Chen
Presenters: Andy Hsu and Sara Liu
Taiwan's income sourcing rules have always been a controversial issue in cross-border transactions, particularly with transactions relating to the provision of services. It is a common issue when multinational companies allocate expenses or charge fees to their Taiwan subsidiaries or unrelated Taiwan clients. Despite the issuance of the Assessment Rules in 2009, in practice the Taiwan tax authorities do not readily agree to a foreign entity's position that the relevant income is non-Taiwan sourced and thus should be exempt from the 20% withholding tax. However, we have experienced a number of client cases in which the tax authorities have agreed to either an exemption from the withholding tax or an apportionment treatment to reduce the effective tax rate in Taiwan. We will discuss the following opportunities:
- Income deemed as non-Taiwan sourced.
- Taiwan sourced income with contribution rate or deemed profit rate applied under article 8 of the Taiwan Income Tax Act (TITA).
- Taiwan sourced income and deemed profit method applied under article 25 of TITA.
Learn about the latest mindset of Taiwan tax authorities in connection with the recognition of Taiwan sourced income and planning opportunities that may be available before or after transactions taking place to mitigate the Taiwan income tax exposure.
BEPS and indirect tax: Devil or angel in the details?
13 March, 2:00 – 3:00 PM HKT (GMT +8)
Host: Neeru Ahuja
Presenters: Bela Sheth, Jun Takahara, and Robert Tsang
Countries around Asia Pacific are starting to take steps to introduce new rules around BEPS Actions and Indirect Tax. New B2C VAT / GST and Customs rules for services and goods are bedding down in many jurisdictions. How are establishment rules evolving and does a VAT registration give rise to a corporate tax permanent establishment? Do the same principles apply to Indirect Tax concepts of "connection" with a country, "fixed establishment", "business establishment", and most "closely associated" rules? Are there Indirect Tax aspects to consider, with respect to transfer pricing requirements? We'll discuss:
- Case studies from countries within Asia Pacific including Australia, New Zealand, Japan, Korea, and Taiwan.
- Impacts on permanent establishment that have significant VAT and customs duty implications.
- VAT / customs duty aspects on transfer pricing requirements.
Learn about the heights and dive into the depths on these new rules. Devil or angel, understand impacts on your business and supply chain.
Global Mobility, Talent & Rewards
Digital tax and employees: The future is now
15 March, 1:00 – 2:00 PM HKT (GMT +8)
Host: Stephen Coakley
Presenters: Elizma Bolt and Donna Rubbo
We are in the midst of significant technological and digital disruption and very much entering an era of unprecedented change in the way services are delivered and received. Professional services and the tax and mobility professions are not immune from this change and in fact, many see this space, along with Government as an early and very opportunistic environment for innovators. In fact, much of this change and innovation is already well underway. The presentation will be focused on the following trends within global mobility and taxation. We'll discuss:
- Employee experience.
- Digital innovation.
- Data and transparency.
In this session, we will explain each trend with our experiences and live examples, discuss barriers to success, and explore the practical and aspirational approaches to digital transformation.
Common pitfalls of transfer pricing for in-house tax teams
20 March, 2:00 – 3:00 PM HKT (GMT +8)
Host: Theresa Goh
Presenters: Alisa Arechawapongsawat, Bhupendra Kothari, and David Letos
Transfer pricing has moved from being a specialist area for dedicated practitioners, to a broad scope international tax issue that impacts all tax professionals. In-house tax and finance teams have noted the challenge of keeping abreast of all the technical and practical aspects when transfer pricing is not their specialist area. An understanding of some common pitfalls that our experts see and advice on how to avoid or successfully manage through can be a useful transfer pricing "intensive" for those requiring a general level of knowledge in their role. We'll discuss:
- Common pitfalls in advising the business on the pricing of new inter-company transactions.
- Simple mistakes to avoid in the ongoing management of transfer pricing documentation.
- Challenges with benchmarking studies and economic analyses.
Join us to raise your awareness of some commonly occurring issues and learn how to mitigate them.
New perspective to Permanent Establishment: Unsettling the past
22 March, 2:00 – 3:00 PM HKT (GMT +8)
Host: Hemal Zobalia
Presenters: Jimit Devani and Hemal Zobalia
The concept of Permanent Establishment (PE) holds a vital place in determining taxability of a non-resident in a source state. Recently, the Supreme Court of India in the case of Formula One World Championship Limited (FOWC) and E-funds IT Solution Inc. (E-funds) has pronounced certain key principles with respect to PE and its determination. We'll discuss:
- FOWC case.
- Fixed place PE: Formula 1 race track
- Application of "time" condition to a repeated, short-term activity
- E-funds case.
- Fixed place PE: provision of support services by Indian affiliate
- Indian subsidiary should not cause a PE merely because of interaction or cross transaction with the foreign parent company
- Profit attributable to PE
- Practical implications of the two cases.
Find out about the latest Indian Supreme Court thinking on the issue of PE status.