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Webcasts archived in the last 6 months can be accessed on this page

Webcasts archived in the last 6 months can be accessed on this page. For a complete program schedule and topic information on upcoming webcasts, select the Program Guide.

您可以在本网页登入过去6个月内举办的网络讲座。如欲获取快将举行的网络讲座的详细时间表及讲题信息,请点选网络讲座指南。  

過去6カ月間に配信されたWebcastのアーカイブはこのページに掲載されています。今後配信予定のWebcastについては、プログラムガイドをご覧ください。

M&A Tax
Tax efficient funding arrangements for M&A transactions in Australia, China, and India

26 June 2018
Host: William Lee
Presenters: Enzo Coia and Amrish Shah

Deal flow continues to be strong in Asia Pacific amid the rapid development of BEPS in Australia, China, and India. Tax authorities have been escalating their scrutiny in regard to interest deductions arising from cross border related party M&A funding arrangements. Due consideration should be given to the choice of funding instruments by evaluating commercial requirements and impact on profit repatriation and exit. We'll discuss:

  • Recent legislative developments for typical funding instruments (e.g., equity and debt classification, cross currency swaps) used for investments in these countries and cases (including the landmark decision in Chevron in Australia) that could impact investors' funding arrangements.
  • Impact of the recent amendments in tax treaties vis-à-vis the funding instruments.
  • Restriction on tax deduction for interest paid to overseas related parties.

Hear about key cases in this area and learn ways your organization can structure its Asia Pacific M&A financing tax efficiently.

Indirect Tax
Indirect tax in the digital economy: Evolving rules in Australia, Japan, and New Zealand

19 June 2018
Host: Robert Tsang
Presenters: Allan Bullot, Chikara Okada, and Jonathan Paul

The Japanese Consumption Tax, Australian GST, and New Zealand GST all have at least one thing in common – maturing and developing approaches in taxing goods and services provided via or over the internet. With all three countries focused on creating an equitable indirect tax framework between domestic and overseas businesses, rules have evolved over the last year. Will other countries in Asia Pacific follow these rules? We'll discuss:

  • Current overview and framework.
  • What are the changes to the current rules?
  • Likely opportunities and/or implications for countries in Asia Pacific.
  • The way forward.

Stay updated on the evolution or revolution that these changes will bring about in the upcoming year, and how it may impact other countries in Asia Pacific.

Indirect Tax
Managing indirect tax and customs through your supply chain

12 June 2018
Host: Meng Yew Wong
Presenters: Senthuran Elalingam, Himanshu Tewari, David Ware, and Dolly Zhang

The introduction and expansion of new indirect taxes across the region coupled with the proliferation of trade agreements has resulted in considerable change across the trade environment over the past few years. The Asia Pacific region is complex and diverse and this is reflected in the manner in which different jurisdictions in the region approach the taxation of trade. It is critical to understand how changes to your supply chain can impact your indirect tax and duty position. We'll discuss:

  • Transformation of the trading environment.
  • Practical case studies.
  • Impacts to the developments in Asia Pacific.
  • The way forward.

Join us as we explore how changes in your supply chain can have major trade and indirect tax implications.

International Tax
Double tax treaties: Update on the significant recent developments in Asia Pacific

5 June 2018
*Due to a significant amount of content, the webcast has been extended to 75 minutes.*
Host: Jun Takahara
Presenters: Gokul Chaudhri and Claudio Cimetta

In this session, we will review the major developments relating to Asia Pacific double tax treaties, including the 2017 edition of the OECD Model Treaty and Commentary, developments concerning the Multilateral Instrument in Asia Pacific, and the important court and tribunal decisions of 2017 on treaty interpretation. We will also provide an overview of the significant changes within the Asia Pacific treaty network. We'll discuss:

  • 2017 OECD Model Treaty and Commentary.
    • OECD BEPS Project treaty-related measures
    • Non-BEPS changes, including important changes to the Commentary on the "permanent establishment" definition
    • Multilateral Instrument in Asia Pacific
  • Important cases on treaty interpretation.
    • Formula One (India): permanent establishment
    • RCF IV (Australia): treaty relief for capital gain
    • Starr International (United States): principal purpose test
  • Future developments and impacts in Asia Pacific.

Gain insights on the significant recent developments concerning Asia Pacific double tax treaties.

International Tax 
Digital taxation: Expansion of source country tax jurisdiction for corporate income tax purposes

24 May 2018
*Due to a significant amount of content, the webcast has been extended to 75 minutes.*
Host: Leonard Khaw
Presenters: Isabelle Mac Innes, Rohinton Sidhwa, and Cam Smith 

In 2017, the Inclusive Framework on BEPS renewed the mandate of the Task Force on the Digital Economy (TFDE) to continue work on the tax challenges of the digitalized economy. The TFDE is expected to deliver its interim report thereon in April 2018. The EU group that is studying the same issue is due to release its findings and recommendations shortly beforehand. At the same time, an increasing number of countries have begun taking steps towards the implementation of unilateral and uncoordinated domestic measures aimed at taxing digitalized activities and highly digitalized business models. We'll discuss:

  • Comment on the reports released by the TFDE and the EU.
  • Review the current status of domestic measures that selected major countries have taken, which are aimed at taxing digitalized activities and highly digitalized business models.
  • Consider short and longer term tax implications for taxpayers.
  • Comment on how taxpayers may prepare themselves for the coming change.

Stay updated concerning measures governments are taking in response to the tax challenges posed by the digitalization of the global economy.

 

Special Edition - Indirect Tax 
Abolition of GST in Malaysia

23 May 2018
Host: Richard Mackender
Presenters: Senthuran Elalingam and Eng Yew Tan 

10 May 2018 represented a truly significant landmark in the history of Malaysia, as the general elections resulted in a change in the Federal Government for the first time. Pakatan Harapan, the coalition forming the new Government, had run the election on a comprehensive reform agenda which included, as a cornerstone policy, the abolition of the unpopular goods and services tax (GST), to be replaced with a Sales and Services tax (SST) regime. On 16 May 2018, the Ministry of Finance had issued a statement that the GST will be reduced from the current 6% to 0% starting 1 June 2018. This is the first step done to ensure smooth transition to the proposed SST. We'll discuss:

  • Highlights of events that has happened so far.
  • Overview of the past SST which has been in placed before the transition to GST in 2015.
  • Implication to supplies spanning the change in rate.
  • Key challenges.
  • What you should do now.

Join us to understand how the change in the GST rate and the introduction of SST will impact businesses in Malaysia.

 

Country Focus
New Australian transfer pricing guidance: Rules or restrictions?

17 May 2018
Host:  John Bland
Presenters: Stephanie Lucas, Liam O'Brien, and Mark Wilkie

The Australian Taxation Office (ATO) has been busy drafting and publishing guidance for taxpayers on a variety of transfer pricing related topics. While the guidance comes in different forms, there is a general expectation that multinationals are familiar with, and acting upon, all ATO views. Some of the guidance might be considered novel in its logic and in its expectations of taxpayers, encouraging multinationals to manage their tax risks to a standard higher than that required by legislation. We'll discuss:

  • Marketing and procurement hubs.
  • Diverted profit tax.
  • Inter-company debt.

Keep up to date with the latest developments in Australia that have wide applicability for multinationals.

Global Mobility, Talent & Rewards
Global human capital trends 2018: New rules for the rise of the social enterprise

15 May 2018
Host: Joseph Logudic
Presenters: Nishith Mohanty and Andrew Warneck

Seismic shifts are reshaping the new world of work. What are the top 10 trends that HR and business leaders should know about as they navigate the new landscape in 2018? We'll discuss:

  • Is your organization transitioning to the future of work?
  • How should you be leveraging digital and technologies like AI to augment human skills?
  • How can HR take the lead to help drive stronger C-suite collaboration?
  • What are the implications of these trends as they relate to the individual, organizations, technology, and society?

Participants will review results of the 6th annual Deloitte global human capital trends research and how organizations can address human capital issues of the future.

Indirect Tax
GST and VAT in India, Malaysia, and the Middle East: Growth spurts or growing pains?

10 May 2018
Host: Sarah Chin
Presenters: Rajeev Dimri, Bruce Hamilton, and Eng Yew Tan

Malaysia's GST hits its 3rd birthday, India's GST is a year old whilst VAT is born in the Middle East in Saudi Arabia and the United Arab Emirates, with Oman and Bahrain slated to become the latest members of the indirect tax club. What are the contrasts in experience across these countries and regions? How have these frameworks evolved differently from the framework laid out in the OECD VAT/GST Guidelines, or the models adopted in Europe and elsewhere across Asia Pacific? We'll discuss:

  • Overview and highlights since the introduction.
  • Differences in the framework and models across region.
  • Identify risks and challenges.
  • Potential opportunities and/or implications in the future.

Join us to explore whether the experiences represent growth gains for the economies and authorities, or some form of pain for taxpayers.

Global Mobility, Talent & Rewards
Global mobility policy trends in Asia Pacific: An evolution of a new era

8 May 2018
Host: Kathryn Osborn
Presenters: Sudhakar Sethuraman and Kevin Zhu

The world of mobility is constantly evolving and Asia has a unique blend of cultures, laws, and practices. A "one size fits all" global mobility policy may not be fit for purpose in the region nor work for every country. The global workforce is transitioning from employees and assignees to business travellers, virtual workers, domestic commuters, and international local hires. Organizations need to be agile to deal with the various mobility challenges that come their way. New generations mean new expectations and the mobility employee experience needs to be positive, innovative, and engaging. We'll discuss:

  • Agile policies for intra-regional Asia moves.
  • Domestic mobility in China.
  • Domestic mobility in India.
  • Flexibility in the mobility policy.
  • Mobility for millennials.

Join us to explore and navigate the changing nature of mobility policies across Asia Pacific and learn how you can create or adapt your approach to be successful for the future.

Transfer Pricing
Transfer pricing and intangibles: Emerging challenges

3 May 2018
Host: Cam Smith
Presenters: Sanjay Kumar, Kerry Lambrou, and James Zhao

Transfer pricing for intangibles remains a hot and evolving topic amidst the complexities of multinationals' international trade. The OECD provided new guidance following Action 8 of its BEPS initiative, and taxpayers and revenue authorities have now had time to consider the implications of new thinking against previous transfer pricing practices and future business priorities. In this session, we will explore how the OECD guidance is being applied in practice, with some attendant challenges for multinationals. We'll discuss:

  • Practical application of the new, broad definition of intangibles and guidance on hard-to-value intangibles.
  • Entitlement to intangibles-related returns – aligning transfer pricing outcomes with value creation.
  • Determining arm's length royalties and pricing intangible transfers.
  • Common areas of intangible-related review and challenge by revenue authorities, and potential impacts on multinationals' global IP strategies under the new landscape.

Join us to keep abreast of developments in this important area of transfer pricing.

India Spotlight
Long term capital gains: Impacts on future landscape

12 April 2018
Host: Amrish Shah
Presenters: Deepa Dalal and Sudhakar Sethuraman

Budget 2018 proposes to radically change the tax treatment of long term capital gains (LTCG) arising from the sale of listed shares and equity-oriented mutual funds. The LTCG from these transactions are currently exempt from income tax subject to payment of securities transaction tax. They are now proposed to be subject to income tax from 1 April 2018. The budget proposals, however, provide a minimum threshold exemption of INR 100,000. Further, appreciation in the value of equity shares until 31 January 2018 is also proposed to be grandfathered. We'll discuss:

  • Overview of the proposed amendment.
  • Grandfathering provision – benefit of cost step up based on fair valuation.
  • Computation mechanics.

Stay updated on what the proposals mean for you and how to make an informed decision regarding investments in India.

China Spotlight
China's new rule on beneficial owners: Key changes and implications

28 March 2018
Host: Vicky Wang
Presenters: Sophie Liu, Apple Tang, and Tony Zhang

On 3 February 2018, China's State Administration of Taxation (SAT) published updating rules (Bulletin 9) regarding the concept of a beneficial owner (BO) under China's tax treaties. Bulletin 9 superseded a number of prior regulations on beneficial owner and becomes the most comprehensive and updated regulation on this important treaty concept. Bulletin 9 will apply to tax payments or withholding obligations that arise on or after 1 April 2018. We'll discuss:

  • What changes does Bulletin 9 make to the seven negative factors listed in Circular 601 that were used to determine a non-resident's BO status?
  • What changes does Bulletin 9 make to the safe harbour rules listed under Bulletin 30 for an automatic BO status recognition?
  • What are the latest documentation requirements to claim treaty benefits?
  • What are some of the additional constraints for enjoying a treaty benefit even if a non-resident satisfies the BO requirement?
  • What do these changes mean to you under your existing structures and what to plan for the future?

Learn about the changes and implications that this new rule has brought that may affect your treaty eligibility, which ultimately may affect your group effective tax rate.

India Spotlight
New perspective to Permanent Establishment: Unsettling the past

22 March 2018
Host: Hemal Zobalia
Presenters: Lakshit Desai and Jimit Devani

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
  • Other recent key Indian jurisprudences that have pronounced interesting dimensions to the concept of PE.
    • Space provided in India for rendering services may constitute a PE
    • Profits from offshore services is attributable in case where Supervisory PE is constituted
    • Constitution of Service PE – physical presence of employees in India not required
  • India annual budgetary exercise amends the definition of "business connection" (a concept under Indian domestic income-tax laws akin to PE).
  • Practical implications of the above cases.

Find out about the latest Indian Supreme Court thinking on the issue of PE status.

Transfer Pricing
Common pitfalls of transfer pricing for in-house tax teams

20 March 2018
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.

Global Mobility, Talent & Rewards
Digital tax and employees: The future is now

15 March 2018
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:

  • Automation.
  • 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.

Indirect Tax
BEPS and indirect tax: Devil or angel in the details?

13 March 2018
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.

Country Focus
Minimizing Taiwan income tax exposure on outbound service fees

27 February 2018
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.

Transfer Pricing
Operational transfer pricing: Exploring the opportunity for business

22 February 2018
Host: Fiona Craig
Presenters: Vincent Geluwie, Stuart Osborne, and Priscilla Ratilal

Operational Transfer Pricing (OTP) is a critical issue for many companies with material levels of cross border trade. Very few companies currently do this well, and Excel spreadsheets still dominate the process. The potential reach of OTP into business processes and systems is becoming a significant improvement opportunity for many companies. There is a lot of scope for either end-to-end process improvement or automated solutions, such as spanning processes and controls, data and management, and people and technology. We'll discuss:

  • Assessing process risks to establish a robust controls framework for operational transfer pricing.
  • Use of the right people with the required skills and knowledge to execute the process.
  • Obtaining accurate, complete, and timely financial data.
  • Putting the right tools and technology in place to enable an end-to-end process.

Join us to hear how new tools and processes can help your business overcome OTP issues.

International Tax
2018 Japan Tax Reform Proposals: Broad base, low rates

8 February 2018
Host: David Bickle
Presenters: Lars Dahlen, Brian Douglas, and Tim O'brien

With continued low unemployment, a rising stock market and signs that persistent wage and price deflation may finally be easing, Japan's economy is benefiting from the improving global economic outlook and sustained financial stimulus from the government and central bank. The 2018 Tax Reform proposals issued by the ruling parties of the Japanese government on 14 December 2017 continue to reflect these efforts to promote economic growth under the government's stimulus program, known as Abenomics, and to implement various tax measures. We'll discuss:

  • Key proposals in the 2018 tax reform, including Corporate Income Tax (CIT) rates, R&D and other incentives, implementation of BEPS measures, such as Action 7 expanding the definition of permanent establishment to include commissionaire arrangements and certain contract agent and other related party activities.
  • Transfer pricing documentation guidance from the Japanese National Tax Agency.
  • 2017 developments in Japan's Treaty network.
  • Customs and Trade issues.

Join us to learn more about these key proposals in the 2018 Japanese tax reform and other recent notable tax and legal updates that may impact multinational enterprises doing business in Japan.

International Tax
Inbound investment into Korea: A clear view of the recent developments

6 February 2018
Host: Sunny Kim
Presenters: Jimmy Lee and Shin Ho Lee 

Significant developments in Korea have caused an impact on inbound investment into the country, including the 2018 tax proposals that include implementation of certain BEPS action plans. We'll discuss:

  • Overview of the selected proposed changes to Korean tax legislation in 2018 which may have implications on foreign inbound investors in Korea.
  • Implementation of various BEPS Actions under the Korean domestic tax legislation.
  • Recent decisions from the Tax Appeals and Supreme Court case.

Discover the latest inbound investment climate in Korea, and what might affect your tax positions when investing in Korea.

Special Edition - India Spotlight
India Budget 2018: What's next on the cards?

2 February 2018
Host: Rohinton Sidhwa
Presenters: Mahesh Jaising and Hemal Zobalia 

The last fiscal year witnessed a slew of reforms on the tax and regulatory front. With the current government entering its penultimate year, the trend of reforms is set to continue. After successfully implementing the Goods and Services Tax (GST) regime in India, the government has now set its sights on overhauling the direct taxes law covering income tax. The release of the final rules on country-by-country (CbC) reporting and master file requirements in India are significantly aligned with BEPS Action 13 guidance, reflecting India's commitment to global consistency. GST, Real Estate Regulation Act (RERA), demonetization, bankruptcy code, and recapitalization of bonds of public sector banks (PSBs) are challenging old practices and transforming the way India is doing business. In these times of massive reforms, interest is further mounting to see what’s next on the cards. We'll discuss:

  • Emerging opportunities in Budget 2018.
  • Analysis and impact of new tax proposals on your business.
  • The way forward.

Gain insights from Deloitte experts with an in-depth analysis of the 2018 India Budget.

Special Edition - International Tax
US corporate tax reform: Tax impact on Asia Pacific investment into the US

30 January 2018
Host: Leonard Khaw
Presenters: David Allgaier and Ivan Strunin

US tax reform includes significant modifications to both domestic and international provisions of the US Tax Code. What should inbound companies and their parent organizations know? We'll discuss:

  • Key changes impacting the US tax burden, including rate reduction, NOL limitations, capital expensing, and state taxes.
  • Provisions applicable to cross-border payments to foreign affiliates, including royalties, cost of goods sold, and services.
  • Foreign-derived intangible income and other rules applicable to the taxation of intangible property.
  • Significant and broadly applicable base erosion measures, including interest limitations under section 163 and hybrid payment rules, and potential headquarters country implications.
  • Alignment with the BEPS Project.

Participants will learn how these provisions might impact their business and explore potential tax planning considerations.

India Spotlight
Re-thinking the inbound investment strategy in India: The dawn of a new era

25 January 2018
Host: Anis Chakravarty
Presenters: Pritin Kumar, Vishal Palwe, and Peter Willeme

India's tax treaties with Mauritius and Singapore were amended to withdraw the exemption from capital gains arising from disposal of shares of an Indian company. The capital gains exemption stands withdrawn in respect of investments made on or after 1 April 2017. The investments made till 1 April 2017 are grandfathered. Going forward, the foreign investors may have to evaluate other jurisdictions for investing in India. This is further complicated by the introduction of the general anti-avoidance rule (GAAR). We'll discuss:

  • Overview of India's revised tax treaties with Mauritius and Singapore.
  • Comparative evaluation of jurisdictions for investing into India.
  • The impact of GAAR on inbound investment structures.
  • The way forward.

Learn about the upcoming investments opportunities in India and how these changes will affect the future landscape.

International Tax
Inbound investments into Taiwan: Practical insights on recent developments

23 January 2018
*Due to a significant amount of content, the webcast has been extended to 75 minutes.*
Host: Leonard Khaw
Presenters: Ping Gwo, Andrew Hsu, and Amber Li

In 2017, Taiwan Ministry of Finance (MOF) introduced a series tax reforms that will have an impact on investment into Taiwan beginning from 2018 tax year. The recent tax reforms not only include the abolition of the dividend imputation system, but also have introduced a number of the initiatives recommended under the BEPS project, including rules on the taxation of the digital economy, transfer pricing documentation requirements, etc. We'll discuss:

  • Recent reform developments in Taiwan, including the update on the abolition of dividend imputation system and implementation of the BEPS Action points in Taiwan.
  • The impact of those reforms on Taiwan inbound investment.
  • Opportunities and challenges.

In light of the changes from the 2018 tax year, keep up to date with the latest developments on inbound investment in Taiwan and hear our insights on how they may affect your business, what to expect, and how to prepare in advance.

Special Edition - International Tax
US corporate tax reform: Tax impact on US investment into Asia Pacific

22 January 2018
Host: Rohinton Sidhwa
Presenters: David Allgaier and Ivan Strunin

The Tax Cuts and Jobs Act includes significant modifications to international provisions of the US Tax Code. What should US and other companies know? We'll discuss:

  • Section 965 rules addressing the immediate taxation of deferred earnings and the participation exemption enacted under section 245A.
  • Provisions applicable to controlled foreign corporations, including global intangible low taxed income.
  • Foreign-derived intangible income and other rules applicable to the taxation of intangible property.
  • Significant and broadly applicable base erosion measures such as the base erosion anti-abuse tax, interest limitations under section 163 and hybrid payment rules.
  • Modifications to existing law relevant to the application of the new provisions.
  • Alignment with the BEPS Project.
  • Possible responses by Asia Pacific countries.

Participants will learn about how these provisions might impact their business and resulting tax planning considerations.

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