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2022
Post-merger integration (PMI) from tax perspective | 8 December 2022
Subject matter experts: Joe Song, Scott Oleson, and William Lee
Over the years, there has been significant growth in legal, operational and structural reorganizations and integrations undertaken by corporations to achieve strategic benefits and to bring value to its shareholders. Tax has cross-functional interdependencies throughout the organization and plays an important role while undertaking such restructurings / reorganization. An effective PMI plan assists in magnifying the value created for the future of an enterprise by realizing efficiencies, synergies and carving our redundancies. In this session speakers from various geographies will discuss following key areas of PMI:
• Simplification of legal entity structure to align with the integrated business model, update tax efficient profile, and enable cost savings.
• Identifying tax synergies by participating in cross-functional integration team or PMO/IMO.
• Evaluating IP, value-chain and supply-chain planning opportunities.
• Evaluating transfer pricing requirements and documentation.
• Tax planning with respect to any planned divestitures including carve-out financials.
E-invoicing and real-time reporting developments in the Asia Pacific | 17 November 2022
Subject matter experts: Allan Bullot, Candy Tang, Justin Ward, Shrenik Shah, and Raoul D’Cruz
In recent years, we have seen a number of countries in the region either adopt or announce an intention to adopt e-invoicing or other electronic reporting requirements. The approaches adopted across the region have not been uniform. Importantly the driving reasons for Governments to adopt such requirements have varied from increasing efficiency and transparency in the invoicing process to enabling tax authorities to have greater access to taxpayer data and information. Whilst these requirements are not yet mandatory in many jurisdictions, based on the recent actions taken by the Governments in the region, it is expected that it will become mandatory within next few years. In this session we will:
• Examine above mentioned Asia Pacific trend and try to map it with the global trend.
• Provide a specific focus to the e-invoicing requirements in some of the key countries in Asia Pacific region, such as Australia, China, India and New Zealand.
• Share insights on how businesses can be well prepared and adapt themselves to this changing environment.
• Share insights on how businesses can adopt a regional e-invoicing strategy to achieve efficiency and uniformity
Germany-India: Transfer Pricing Controversy, Dispute Mitigation & Resolution | 10 November 2022
Subject matter experts:
Claudia Lauten , Manfred Naumann , Sobhan Kar, Tehmina Sharma, and Arundhati Pandeya-Koch
Over the years, bilateral trade between India and Germany has been steadily increasing. German companies have discovered new business and investment opportunities in India and so have Indian companies in Germany.
However, escalating tax and transfer pricing disputes have indeed cast a shadow on the booming economic cooperation between both countries. Such disputes have often led to lengthy and resource intensive dispute resolution proceedings and incidence of double taxation aggrieving tax payers.
Experts from Deloitte India and Germany, including Senior Advisors who were previously part of the tax administrations in both countries, are coming together to host a webcast to discuss the current transfer pricing controversy landscape in both countries and discuss options available to taxpayers.
The discussion will focus on the key areas of dispute, options to mitigate and alleviate double taxation including the success rate of bilateral APA and MAP proceedings, among others. Furthermore, participants will have the opportunity to raise questions during the live Q&A session.
India Japan APA, MAP and controversy experience | 15 September 2022
Moderator:
Tetsuya Kawase, Partner, Deloitte Japan
Subject matter experts:
Hiroki Yamakawa, Partner, Deloitte Japan
Sobhan Kar, Senior Advisor, Deloitte India
Yuki Shoji, Deloitte India
India and Japan are long-standing partners in tax and trade. Both the countries have been able to successfully navigate and resolve tax controversy and prevent disputes by way of Advance Pricing Agreements (APA) and Mutual agreement procedures (MAP). Recent international tax developments such as the signing of the multilateral instrument in 2019 and emergence of the Pillars has provided further impetus to tax cooperation between India and Japan.
Deloitte India, together with partners of Deloitte Japan, is pleased to present an exclusive bi-lingual webinar on transfer pricing for Japanese multinationals investing in and trading with India.
The insights will be shared by Sobhan Kar who has more than 2 decades of experience as an IRS officer and was former Director (APA), in the office of the Indian Competent Authority for 6 years. He has been part of multiple bilateral APA/MAP negotiations and has been instrumental in resolving many complex cases. Sobhan has recently joined Deloitte as a Senior Advisor.
In our interaction with Sobhan Kar, we will cover the following major aspects and challenges faced by taxpayers and decipher views/ approaches adopted by the tax authorities.
• Evolution of the Indian APA programme over the last decade
• Transfer pricing litigation scenario and impact of APA
• Indian Government approach in resolving PE issues under MAP
• APA experience in resolving varied issues under transfer pricing audit
• MAP resolutions – MNCs view and tax authorities’ approach
• Way-forward on APA / MAP as an effective alternate dispute resolution mechanism
Taxation of Cryptocurrency in Asia Pacific: Current and proposed tax regimes | 16 August 2022
Subject matter expert: Promod Batra
The environment for digital currencies is changing rapidly with tax authorities becoming even more focused on ensuring that these assets are appropriately taxed but can we even agree on what digital currencies are and therefore how they should be taxed? There is no clear consensus and tax authorities are at the moment focused on ensuring that individuals report on gains in their tax returns but what about the broader institutional framework.
We discussed:
• The current and proposed regimes for taxation of Cryptocurrencies in Asia Pacific.
• Key takeaways.
India transfer pricing dispute resolution: The way forward | 28 July 2022
Moderator
• Karishma Phatarphekar, Partner, Deloitte Touche Tohmatsu India LLP
Subject matter experts
• Ankit Goel, Subject matter expert
• Edward Morris, Partner, Deloitte UK
• Sobhan Kar, Senior Advisor, Deloitte Touche Tohmatsu India LLP
The Advance Pricing Agreement (APA) programme in India, introduced a decade ago, successfully caught the attention of MNC taxpayers, and has been a distinctive achievement for the Indian Revenue authorities in terms of concluded applications. The programme has also had its fair share of challenges, ranging from taxpayer expectations to issues in negotiations.
The Mutual Agreement Procedure (MAP) programme is intended to resolve double taxation that could arise from transfer pricing adjustments or other tax cases such as attribution of profits to permanent establishment. The programme, that has been a subject of peer review under the aegis of the OECD, has also witnessed several bilateral conclusions over the past about 24 months.
Let’s hear your views and challenges that you may have faced, and discuss approaches of the APA and Competent Authority.
Indeed, the above alternate dispute resolution mechanisms have been a game changer in the Indian Transfer Pricing litigation scenario. We will cover the following major aspects and challenges faced by taxpayers and decipher views/ approaches adopted by the tax authorities.
• Evolution of the APA programme over the last decade
• Impact on transfer pricing litigation scenario
• Post APA compliances (approach and challenges of the Transfer Pricing Officer)
• Impact of COVID-19 on negotiations and approach of tax authorities
• MAP resolutions – MNCs view and tax authorities’ approach
• Way-forward on APA / MAP as an effective alternate dispute resolution mechanism
Labour Codes: Update on State rules and overall status | 14 July 2022
Subject matter experts: Radhika Viswanathan, Saraswathi Kasturirangan, and Tarun Garg.
In an attempt to consolidate and simplify labour regulations in India, the four labour codes, subsuming 29 central legislations, have been approved by the President.
While the notification of the effective date is pending, the States and union Territories have issued the draft rules. In this session, we'll discuss:
• What is the status of the central labour codes?
• What kind of changes do we expect?
• What is the status of the various state rules?
• How would this be impacted by the central regulations?
Secondment arrangements – recent ruling and key impact | 7 July 2022
Subject matter experts: Aarti Raote, K Baskar, Suchint Majmudar, and Sumeet Hemkar.
In the contemporary global economy, to leverage on talent available within the group companies, employees are frequently seconded by group companies. The issue of levy of indirect tax on such cross border secondment arrangements had settled over the last few years by way of multiple favorable rulings.
Thus, in cases where seconded employees were working under the control and supervision of the Indian company and salary was being paid in India after deducting taxes as per the Indian tax laws, largely, the position that was taken that the seconded employees have employer employee relationship with Indian company and no indirect tax was applicable on such transactions.
Recently, the Supreme Court of India in the matter of Northern Operating Systems held that one factor is not sufficient to conclude that employer employee relationship exists between the secondee and the Indian company. Multiple factors such as salary payment, nature of task assigned, responsibility for task performed, eligibility to terminate employment, duration of the secondment, overall arrangement between Indian and overseas company have to be considered.
To understand the impact of the aforesaid ruling on taxability of secondment agreements, we'll discuss:
• Alignment of position under direct tax and indirect tax laws.
• Review of secondment arrangements to review tax position.
• Impact of the ruling on the service tax position taken for taxability of secondment contracts.
• If service tax is paid for the past period, whether benefit of credit/refund can be claimed now.
• Requirement to pay tax on secondment arrangements under GST regime, eligibility to claim credit/refund for the previous years.
Financial Services Series: Tax developments in India | 17 May 2022
Subject matter experts: Bahroze Kamdin, Madhav Kanhere, Rajesh Gandhi, and Russell Gaitonde
The Indian economy is recovering from the COVID-19 impact and is gradually picking up amidst these uncertain times and volatile environment, caused by various disruptions, high inflation, and geo-political tensions.
The financial services sector can help define the economy and would need to be its backbone, by playing a pivotal role for strength and stability, while operating in a changing world. With the recent developments in the tax environment, what is the impact to the financial services industry?
We'll discuss:
• Key tax developments for financial services in India.
• Tax policy priorities and current tax audit focus.
IFSCA (Fund Management) Regulations, 2022 | 28 April 2022
The Final International Financial Services Centres Authority (Fund Management) Regulations, 2022 (“FM Regulations”) were notified on 22 April 2022.
The FM Regulations are broadly similar to the draft Fund Management regulations released by the International Financial Services Centres Authority (IFSCA) earlier in February. However, the final regulations have some key changes which will impact fund managers and investment vehicles in IFSC.
Join our subject matter experts for an interactive session on this most awaited development in IFSC.
In addition to the subject matter experts, we will be joined by Dipesh Shah, Executive Director (Development), IFSCA who will share his insights.
Moderator:
• Sandeep Sonpatki, Deloitte Touche Tohmatsu India LLP
Subject matter experts:
• Dipesh Shah, Executive Director (Development), IFSCA
• Mihir Upadhyay, Deputy General Manager, IFSCA
• Rajesh H. Gandhi
• Sandip Shah, Head – IFSC Department, GIFT City
M&A and Carve-Out strategy in China and India | 31 March 2022
Several carve-out deals have recently been announced, indicating that in the current economic context, carve-outs are proving to be an interesting option for big corporations to achieve strategic benefits and to bring value to its shareholders. In the past, companies have considered carve-outs when a part of their business is too weak or troubled to keep, or when they want to monetize it.
Today, companies are increasingly seeing value in separating non-strategic business units and building a more focused portfolio. Professionals from various geographies will discuss:
• Overview of carve-out.
• Market trends and transaction life-cycle.
• Benefits and challenges of carve-out from a tax perspective.
Subject matter expert: D.V. Manohar
Indirect Tax developments on electronically supplied services (ESS) and e-invoicing in Asia Pacific | 3 March 2022
The digitization of indirect taxes continues to gain momentum across the region as more countries adopt or expand e-invoicing requirements. On a similar front, we continue to see adoption of rules imposing indirect taxes on the provision of electronic services by foreign service providers.
This session will chart the implementation and development of these rules across the Asia Pacific. We'll discuss:
• Recap on e-invoicing and ESS requirements.
• The current state of play across the region in terms of jurisdictions that have adopted, announced or proposed e-invoicing or ESS rules.
• An overview of recent expansions and implementations including China and Thailand.
• A retrospective on the implementation of e-invoicing in India.
Subject matter expert: Shrenik Shah
Reward in future of work: Operating an equity plan | 22 February 2022
Equity compensation is a constantly expanding landscape and its role is becoming more and more important for companies in pursuit of key talents and ultimately their success. In the context of Asia Pacific, the use of equity compensation is a critical part of remunerations strategy led by mature market such as Australia and Japan, and rising generation of start-up companies such as China and India.
Unsurprisingly, this is where most governments around the world continue to increase their attention on corporate governance around equity plans ensuring regulatory and tax compliance remaining high on companies' agendas.
We discussed:
• Recent tax and regulatory development in key countries and/or government/audit focus on employer's obligation on equity compensation and how to manage the challenges.
• Tax considerations in designing the equity plan to deal with the changing landscape under the future of work.
Subject matter expert: Aarti Raote
GIFT IFSC: Draft IFSCA (Fund Management) Regulations | 23 February 2022
International Financial Services Centres Authority (“IFSCA”), in its endeavour to develop a comprehensive and consistent regulatory framework for Investment
Funds based on global best practices with a special focus on ease of doing
business, has released a consultation paper to seek comments/views/suggestions from public on the IFSCA (Fund Management) Regulations, 2022.
IFSCA has requested for comments on the Draft Regulations on or before
28 February 2022.
Watch our subject matter experts interactive session on this important development where we will discuss the key features of the proposed regulations impacting funds and fund managers and discuss your concerns on the topic.
In addition to the subject matter expert from Deloitte, we were bejoined by Sandip Shah, Head – IFSC Department, GIFT City who shared hisinsights with respect to the proposed regulations.
Moderator:
• Sandeep Sonpatki, Partner, Deloitte Touche Tohmatsu India LLP
Subject matter experts:
• Sandip Shah, Head, Head – IFSC Department, GIFT City
• Rajesh H. Gandhi
Opportunities for capital markets in IFSC exchanges | 4 February 2022
GIFT City is the first International Financial Services Centre (IFSC) in India and has grown over the years. IFSC provides a platform to tap global capital flows. It also provides a globally competitive financial platform for the full range of international financial products and services at the regional and global level.
To attract global investors, tax benefits have been provided to non-residents investors investing in securities traded on the IFSC stock exchanges.
Moreover, to deepen the financial markets in IFSC and provide resident individuals with an opportunity to diversify their portfolio, the Reserve Bank of India (RBI) permits the individuals to make remittances under the Liberalised Remittance Scheme (LRS), subject to conditions.
We have the privilege to host Dipesh Shah, Executive Director (Development), International Financial Services Centres Authority—the regulator of IFSC, as the keynote speaker for the session.
It will be followed by a panel discussion that will help decipher the relevant IFSCA regulations, eligible investment opportunities in IFSC, existing tax benefits, and the impact of the Budget 2022 proposals for investors investing in IFSC.
Moderator:
Sanjoy Datta, Deloitte Touche Tohmatsu India LLP / Monish Shah, Deloitte Touche Tohmatsu India LLP
Subject Matter Speakers:
• Sandip Shah, Head – IFSC Department, GIFT City
• Sameer Patil, Director, India International Exchange (IFSC) Limited (India INX) and Chief Business Officer, BSE Limited
• Bahroze Kamdin
India Budget 2022: Foreign Portfolio Investors | 1 and 4 February 2022
India Budget 2022 will be presented in the parliament on 1 February 2022.
The economy has witnessed a steady recovery to date. However, the downside risks continue as the latest surge in COVID-19 cases since the start of the year has brought back uncertainties.
While the economy is expected to be resilient, it will require sustained efforts on reforms and effective implementation of various economic stimulation measures.
The government is anticipated to further rationalise the tax regime to reduce tax litigation and ease tax compliances.
Join our subject matter experts for an in-depth analysis of budget proposals that could impact Foreign Portfolio Investors (FPIs). The session lays a special focus on the following:
• The current economic situation and a roadmap for FY 2022-23
• Key tax and regulatory proposals, with a special focus on the impact for FPIs
We have arranged two conference calls. You may attend the one that suits you the best.
Moderator: Nitin Shingala
Subject Matter Experts:
• Rajesh H. Gandhi
• Rumki Majumdar
India Budget 2022: Enabling India's big leap | 2 February 2022
India Budget 2022 was presented in the Parliament on 1 February 2022.
The Union Budget has put the economy on an accelerated growth path after the impact caused by the pandemic. Amendments in the tax law to bring about sustainable growth, infrastructure investment, focus on R&D spending, nurturing incentives to the core sectors including manufacturing and services, tapping the huge experience of running captive centres are some of the priority items on the agenda of the Government as the preparation get underway to unveil the budget.
Ease of tax compliances, simplification and digitisation are the cornerstones to enhance the ease of doing business in India.
With an optimistic outlook towards sustained growth, all eyes are on the announcements.
The subject matter experts shared a short, simple, and strategic take on the India Budget 2022. The following topics were discussed:
• 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
Moderator: Hemal Zobalia
Subject Matter Experts:
• Bela Sheth Mao
• Jatin Kanabar
• Sanjay Kumar
India Budget 2022: Impact for US multinational enterprises | 2 February 2022
The Union Budget of India will be presented in the Parliament on 1 February 2022.
India’s economy is witnessing a steady recovery, but the recent surge in COVID-19 infections in India may have an impact on the economic recovery.
It is widely expected that the primary goal of the budget will be to ensure that the Indian economy continues its path to recovery. The Indian government is expected to offer tax incentives and reliefs to boost new-age sunrise sectors, nurture tech-led innovation and start-up eco-system, bolster the manufacturing sector, and support the pandemic-hit sectors. India’s Union Budget 2022 may, for the first time, introduce a framework for taxation of cryptocurrency. The government will have to walk the tightrope of supporting the economy and ensuring that that fiscal deficit is not completely unchecked.
Foreign investors expect the Indian government to continue its efforts
to improve the investment climate, rationalise tax regime, introduce measures for improving ease of tax compliance, and reduce tax litigation.
Subject matter experts analysed the budget proposals which could impact US multinational enterprises (MNEs).
The session layed special focus on key tax and regulatory proposals,
with a special focus on impact for US multinational enterprises (MNEs).
Moderator: Anil Talreja, Partner, Deloitte Touche Tohmatsu India LLP
Subject Matter Experts:
• Manisha Gupta
• Prashanth Bhat
• Rajesh Gandhi
Union Budget 2022: Top highlights | 1 February 2022
India Budget 2022 will be presented in the Parliament on 1 February 2022. The Union Budget is expected to put the economy on an accelerated growth path after the impact caused by the pandemic. Amendments in the tax law to bring about sustainable growth, infrastructure investment, focus on R&D spending, nurturing incentives to the core sectors including manufacturing and services, tapping the huge experience of running captive centres are some of the priority items on the agenda of the Government as the preparation get underway to unveil the budget. Ease of tax compliances, simplification and digitisation are the cornerstones to enhance the ease of doing business in India.
With an optimistic outlook towards sustained growth, all eyes are on the announcements.
Subject matter experts shared a short, simple, and strategic take on the India Budget 2022. Discussed the following topics:
• 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
Moderator: Karishma Phatarphekar
Subject Matter Experts:
• Amit Sarker
• Priya Narayanan
• Richa Gupta
Remote work: Setting the right strategy | 2 December 2021
The pandemic has accelerated the future of work, and the landscape of remote working is evolving rapidly. Businesses are increasingly being challenged by questions on where and how work will be done.
In view of this, we conducted a webinar wherein the panellists responded to questions around the following topics:
• Human capital trends relevant to remote or hybrid work
• Consideration of India and US tax, mobility, and immigration* issues to set a remote/hybrid work strategy
• Navigation of operational challenges in the changing talent and regulatory environment
* Deloitte’s US firms do not practise law or provide legal advice.
Moderator: Elizabeth Karcher, Global Employer Services, Deloitte Tax LLP, US
Speakers:
• Brent Copreland, Global Expatriate tax leader, CISCO
• David Koziol , Director, Global Mobility & Immigration, Oracle
• Kiran S N, Associate Vice President, HCL
• Rajesh Gandhi, Subject Matter Expert
• Sean Trotman, Global Employer Services, Deloitte Tax LLP, US
• Tapati Ghose, Deloitte Touche Tohmatsu India LLP
• Swati Karkun, Global Employer Services, Deloitte Tax LLP, US
Impact of OECD Two-pillar solution in Asia Pacific: Latest developments and what to expect | 11 November 2021
Subject matter expert: Sanjay Kumar, Shefali Goradia
On 10 July the G20 endorsed the key components of the two pillar approach to international tax reform that was recently endorsed by 133 countries and jurisdictions, constituting the vast majority of the OECD/G20 Inclusive Framework (IF) on Base Erosion and Profit Shifting. Each of the two pillars addresses a separate concern.
Pillar One targets the largest multi-national groups focusing initially on those with EUR20 billion of consolidated revenue or more and net profits in excess of 10% (profit before tax/revenue) and will require them to pay tax in the locations where their customers and users are located. A formulaic approach will be used to allocate a percentage of profits between each jurisdiction. Pillar One should effectively require in scope multinationals to pay at least some tax in the markets they interact with.
Pillar Two, the key components of which are commonly referred to as the "Global Minimum Tax" or "GloBE" and which is the focus of this session, introduces a minimum effective tax rate of at least 15%, calculated based on a specific ruleset. Groups with an effective tax rate below the minimum in any particular jurisdiction would be required to pay top-up tax to their head office location. The tax would be applied to groups with revenue of EUR750 million or more, making it far more widely applicable than Pillar One.
A final decision on key design elements of Pillar One and Pillar Two is expected to be announced in October. Join our team of Deloitte specialists as they discuss these announcements and their potential implications focusing on the Asia Pacific region.
Investing in Australia: Getting the setup right | 2 November 2021
Subject matter expert: Global SMEs
Despite border closures and various restrictions imposed due to the current global pandemic, Australia is still open for business. Western Parkland City is Sydney's third, 22nd century city offering exciting new opportunities. The Federal, State and Local governments have committed, through a 20 year City Deal, to large scale infrastructure investment including the development of a new international airport in Western Sydney. As a result, many inbound investors are being attracted by the opportunity being based in the Western Parkland City presents – a digitally enabled city with 24x7 access to South East Asian market, Government grants, and incentives on offer as well as a population of 1.5 million people and a growing workforce. This session will support you to understand the business ecosystems and fiscal incentives when setting up your business in Australia, specifically Western Sydney. Our discussion will include an overview of efficient ways for international businesses to set up operations in Western Sydney and bring in their foreign talent in a highly tax effective manner. We discussed:
An introduction to Western Sydney, Australia and the investment opportunities in the new city.
• Immigration insights and solutions.
• Fiscal incentives on investments.
• Employment and mobility tax matters.
• Employee matters relating to international placement.
Virtual Symposium on litigation and dispute resolution for the energy, resources and industrial (ERI) sector | 27 October 2021
Moderater: Karishma R. Phatarphekar, Partner, Deloitte Touche Tohmatsu India LLP
Subject matter experts:
• Jimit Devani
• Ketan Ved
• Muralidharan Ramaratnam
• Advocate Paras Savla
Interactive discussion with our panel of experts on how to navigate through the top litigious issues and impact of revamped dispute resolution forums.
We discussed:
• Emerging issues and the pros and cons of the revamped dispute resolution forums to mitigate them
• Strategies for navigating through the top litigation issues
• Sharing of practical experiences of handling recent litigation issues in tribunal / courts
The return of travel: Are you ready? | 21 October 2021
Subject matter expert: Jimish Vakharia
Despite the significant ongoing border restrictions across the Asia Pacific, there is strong demand for international travel this forthcoming holiday season extending to the Lunar New Year in February 2022. The landscape for travel has changed significantly as the pandemic continues to create complexity for individuals to understand their ability to travel and potentially their ability to return to their home location.
We discussed:
The posture that companies are taking regarding personal travel, the immigration, tax and remote work risks that may be created and the support measures that organizations are proactively putting in place to identify and mitigate these risks.
Companies' approach to business travel in 2022 in order to ensure that they are able to identify and mitigate the significant additional risks, costs and duty of care requirements that will exist when business travel returns.
The approaches that forward thinking organizations are currently implementing in order to tackle the scale of these impending challenges.
Advance tax topics for Indian nationals seeking/having US residency | 20 October 2021
Subject matter experts:
• Joydeep Datta Gupta, Deloitte Touche Tohmatsu India LLP
• Anna Chapman, Subject matter expert, US
• Divya Baweja, Subject matter expert, India
• S. Ananthapadmanabhan, Subject matter expert, India
• Vijay Dhingra, Subject matter expert, India
• Jason Fox, Subject matter expert, US
• Pratik J Shah, Subject matter expert, India
Indian nationals continue to explore options to establish residency in the US. Acquiring US residency requires the individuals to consider the income and estate tax aspects.
During the first webinar, our guest speaker discussed the EB-5 migration process and our Deloitte subject matter experts answered questions around India Foreign exchange fundamentals and basic United States (US) Federal Income tax, State income tax and Estate tax as they apply to first time residents.
Deloitte Touche Tohmatsu India LLP (DTTILLP) is now hosting a second webinar to highlight and explore some of the more challenging tax obligations which Indian nationals establishing US residency or domicile typically encounter.
We discussed the following topics:
Series-2:
• US and India income tax complications
• Reporting of Assets
• US Estate and Gift tax scenarios
• Tax implications on ceasing to be a Lawful Permanent Resident
Tech industry: Emerging business models and tax in India | 18 October 2021
Subject matter experts: Chad Hungerford, Nidhi Lukose, Rajesh Gandhi, Shefali Goradia, Suchint Majmudar
As India ups its game on taxation of tech industry, MNEs may have to evaluate how it impacts their business from a corporate tax, indirect tax, and transfer pricing perspective.
This webinar seeks to discuss India tax issues relevant for the emerging business models through interesting case studies.
Join us for a webcast on 18 October 2021 at 8:30 p.m. India time for all that you need to know to make an informed decision of the impact of this India tax development on your business.
PLI Schemes: Textile sector | 7 October 2021
Subject matter experts: Anand Ramanathan, Monika Arora, Neeru Ahuja, Saurabh Kanchan
The Indian Government recently notified Production Linked Incentive (PLI) scheme for the textile sector (man-made fibres and technical textiles) with the objective of incentivising businesses. It becomes relevant for the textile players to evaluate their upcoming investment plans for achieving maximum returns.
This webinar seeks to discuss key aspects of the scheme, related corporate income tax benefits, sales acceleration strategy, experience from PLIs for other sectors and key take-aways to be PLI ready.
Join us for a webcast on 7 October 2021 at 3:00 p.m. India time for all that you need to know to make an informed decision of the impact of this India tax development on your business.
Corporate Income Tax: Compare and contrast software copyright treatment in Australia and India | 5 October 2021
Subject matter experts: Sharath Rao
The Deloitte Dbriefs Intangibles Taxation series will explore some of the key tax issues around a complex and emerging topic. Cross border related party intangibles arrangements are increasingly the focus of tax authorities from intellectual property migration to software R&D, digital services tax and Pillar 1 and Pillar 2 through to copyright royalties. We'll discuss:
• The fundamental tax and legal issues that arise when dealing with copyright in software.
• Compare the positions adopted in Australia and India in light of the India Supreme Court ruling in the Engineering Analysis Centre of Excellence Private Limited case and the Australian Taxation Office draft ruling on software TR2021/D4.
PLI Scheme for Auto sector: Key details and opportunities | 30 September 2021
Subject matter experts: Porus Doctor, Saurabh Kanchan, Sumeet Hemkar
The Government of India has notified the Production Linked Incentives (PLI) scheme for Automotive to promote investments in Advanced Automotive Technologies in India. The scheme with incentives corpus of INR 25,938 crore provides a great opportunity to the companies looking to invest in automobile sector as the Central Government is targeting to subsidize more than 50% of the new investments, linked to the performance over 5-year period.
This webinar seeks to discuss key scheme details, opportunities, and challenges in wake of this latest scheme.
Join us for a webcast on 30 September 2021 at 4:30 p.m. India time for all that you need to know to make an informed decision considering incentives on offer under the PLI scheme for automotive sector.
The duration of the webcast will be 60 minutes including time for Q&A.
4 years of India GST: Key developments and the road ahead | 23 September 2021
It has been 4 years since the introduction of GST and it has been a transformational and exhilarating journey for government, industry, consumers and all other stakeholders. The law is consistently evolving with key focus on making GST IT systems robust and taxpayer friendly, implementing anti-abuse measures and shifting to digital interface for all major procedures. In the coming year, improving revenue collections and increased taxpayer scrutiny are expected to be on the Government's radar as the authorities commence audit for first year. As India enters its fifth year of GST, let us look at last year's key developments and the road ahead. We'll discuss:
- Trend in revenue collections including impact of COVID-19 and subsequent recovery.
- Significant policy amendments including COVID-related relief measures, simplification of compliances and procedures.
- Technological changes implementing pathbreaking anti-fraud measures like e-invoicing, automated population of returns, ITC reconciliations, etc.
- Key initiatives of the government for which industry needs to gear up such as measures for facilitating digital payments, GST audits etc.
- What lies ahead for the industry such as expansion of GST to include new sectors, clarification on disputed positions, further technological changes etc.
Subject matter experts: Madhava Yathigiri, Nidhi Lukose
Indian GST and customs: Fundamentals and updates | 6 September 2021
The Indian indirect tax structure has witnessed landmark reforms with the introduction of the Goods and Services Tax (GST) and changes in customs processes. Businesses, whether prospective or existing, need to adapt to the changes for effective operations.
Over a series of webinars, our subject matter experts will discuss the Indian GST and customs landscape as well as recent updates. They will also share insights on how the changes impact Japanese companies and recommend actions that can be taken today to address key business challenges.
Our inaugural webinar covered basics of GST and customs, and key issues around taxability and categorisation of supplies under GST.
Panellists:
• Bhavik Timbadia, Subject matter expert, India
• Mahesh Jaising, Partner, Deloitte Touche Tohmatsu India LLP
• Payal Tuli, Tax Principal, DTS Global Trade Advisory
• Saloni Roy, Subject matter expert, India
• Vimal Pruthi, Subject matter expert, India
Indian GST and customs: Fundamentals and updates | 3 September 2021
The Indian indirect tax structure has witnessed landmark reforms with the introduction of the Goods and Services Tax (GST) and changes in customs processes. Businesses, whether prospective or existing, need to adapt to the changes for effective operations.
Over a series of webinars, our subject matter experts will discuss the Indian GST and customs landscape as well as recent updates. They will also share insights on how the changes impact Japanese companies and recommend actions that can be taken today to address key business challenges.
Our inaugural webinar covered basics of GST and customs, and key issues around taxability and categorisation of supplies under GST.
Panellists:
• Fumiko Mizoguchi, Partner, Indirect Tax, Deloitte Japan
• Koji Makino, Managing Director, Indirect Tax, Global Trade Advisory
• Payal Tuli, Tax Principal, DTS Global Trade Advisory
• Saloni Roy, Subject matter expert, India
US-India tax fundamentals for new US tax residents | 18 August 2021
The recent global pandemic has prompted high net worth families to consider alternate residency as a safety and security strategy. However, establishing residency in another country may bring income and estate tax complications.
The United States (US) taxation system can be especially difficult to understand and very complicated for foreign nationals with material assets in their home country.
Deloitte Touche Tohmatsu India LLP (DTTILLP) is hosting two webinars on tax issues faced by Indian families with US permanent residency. The panellists include tax specialists from Deloitte Global Employer Services, and subject matter experts, and an Immigration specialist from FRR immigration.
Series-1: Fundamental tax implications of secondary residency in the US
• EB-5 update and Issues
• Indian Foreign exchange fundamentals
• US Inpatriate Tax fundamentals
• Estate and Gift Tax fundamentals
Subject matter experts:
• Anna Chapman, Global Employer Services, Deloitte Tax LLP, US
• Joydeep Datta Gupta, Deloitte Touche Tohmatsu India LLP
• Janak Mehta, Director, FRR Immigration
• Vijay Dhingra, Subject matter expert, India
• Jason Fox, Global Employer Services, Deloitte Tax LLP, US
GIFT IFSC: An evolving landscape | 29 July 2021
A discussion on recent developments and tax incentives introduced to relocate offshore funds and set up new fund structures in Gujarat International Finance Tec-City (GIFT City) International Financial Services Centre (IFSC).
• Incentives to offshore funds in relocating to IFSC
• Incentives to new fund structures set up in IFSC
• Practical aspects and considerations in relocating existing offshore funds as well as setting up new funds
• Proposed Variable Capital Company (VCC) structure in IFSC - Key recommendations of the committee set up by the IFSC Authority
Subject matter experts:
Sandip Shah, Head – IFSC Department, GIFT City
Rajesh H Gandhi
Moderator: Monish Shah, Deloitte Touche Tohmatsu India LLP
Double tax treaty update | 7 July 2021
Ratification of the Multilateral Instrument (MLI) by many countries has resulted in one of the most across the board changes to double tax treaties in recent times but the precise consequences vary and common positions / interpretations have yet to emerge. In this session, we'll discuss:
• The changes and how they are expected to impact the Asia Pacific double tax treaties.
• Principal purposes, economic substance, and other treaty interpretation matters
• .Recent legal cases that impact treaty interpretations.
Subject Matter Expert: Gokul Chaudhri
Remote work: Setting the right strategy | 17 June 2021
The landscape of remote work is changing rapidly as the pandemic has accelerated the future of work. For many businesses, there will be reduced importance as to where work is done and increased focus on how work is done, leveraging robotics, automation, digital capabilities, connected platforms, tools and techniques. We are seeing remote work come to life in several scenarios today, and each has different features, challenges and possible approaches. Our discussion will also include a review of alternative employment models such as a GEC and where these may or may not be attractive remote work solutions. This session will focus on how companies are:
- Navigating challenges including tracking and managing employee and employer risk and compliance.
- Developing a decision making framework to manage remote work requests and mitigate compliance risk.
- Developing remote work policy, processes and governance models to implement long-term remote working solutions.
Subject Matter Expert: Vijay Bharech
Structuring for special-purpose acquisition company (SPAC) listing, tax consequence and other key aspects | 27 May 2021
Over the past decade, special purpose acquisition companies (SPACs) have gained popularity in the global markets. The year 2020 has been the year of SPAC with a record fund raise of around US$83 billion and more than 50 percent of the listing transactions in the United States having been executed through SPACs. In the first few months of 2021, the momentum of fund raising in US through SPAC has increased multi-folds with European region also raising funds through SPAC. Asia Pacific has recently witnessed its first SPAC getting close to fruition in the recent times. This has garnered a lot of interest in the business and the investor community, eliciting several questions from them on various aspects related to SPAC. In near future, it is expected that Asia Pacific will also catch on to SPAC fund raising wave soon. We'll discuss:
• An overview of SPAC.
• Structures, listing, and tax consequences and other key aspects.
• Takeaways and the way forward.
Subject Matter Expert: Hemal Mehta
Production Linked Incentives Scheme | Leap towards Atmanirbhar Bharat | 21 May 2021
The Indian Government is consistently working on fiscal reforms to drive its “Atmanirbhar Bharat” campaign.
Recently, a new framework of Production Linked Incentives (PLI) schemes is being issued by the Federal Government which provide incentives upon undertaking manufacturing activities in India and is applicable to domestic sales and to exports from India. PLI schemes are sector focussed and cover 13 different sectors for now, with a scope of more sectors to be included in the future.
These schemes also have an important interplay with corporate tax concessions. These schemes would be of interest and may be applicable to some of your investee companies.
During this webinar we would be learning about the following:
• Overview of PLI Scheme issued in India so far
• Sector coverage and benefits under the Schemes
• PLI Experience – some practical insights
Speakers:
• Shalabh Goel, Director - Finance, India and APAC, Centrient Pharmaceuticals
• Bela Sheth Mao, Host and Partner, Deloitte Touche Tohmatsu India LLP
• Gulzar Didwania, Subject matter expert
• Rajiv Bajoria, Subject matter expert
• Saurabh Kanchan, Subject matter expert
Emerging Production Linked Incentives Schemes: What's in it for you? | 29 April 2021
The Government of India has been consistently focusing on fiscal reforms to drive the "Make in India" campaign. Recently, Production Linked Incentive (PLI) schemes have been being instituted by the Federal Government which provide incentives to organizations undertaking manufacturing activities in India and is applicable to both domestic sales and to exports from India. The PLI schemes are sector focused and currently cover 13 different sectors. These schemes can be availed in parallel with state incentives as well as corporate tax concessions emerging from legal entity structuring. The early rounds of PLI notifications had significant patronage which has encouraged the government to explore extending it to additional sectors beyond the 13. Given this in context, we will discuss:
- The Indian economy in perspective and the focus on manufacturing.
- Overview of PLI schemes issued by Federal Government.
- Sector coverage and interplay with State Industrial Policies.
- Interlinkages with legal entity structuring and supply chain implications.
- Concessional corporate tax rates for new manufacturing entities and incentives to support employment generation.
- Impact for businesses
Subject matter experts:
Gulzar Didwania
Neeru Ahuja
PS Easwaran
Transfer Pricing in uncertain times: Considerations for year-end book closure | 14 April 2021
The catastrophic impact of the COVID-19 pandemic will be far reaching—one of the implications MNCs will be closely deliberating at the time of book-closure of the first COVID impacted year is the treatment to transfer prices with related parties, particularly as the supply chain of companies is dramatically impacted.
Such uncertain and unprecedented times will require a multi-pronged bespoke approach which will provide you with the following support:
• Predict an appropriate arm’s length price.
• Align the business specific impact with your transfer pricing policy.
• Create a contemporaneous documentation or legal evidence file to mitigate your future audit risks.
Join us as we discuss experiences on risk mitigation strategies, as well as holistic approaches towards the challenges presented by the pandemic, and how we can navigate the year-end book-closure.
Subject matter expert:
• Karishma Phatarphekar, Partner, Deloitte Touche Tohmatsu India LLP
• Atul Gupta, subject matter expert
• Bhupendra Kothari, subject matter expert
• Richa Gupta, subject matter expert
Tax controversy in Asia Pacific: Implications and takeaways (Part 3) | 7 April 2021
The tax environment is changing rapidly with tax authorities once again becoming more focused on tax disputes post all the government relief provided because of Covid-19. In part 3 of our 3 part Tax Controversy series, we review the administrative and practical approach of the tax authorities to controversy and disputes in the region. We'll discuss:
• Tax authorities approach to controversy and disputes in the region.
• Key takeaways.
Subject matter expert: Ketan Ved
Special-purpose acquisition company (SPAC) | 25 March 2021
Over the past decade, special-purpose acquisition companies (SPACs) have gained popularity in the global markets. The year 2020 has been the year of SPAC with a record fund raise of around US$83 billion and more than 50 percent of the listing transactions in the United States having been executed through SPACs.
India saw its first SPAC getting close to fruition in the recent times with the announcement of the merger of RMG II SPAC and Renew Power (Renew SPAC). This has generated a lot of interest in the Indian business and the Investor community, eliciting several questions from them on various aspects related to SPACs.
In the first of a series of sessions dedicated to SPACs, please join us for a deep dive into the structuring considerations in a SPAC and engage in a discussion around the practical challenges and insights in the SPAC journey.
Moderator for the session
• Kalpesh Maroo, Partner, Deloitte Touche Tohmatsu India LLP
Speakers for the session
- D Muthukumaran, CFO, Renew Power Limited
- Harshal Kamdar, CFO, Sequoia Capital
- Hemal Mehta, Subject matter expert
Tax controversy in Asia Pacific: Implications and takeaways (Part 2) | 25 March 2021
The tax environment is changing rapidly with tax authorities once again becoming more focused on tax disputes post all the government relief provided because of Covid-19. In part 2 of our 3 part Tax Controversy series, we review some of the key tax cases in the region from 2020 dealing with transfer pricing and how the tax authorities utilize transfer pricing in tax disputes. We'll discuss:
• Transfer pricing cases in the region and practical implications of those rulings.
• Key takeaways.
Subject matter expert: Karishma Phatarphekar
Recent Supreme Court ruling on Taxation of Software | 20 March 2021
The Indian Supreme Court (SC), vide its judgment dated 2 March 2021, decided a two-decade long income-tax litigation in India in relation to whether payments to foreign vendors towards purchase of computer software ought to be characterised as ‘royalty’ under the domestic law and/or the Double Tax Avoidance Agreements (DTAAs).
This landmark pronouncement must bury the historical tax controversy on software taxation in India, even as the 2012 amendment to the ‘royalty’ definition could hold the sway in cases which are not amenable to beneficial outcome under the DTAAs. Whilst the taxpayers rejoice the outcome, the Revenue may seek a remedial course under revisionary powers of the Supreme Court despite the unequivocal ratio laid down in the ruling. The Revenue’s ability to access any remedy in this case, however, would not be free from legal lacunae or limitations.
We have invited following legal experts to share their perspective over a general discussion on the ruling:
• Ajay Vohra, Senior Advocate
• N. Venkatram, Senior Advocate and Additional Solicitor General of India
• R. V. Easwar, Senior Advocate and Retired Judge Delhi High Court
Tax controversy in Asia Pacific: Implications and takeaways (Part 1) | 16 March 2021
The tax environment is changing rapidly with tax authorities once again becoming more focused on tax disputes post all the government relief provided because of Covid-19. In part 1 of our 3 part Tax Controversy series, we review some of the key tax cases in the region from 2020 dealing with general anti avoidance (GAAR) and how the tax authorities utilize GAAR in tax disputes. We'll discuss:
• Tax cases in the region and practical implications of those rulings.
• Key takeaways.
Subject matter expert: Sharath Rao
Indian Supreme Court judgment on income-tax characterisation of software payments | 6 March 2021
The Indian Supreme Court (SC), vide its judgment dated 2 March 2021, has decided a two-decade long income-tax litigation in India in relation to whether payments to foreign vendors towards purchase of computer software ought to be characterised as ‘royalty’ or as purchase of goods.
The SC, through an unanimous judgment pronounced by a bench of three Judges, allowed the appeals of the companies (filed against a Karnataka High Court ruling decided against the companies) and rejected the Revenue appeals (filed against a Delhi High Court decided against the Revenue). In a fairly detailed judgment, the SC held that payments made to foreign vendors towards simpliciter purchase of software (either by Indian distributors, for onward distribution to end-users or directly by Indian end-users) cannot be said to be a payment towards use of the copyright therein. As such, the payments are not taxable in India in the hands of the foreign vendors as ‘royalty’, for the years prior to the 2012 amendment to the definition of ‘royalty’ in the Indian domestic tax law. No TDS (withholding tax) therefore applies. The SC held that the 2012 retroactive amendment to the ‘royalty’ definition has to be implemented only prospectively and not retroactively. The SC also held that given the Double Tax Avoidance Agreements (DTAAs) override principle in the Indian income-tax law, the payments would not be taxable as ‘royalty’ under most of India’s DTAAs, even after the 2012 amendment in the Indian domestic tax law.
Subject matter experts:
• Arvind Datar, Senior Advocate, Supreme Court of India, Delhi
• Aravind VA, Direct Tax Head – India/South Asia, IBM
• Karishma Phatarphekar, Partner, Deloitte Touche Tohmatsu India LLP
• Rohinton Sidhwa, Subject matter expert
• Sharath Rao, Subject matter expert
Parental Corporate Guarantee: Changing landscape | 25 February 2021
Parental corporate guarantees are common intercompany transactions. Recently, tax and regulatory have been quite vigilant about these transactions and have been scrutinizing these transactions more closely. Unlike intercompany loans, pricing guarantees can be specifically tricky, given that in these transactions, a compensation is warranted only if there is a specific benefit conferred to the recipient. That more often than not is not so straightforward. Besides, there is always a risk of given default for the guarantor. The OECD paper on transfer pricing of financial transactions, issued in February 2020 as part of the BEPS inclusive framework, gives some valuable insights. We'll discuss:
• Transfer pricing aspects of downstream guarantee, upstream guarantee, and cross guarantees.
• Performance guarantee and letter of comforts and support.
• Specific country requirements in Asia Pacific.
Explore the latest developments in this important area of transfer pricing and how your organization might need to respond.
Subject matter experts: Sanjay Kumar and Trina Maitra
India's new labour codes: Prepare for the challenges ahead | 23 February 2021
The Ministry of Labour & Employment, Government of India, has initiated steps to simplify, amalgamate, and rationalize numerous central labour laws, into the following four labour codes - Code on Wages, Code on Social Security, Code on Industrial Relations, and Code on Occupational Safety, Health and Working Conditions. All the four labour codes have now received the assent of the President and the draft rules have also been issued. The Codes are now awaiting the notification of the effective date. We'll discuss:
• An overview of the four labour codes.
• Analysis of various definitions and their impact.
• Areas of focus and possible challenges.
Learn about the latest updates in India's labour codes and how you may need to address the challenges going forward.
Subject matter experts: Saraswathi Kasturirangan, Anjali Malhotra, Atul Mittal, Radhika Viswanathan
Gear up for the labour codes | 16 February 2021
The Ministry of Labour & Employment, Government of India has initiated steps to simplify, amalgamate, and rationalise numerous central labour laws, into the following four labour codes:
1. Code on Wages
2. Code on Social Security
3. Code on Industrial Relations
4. Code on Occupational Safety, Health and Working Conditions
While all four codes listed above, have been approved by Parliament and the Acts have been formulated, their effective date and the final rules are yet to be notified.
We invite you to join us for a knowledge-sharing session with our subject matter experts, and gear up to overcome the challenges of adopting the Codes.
Here is the agenda for the webinar:
• Overview of the specified codes
• Analysis of wage definition, and evaluation of their impact
• Focus areas and possible challenges
US Tax Update: What the new US administration has in store? | 11 February 2021
The Tax Cuts and Jobs Act of 2017 included significant modifications to international provisions of the US Tax Code.
With Joe Biden being sworn in as the 46th President of the United States of America on 20 January 2021, a change in course may be expected as the new US administration prepares to advance his tax policy agenda.
This webinar seeks to provide an interesting discussion on reviewing the tax policy agenda laid out by President Biden in his election campaign.
The proposed tax changes, among others seeks to increase the headline US corporate tax rates as well as GILTI rates, introduce a Minimum Alternate tax on non-US tax paying companies above a specified threshold, provide credits for Make in America, introduce a 10% surtax (offshoring penalty).
As for individual taxpayers, there may be some cheer for low and middle income taxpayers, although tax rates may go north for high income earners.
It is imperative to understand the impact these changes could have on the overall business models and tax costs of US corporations holding Indian subsidiaries and Indian MNCs holding US subsidiaries or having operations in the US. The changes could potentially impact several business operations such as intra-group transactions, outsourcing work outside US, manufacturing and undertaking qualifying activities to obtain credits in US, etc.
Join us for a webcast on 11 February 2021 at 7:00 p.m. India time for all that you need to know to make an informed decision of the impact of this significant development on your business.
The duration of the webcast will be 45 minutes including time for Q&A.
Subject matter experts:
• Jeffrey Kummer, Tax Managing Director, Deloitte US
• Vivien Wang, Tax Partner, Deloitte US
• Vasudha Rangaprasad, Tax Principal, Deloitte US
• Rajesh Gandhi
Union Budget Webinar for Japanese companies | 8 February 2021
The Government of India will present the Union Budget for the financial year 2021-22 on 1 February 2021. The budget normally has many policy statements, which have bearing for foreign investors as well as domestic companies and other stakeholders. Given the active policy work of the Government in areas such as farming and labour, expectations run high among all stakeholders.
Deloitte Touche Tohmatsu India LLP (DTTILLP) will be hosting a policy webinar to discuss analytically the impact of the budget on the Indian economy, with a focus on the measures taken by the central as well as state governments to create opportunities for the Japanese MNCs.
Key features of the webinar
- Budget 2021 - Policy and key tax proposals
- Diversification of supply chain
- Trends in the market
- Experts from Embassy of India
Subject matter experts:
- H.E. Sanjay Kumar Verma, Ambassador of India to Japan
- Dr. Sanjay Kumar, Partner, Tax and Public Policy Leader, Deloitte Touche Tohmatsu India LLP (DTTILLP)
- Mona Khandhar, Minister (E&C), Embassy of India, Tokyo, Japan
- Anand Ramanathan, Partner, Deloitte
- Masumi Hirayama, Principal, International Tax, Deloitte Singapore
- Fumiko Mizoguchi, Partner, Indirect Taxes, Deloitte Japan
- Bhavik Timbadia, JSG Tax Leader, Deloitte India
India Budget 2021 Life Sciences and Healthcare | 5 February 2021
India Budget 2021 was presented in Parliament on February 1, 2021. As expected, health and well-being topped the list in the six-pillared Budget announced by the Finance Minister.
Keeping in perspective the holistic approach of prevention, cure, and well-being, the FM introduced certain schemes focussing on healthcare infrastructure. There have been many representations to the government to provide reliefs and tax sops to encourage private sector engagement in the areas of research and increase the affordability of healthcare.
Join our subject matter experts along with speakers from the industry for an in-depth analysis of Budget proposals. The session lays special focus on :
• The impact of the budget proposals on the industry
• Opportunities and challenges on the road ahead
India Budget 2021 PE/RE | 2 February 2021
India Budget 2021 will be presented in Parliament on February 1, 2021. This year all eyes are set on how the government will reset its growth agenda and strike a balance between industry expectations and economic outlook.
There have been many representations to the government to provide reliefs and tax sops to spur economic growth, however, it will be interesting to see how the government balances such expectations along with the rising fiscal deficit.
Join our subject matter experts for an in-depth analysis of Budget proposals that could impact the Private Equity investors, their portfolio entities, and the Real Estate sector. The session lays special focus on :
• The current economic situation and the roadmap for the financial year 2021-22
• Key tax and regulatory proposals, with a special focus on impact for PE/RE
India Budget 2021: Towards a thriving India | 2 February 2021
India Budget 2021 will be presented in the Parliament on 1 February 2021. This year, all eyes are set on how the government will reset its growth agenda and strike a balance between the health and medical care needs and economic outlook. With digital as a necessity in the new world order, the expectations are on a rise. Fresh opportunities and revival of demand are the sources of optimism, and these are leading the country towards the journey of a thriving India. We'll discuss:
• The Government's initiatives on reviving the industries, boosting optimism, and proposals on the tax front.
• Key announcements towards making India self-reliant.
• Detailed analysis and impact of new tax proposals on your business, and the way forward.
Join our Deloitte specialists as they share a short, simple, and strategic take on the India Budget 2021.
Subject matter experts: C A Gupta, Monika Arora, Manoj Kumar, Priya Narayanan
India Budget 2021 FPIs: Webinar invitation
Date: Option 1: Monday, 1 February 8 p.m. India time
Option 2: Tuesday, 2 February 10:30 a.m. India time
This year all eyes are set on how the government will reset its growth agenda and strike a balance between industry expectations and economic outlook.
There have been many representations to the government to provide reliefs and tax sops to spur economic growth, however it will be interesting to see how the government balances such expectations along with rising fiscal deficit.
Join our subject matter experts for an in-depth analysis of Budget proposals which could impact Foreign Portfolio Investors (FPIs). The session lays special focus on :
• The current economic situation and the roadmap for financial year 2021-22
• Key tax and regulatory proposals, with a special focus on impact for FPIs
Subject matter experts:
• Rajesh H. Gandhi
• Sanjay Kumar
• Sanjoy Datta
Union Budget 2021: Highlights | 1 February 2021
India Budget 2021 will be presented in the Parliament on 1 February 2021. This year, all eyes are set on how the government will reset its growth agenda and strike a balance between the health and medical care needs and economic outlook. With digital as a necessity in the new world order, the expectations are on a rise. Fresh opportunities and revival of demand are the sources of optimism, and these are leading the country towards the journey of a thriving India.
Join our subject matter experts as they share a short, simple, and strategic take on the India Budget 2021. We will discuss:
- The Government's initiatives on reviving the industries, boosting optimism, and proposals on the tax front
- Key announcements towards making India self-reliant
- Analysis and impact of new tax proposals on your business, and the way forward
Navigating intra-group service challenges in Asia Pacific | 28 January 2021
The challenges many companies face when charging headquarter or shared service center transfer pricing in Asia Pacific is long running and well known. It is even more pronounced in the current environment. For example, the benefit of companies' IT and digital spending is clearer to remote working employees, regulators, and tax administrators while pressure to reduce cost and operating leverage is acute. Against this backdrop, we will discuss the approaches to navigate these challenges and our professionals from across the region will examine three important questions:
• How has the audit environment for intra-group services and the definition of "low value" changed since the OECD released advice on low value-adding intra-group services?
• What is the interplay between commercial, financial service regulatory, and transfer pricing trade-offs to consider when putting in place or improving transfer pricing arrangement for intra-group services?
• With limited resources to operate intra-group services transfer pricing, what are the practical ways to determine and defend intra-group service charge deductions in Asia Pacific?
Find out what could help your organization to respond to the intra-group service challenges and prepare for the future.
Subject matter experts: Anushree Jagnani
Redefining priorities for global mobility, rewards, and talent: Webinars on respond, recover, and thrive | 20 January 2021
Series-3 (Thrive): COVID-19 has been impacting travel, ways of working, and ways of living across the globe. During this time, leaders are being asked to not only react to ever-changing global events, but also plan, manage business continuity, learn and emerge stronger, and prepare for the next normal.
We are organising a series of webinars covering the three stages of the COVID-19 crisis—respond, recover, and thrive.
In the upcoming ‘Thrive’ series, we will discuss the following factors on how an organisation prepares for, and shapes the “new normal”:
• Defining the next normal: With uncertainty and challenges persisting with the global pandemic, how are organisations considering to thrive? How should the performance be measured in a radically different talent environment?
• Conditions impacting government and employee behaviour: Discuss possible changes in approaches the governments collecting tax revenue, and consider what is the talent marketplace telling us about remote work, productivity, and engagement.
• Determining outcomes: End with actionable next steps on how to consider and what to do with a changed global workforce. Learn from our guest client speaker and each other.
Subject matter experts:
• Dharmesh Kothari, Vice President, Publicis Groupe
• Jeff Schwartz, Subject Matter Expert, US
• Poorva Prakash, Subject Matter Expert, India
• Michelle Fertig, Global Employer Services, US
Understanding the Code on Social Security 2020 | 18 November
The Ministry of Labour and Employment, Government of India has taken an important initiative of simplification and amalgamation of numerous central labour laws into the following four labour codes:
1. Code on Wages,
2. Code on Social Security,
3. Code on Industrial Relations and
4. Code on Occupational Safety, Health and Working Conditions
The Code on Social Security encompassing provisions relating to provident fund, employees’ state insurance (ESI), gratuity, and maternity benefit among others was passed during the monsoon session of Parliament, and received Presidential assent on 28 September 2020. The effective date of its coming into force is awaited.
We invite you to join us for a knowledge- sharing session by subject matter experts, on the compliance aspects relating to the Code on Social Security.
Agenda for the webinar is as follows:
• Overview of the Code on Social Security
• Analyse the key features of the Code, i.e., applicability, procedural requirements, and understanding the impact
• Discuss the compliance requirements, challenges, and concerns
Register for an update on the upcoming Code on Social Security.
GIFT IFSC 2020: A new global fund jurisdiction | 10 November
In 2015, India set up its first International Financial Services Centre (IFSC) in the newly established Gujarat International Finance Tec-City (GIFT City), in the western state of Gujarat. The GIFT IFSC initially offered business opportunities in diverse financial areas including banking, capital markets, insurance, asset management, and ancillary services. In 2015, the Indian regulators allowed the setting up of Alternative Investment Funds (AIFs) in GIFT IFSC. Since then, many tax incentives have been rolled out by the Government of India to promote fund activities in GIFT IFSC.
In a recent development, capital gains from non-equity investments made by a Category III AIFs set up in IFSC have been exempted from tax in the hands of the AIF and its investors. Tax exemption is further extended to transfer of units of the AIF between investors.
This is a significant move and would enable GIFT IFSC to compete with popular offshore fund jurisdictions such as Singapore and Mauritius.
Please join Deloitte Touche Tohmatsu India LLP for an interactive discussion on the framework and opportunities for setting up fund structures in Gujarat International Finance Tec-City International Financial Services Centre (GIFT IFSC).
We will discuss:
• A brief update on the GIFT IFSC ecosystem, stakeholders, key tax and regulatory aspects, and recent developments
• Opportunities and issues for a fund in GIFT IFSC
• How do the recent changes compare GIFT IFSC with key offshore jurisdictions such as Singapore and Mauritius?
Moderator:
• Monish Shah, Deloitte Touche Tohmatsu India LLP
Subject matter experts:
• Arjun Prasad, Deputy General Manager, International Financial Services Centres Authority (IFSCA)
• Sandip Shah, Head – IFSC Department, GIFT City
• Rajesh Gandhi
M&A and COVID-19 strategy in India, Japan, and Korea: Charting new horizons in a world of asymmetric recovery | 10 November
M&A activity is likely to be dominated through an offensive strategy or a defensive strategy with a view to maximizing value. Asia Pacific remains the hot bed of economic activity and the focus on the region from an M&A perspective is quite high. For buyers, the greater opportunity of companies likely to streamline and reposition their portfolios, through the sale of non-core businesses pursuant to the pandemic, is leading to an increase in potential investment opportunities. However, end-to-end M&A, which includes but is not limited to carve-out and acquisition/disposal of a business presents some unique challenges. Professionals from different tax geographies will discuss:
• Divest non-core or distressed assets and wind down underperforming businesses.
• Pursue co-investment opportunities for capital intensive projects and opportunistic deals to safeguard core markets.
• Acquire distressed underperforming peers and early stage companies and capabilities to accelerate digital transformation.
• Strategic acquisitions to fill the portfolio of operations and vertical integration.
Learn about practical issues in connection with M&A tax considerations for possible buyers and potential sellers in India, Japan, and Korea.
Subject matter experts: Rahul Vig
Redefining priorities for global mobility, rewards, and talent: Webinars on respond, recover, and thrive | 4 November
Series-2 (Recover): COVID-19 has been impacting travel, ways of working, and ways of living across the globe. During this time, leaders are being asked to not only react to ever-changing global events, but also plan for the future, manage business continuity, learn and emerge stronger, and prepare for the next normal.
We are organising a series of webinars covering the three stages of the COVID-19 crisis—respond, recover, and thrive.
In the upcoming ‘Recover’ series, we will discuss the following factors that will help an organisation learn and emerge stronger:
• Headcount optimisation: Evaluating talent cost enhancement strategies including unique considerations for mobile employees (travel assigned, transferred, etc.)
• Broad-based rewards: Re-evaluating employee compensation and benefits for the ‘Recover’ phase focused on stabilising operations
• Equity & long-term incentives: Plan and program considerations to balance cost reduction pressures and talent engagement
Subject matter experts:
• Anupama Kaul, CHRO, Cummins
• Peter Simeonidis, Global Employer Services, US
• Homi Mistry, Subject matter expert, India
• Ian Dawson, Subject matter expert, US
• Claire Morrow, Global Employer Services, US
India's Equalization Levy: What comes next | 3 November
Internationally, the widespread growth in digitization of business has created challenges in allocation of taxes between market jurisdictions and headquartered jurisdiction. While the OECD has been working on arriving at a consensus on taxation of the digital economy, based on the recommendations in the BEPS action plans, many countries, have either proposed or implemented a unilateral Digital Services Tax. Further, the United Nations has introduced a proposal in the form of Article 12B (Income from Automated Digital Services) possibly in a bid to give a simple and easy to implement solution. India was the first country to introduce a digital tax called the "Equalization Levy" in 2016 on online advertisement services purchased from non-resident companies and from 1 April 2020, the scope of the Equalization Levy has been expanded to include levy on all online sale of goods or services into India by non-resident e-commerce operators. In this session, we'll discuss the following:
• Update on OECD's position on Pillar One and Pillar Two.
• Overview of the UN's Proposal on income from Automated Digital Services – Article 12B.
• Asia Pacific update on Digital Services Taxes or other responses.
• India's Equalization Levy.
• Case studies on the Indian experience.
Stay updated on the latest developments on digital services taxes and the Indian Equalization Levy and its impact on your organization.
Subject matter experts: Manoj Kumar, Radhakishan Rawal, Shefali Goradia
G20/OECD Inclusive Framework on BEPS: Reports on Pillar One and Pillar Two Blueprints | 27 October
On 12 October 2020, OECD released a package consisting of the reports on the Blueprints of Pillar One and Pillar Two. These Blueprints give details of the architecture and policy rationale of the proposed solutions. These represent a significant departure from the current framework of international taxation and allocate higher taxing right to the market jurisdictions.
Mr. Rasmi Ranjan Das, Joint Secretary (FT&TR-I), CBDT will share his views on the proposed solutions. The event will predominantly focus on Pillar 2 proposals with high-level comments on Pillar One. We will discuss the following along with examples:
· Income Inclusion Rule (IIR)
· Undertaxed Payment Rule (UTPR)
· Switch-over Rule (SOR)
· Subject to Tax Rule (STTR)
Guest speaker: Rasmi Ranjan Das, Joint Secretary (FT&TR-I), CBDT, Department of Revenue, Ministry of Finance
Subject matter experts: Ashutosh Dikshit, Radhakishan Rawal, Shefali Goradia, Vishweshwar Mudigonda
India's shift from dividend distribution tax to taxing the shareholder: Issues, challenges, and opportunities | 20 October
India has abolished its two-decade-old levy of dividend distribution tax on domestic companies and moved back to the classical system of taxing dividends in the hands of shareholders. Domestic companies will now therefore have to comply with withholding tax provisions on dividend declared. We'll also discuss:
• Impact on the shareholders.
• Concept of beneficial ownership under tax treaty.
• Impact of General Anti-Avoidance Rules (GAAR), Principal Purpose Test (PPT), and Multilateral Instrument (MLI).
• Availability of lower rate under Most Favoured Nation (MFN) clause.
• Documentation to be maintained by domestic companies.
Gain insights on how this will impact your organization.
Subject matter experts: C.A. Gupta, Rashmi Maskara, Sujit Parakh
Gearing up for the labour codes – Code on Wages | 7 October
The Ministry of Labour and Employment, Government of India has taken an important initiative of simplification and amalgamation of numerous central labour laws into the following four labour codes:
- Code on Wages,
- Code on Social Security,
- Code on Industrial Relations and
- Code on Occupational Safety, Health and Working Conditions
The Code on Wages which was enacted in August 2019 is awaiting notification for the effective date. The draft rules were also published earlier this year, and stakeholder suggestions were invited. We expect the revised rules to be published soon.
The other three codes have also received the Presidential assent and now awaiting the notification of the effective date.
Deloitte Touche Tohmatsu India LLP invite you to join us for a knowledge-sharing session by subject matter experts, on the compliance aspects relating to the Code on Wages read with the draft rules.
Agenda for the webinar:
- Overview of the Code on Wages
- Analyse the key features of the Code, i.e., definitions, applicability, procedural requirements, and understanding the impact of the same
- Discuss the compliance requirements, challenges and concerns
Subject matter experts: Nitin Shingala, Saraswathi Kasturirangan, Radhika Viswanathan, Tarun Garg
Redefining priorities for global mobility, rewards, and talent Webinars on respond, recover, and thrive | 30 September
COVID-19 has been impacting travel, ways of working, and ways of living around the globe. During this time, leaders are being asked to not only react to ever-changing global events, but also plan for the future, manage business continuity, learn and emerge stronger, and prepare for the next normal.
A typical crisis plays out over three time frames:
• Respond, in which a company deals with the present situation and manages continuity;
• Recover, during which a company learns and emerges stronger;
• Thrive, where the company prepares for and shapes the “next normal”.
We are organising a series of webinars on the three stages, covering the following aspects:
Series-1 (Respond)
We will discuss how an organisation deals with the present situation and manages mobility, rewards, and talent for business continuity:
• Workplace and policy | revising work arrangements
• Compliance and regulatory | re-evaluating the future of employee mobility
• Economic and tax relief | understanding stimulus packages
Subject matter experts: Saraswathi Kasturirangan (India), Joel Eisenreich (Global), Michelle Fertig (Global), Chaitanya N Sreenivas (VP HR & HR Head India South Asia at IBM)
Gearing up for the labour codes | 15 September
The Ministry of Labour & Employment, Government of India has initiated steps to simplify, amalgamate, and rationalise numerous central labour laws, into the following four labour codes:
1. Code on Wages
2. Code on Social Security
3. Code on Industrial Relations
4. Code on Occupational Safety, Health and Working Conditions
The Code on Wages was enacted in August 2019 and is awaiting notification for the effective date. The draft Code on Social Security has been reviewed by the Parliamentary Standing Committee and is subject to recommendations shared by them. We expected this to be enacted shortly as well.
We invite you to join us for a knowledge- sharing session by Deloitte subject matter experts, on gearing up to meet the challenges of adopting the Code on Wages and the Code on Social Security.
Agenda for the webinar:
• Overview of the specified codes
• Analysis of various definitions and understanding their impact
• Areas of focus and possible challenges
Subject matter experts: Nitin Shingala, Saraswathi Kasturirangan, Radhika Viswanathan, Tarun Garg
Elevate your mobility program through data analytics | 8 September
Mobility eco-systems are evolving and have become more and more complex over time. In a post COVID-19 era, what will mobility and the eco-systems we know look like? How organizations use and make the most of their data will underpin how you support your globally mobile workforces and navigate this new normal. We'll discuss:
• Trends in data management, analytics, and insights they might bring to mobility programs.
• Strategies for advancing the use of mobility analytics, including industry practices and market solutions.
• Building the business case for change and the budget to enact it, including factors that can make an effective case.
• How government authorities in Asia Pacific leverage data to make compliance requirements simpler for your mobile employees.
Gain insights on how organizations are leveraging data to elevate their mobility program, and make forward-thinking decisions about deploying global talent.
Post COVID-19 changes and transformations in the operating model: A focus on China and India | 18 August
While the COVID-19 pandemic may have constrained you physically to work from home, this critical moment breaks the brick-n-mortar of your decision-making at functional level. If the digitalization before COVID-19 is the innovation of the leader or the icing on the cake of the conventional business, then the operation digitalization during the pandemic is becoming the inelastic demand for the enterprise to maintain operation. Companies are increasingly engaging across traditional organizational boundaries and faced with business questions such as: What to do to unleash cash flow potential? How to adjust the supply chain? Which new technologies and business models will emerge from this crisis? In the post COVID-19 era, enterprises' non-contact automation, intelligence and digital business operation capabilities not only ensure the smooth and orderly operation of business, but also promote the efficiency and compliance of the back office operation. Thus, change is coming. We'll discuss:
• Tax and regulatory perspective.
• Changes in operating model.
• Practical case studies.
• Cash flow optimization options.
• The way forward.
Find out what could help your organization to respond to the new challenges from digital transformation to digitalization operation and begin to move towards a new “usual”.
India's GST update: Impact, challenges, and what's next | 11 August
It has been three years since the introduction of Goods and Services Tax (GST), India's biggest tax reform, on 1 July 2017. It has been a fascinating ride for the Government, industries and consumers, due to the host of changes and reforms introduced in the past three years. These changes were primarily focused on rationalizing rates, simplifying procedures and curbing tax evasion. Stabilizing one of the world’s biggest online tax systems, i.e., GSTN, was also a key focus area for the Government. A world-class, simplified, and technology-enabled robust GST system is not only critical for a sustainable growth, but also imperative for the ease of doing business. In the next few years, the Government may take steps to further simplify the GST law. These steps can prove to be a harbinger of growth at a time when the entire world is affected by the COVID-19 pandemic. We'll discuss:
• How successful has this historical tax reform been in achieving its desired objectives
• What has worked well for the Government and taxpayers?
• What are the key challenges facing the industry?
Stay ahead on India's GST developments to better prepare your business for the future.
Preparing the manufacturing sector for post COVID-19 | 18 June
The manufacturing sector has been adversely affected by COVID-19, and bouncing back is going to have several implications. Re-starting the business after the lockdown, calls for changes and support business revival and growth.
While the Central and State Government’s measures may help the manufacturing units to stand up, corporate leaders need to put in place new business plans on different taxes and improve their prospects in these difficult times.
We invite you to join for an interactive knowledge sharing discussion shared by Deloitte Subject Matter Experts on closely monitoring the COVID-19 impact on the manufacturing industry.
Agenda for the webinar:
• Cash optimisation measures
• Government incentives for manufacturing
• Strategies for business efficiency
AAR ruling on tax avoidance threshold | 10 June
The recent ruling* from Authority for Advance Rulings (AAR) rejects the applicants’ contention of relying on the India Mauritius tax treaty to seek capital gains exemption in case of an indirect transfer. AAR ruled that the transaction was designed prima facie to avoid tax, and concludes that the applicant companies were only a ‘see-through entity’ to avail the benefits of India-Mauritius Double Tax Avoidance Agreement (DTAA). It has also made remarks on the holding structure, management & control aspects, interpretation of Article 13(4), and use of the grandfathering benefits under the treaty.
Join us for a webcast on a general discussion on the implications of the ruling. We will discuss the following topics:
• Analysis of the decision
• Probable pitfalls?
• Insights on Interpretation of the Legal Jurisprudence by relevant external subject matter expert
COVID-19: Global trade impacts and considerations | 2 June
To respond to the threat posed by the COVID-19 pandemic, governments across the globe are developing policies to protect the public and to help businesses deal with its impact. Deloitte Global Trade Advisory (GTA) professionals throughout the world are monitoring developments with respect to trade regulatory measures and its impact to businesses. We'll discuss:
- Recent trade regulatory developments in Asia Pacific.
- What trade measures businesses can consider as they seek to recover from the impact of COVID-19.
Stay updated on the latest developments on trade regulatory and its impact on global trade.
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