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Deloitte India Tax webcasts

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Upcoming webcasts

Structuring for special-purpose acquisition company (SPAC) listing, tax consequence and other key aspects

Date: 27 May 2021

Time: 11:30 AM India time

Subject Matter Expert: Hemal Mehta

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.
 

Remote work: Setting the right strategy

Date: 3 June 2021

Time: 11:30 AM India time

Subject Matter Expert: Vijay Bharech

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 the short-term 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.

Previous webcasts

Emerging Production Linked Incentives Schemes: What's in it for you? | 29 April

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

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

The Direct Tax Vivad se Vishwas Act, 2020 | 16 December

With a view to clear the backlog of litigation, the Indian Government launched a direct tax litigation settlement scheme named the Direct Tax Vivad Se Viswas Scheme (VSV scheme) in March 2020. The VSV scheme offers taxpayers a one-time window to settle their pending income tax litigation by filing for settlement before 31 December 2020.

According to the information available on public domain, 45,855 declarations have been filed under the VSV Scheme until 17 November 2020, and a total of INR724,800M had been paid by the taxpayers. With many of the eligibility and computational related aspects clarified in the first set of FAQs, the CBDT has also issued second set of FAQs recently to aid taxpayers to adopt a pragmatic and rational decision with reference to their tax dispute matters.

Subject matter experts:
• Satyakam Mishra, Principal CCIT(International Taxation), Delhi
• Pragya Sahay Saksena, CCIT(IT&TP)WZ, Mumbai
• Gangadhar Panda, CIT(IT)-2, Delhi
• Jasdeep Singh, CIT(IT), Chennai
• P Chandershekhar, CIT(IT&TP), Hyderabad
• Gaurav Kanaujia, CIT(IT&TP), Kolkata
• Vipul Jhaveri, Subject matter expert
• Karishma Phatarphekar, Subject matter expert
 

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:

  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 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.

Buyback of shares: Key considerations | 4 May

With the rapidly evolving COVID-19 scenario, financial markets are in flux resulting in unprecedented volatility. There has been a sharp decline in Indian stock markets over the past few weeks. During these times, some companies may be looking at buy back of shares in the light of the recent developments.


Please join us for a webcast that will give an overview of the aspects involved in buyback of shares and the relevant practical considerations, including deliberation on the contributions by the participants during the webcast.

An eminent speaker from the industry will also share his views on the topic.

Recent India tax and regulatory environment and updates | 28 April and 30 April

The Indian Finance Bill, 2020 has been passed by the Parliament as Finance Act, 2020 with a few significant changes.

In addition, owing to the disruption caused by COVID-19, the Government of India has announced a number of tax and regulatory measures to provide relief to companies and individual tax payers (including expatriates).

We invite you to join us for a series of webinars scheduled for 28 and 30 April 2020. We will discuss the current environment along with updates. These sessions will be in Chinese language.

Agenda for 28 April:

  • Key amendments under Finance Act, 2020 from corporate and personal taxation perspective
  • Tax and Regulatory measures taken by authorities to relieve the compliance and cash flow burden of tax payers
  • Mobility and other related considerations for employees (including expatriates)

Join us for the important updates, and prepare for what's next.

Transfer Pricing: Recent developments on profit attribution in India and China | 28 April

Recent discussions in the OECD/G20, and more widely, particularly on profit attribution for digital taxation, have for once opened the doors for fundamentally new approaches. Established norms of arm's length pricing for allocating profits of MNEs for taxation across countries, with almost no attribution to markets where sales or use occur are being challenged. All these changes are presenting significant challenges to the companies. We will be focusing on countries such as India and China and more broadly covering the Asia Pacific region, and analyze the developments in these countries, dealing with the scope of and attribution to Significant Economic Presence. Realizing that this can spawn disputes, the Indian government has also proposed activation of APA mechanism for permanent establishment cases, besides covering also by safe harbour rules. Relevant agency PE risk mitigation in China, and interconnection between PE and pillar one profit attributions will be part of the discussion. We'll discuss:

  • Scope of Significant Economic Presence in India and attribution of profits thereto – amendments basis India Budget.
  • Expanding the scope of APA and Safe Harbour to cover PE and Significant Economic Presence.
  • Agency PE risk mitigation approaches in China, and its position on profit attribution to PE and Pillar one.

Stay informed about the latest developments on profit attribution and prepare for the future.

What Tax Departments can consider in light of an expected recession – Downturn Planning | 22 April

Most tax departments have last experienced a downturn during the financial crisis a decade ago. A downturn can create:

  • Unexpected compliance challenges.
  • Needs and opportunities to generate or move cash.
  • Requirements to re-align your structure with your organization's long term goals.

Our Service Line Leaders will provide a refresher on what to look out for from a corporate domestic and cross border taxation perspective.

Equalisation levy on e-commerce supply and services | 3 April

The India Finance Act, 2020 was enacted on 27 March 2020; Part VI of the Act deals with amendments to the Finance Act, 2016 (‘FA 2016’), in relation to equalisation levy (‘EL’).


Taking a cue from the G20/OECD BEPS Action 1 which deals with the digital economy, equalisation levy was introduced for the first time in India in 2016 through the FA 2016. Per the FA 2016, EL of 6 percent is currently applicable on revenue from online advertisements and related activities earned by non-resident companies. The scope of EL is now expanded from 1 April 2020 to cover e-commerce supply and services by non-resident e-commerce operators companies, which attracts EL of 2 percent.

Please join us for the webcast along with government representatives, to help address your concerns or queries on the matter.

Speakers for the session

  • Kamlesh Varshney, Joint Secretary, TPL-1, Ministry of Finance, Government of India
  • Shefali Goradia, Direct Tax, Partner, Deloitte India
  • Ashutosh Dikshit, Tax Policy, Partner, Deloitte India

India Finance Bill Amendments and reliefs announced to combat COVID-19 | 27 March

Host: Shefali Goradia
Presenters: Vijay Dhingra and C.A. Gupta

The India Finance Bill, 2020 that was presented in the Parliament has been passed with some very important changes. In addition, in view of the disruption caused on account of the COVID-19, the Indian Finance Minister on 24 March 2020, announced a number of tax measures to provide relief to tax payers, for example, the extension of various due dates including under the Direct Tax Vivad se Vishwas Act, 2020. We'll discuss:

  • Major changes proposed in the Finance Bill, 2020.
  • Equalization levy on certain digital transactions.
  • Tax reliefs proposed as a part of the various measures to combat COVID-19 including the implications under the Direct Tax Vivad se Vishwas Act, 2020.

Join our Deloitte specialists to learn more about the important updates on the India Finance Bill and prepare for what's next.

Tune in to the recording here.

The Direct Tax Vivad se Vishwas Bill 2020: Decoding the rules | 18 March

“The Direct Tax Vivad se Vishwas Bill, 2020” (“the scheme”) is likely to receive the President’s assent today.

Under the scheme, a taxpayer can settle a litigation pending before any forum, as on 31 January 2020, by paying the tax on the disputed income and get a full waiver of interest and/or penalty.

The government has issued answers to Frequently Asked Questions and is expected to announce the rules today.

Please join us for the webcast along with the government representatives to address doubts on the matter.

Speakers for the session

  • S K Gupta, Principal Chief Commissioner of Income Tax, Mumbai
  • Geetha Ravichandran, Chief Commissioner of Income-tax (International taxation), West Zone
  • Deloitte India Subject Matter Experts

India tax litigation settlement scheme: The Direct Tax Vivad se Vishwas Bill, 2020 | 11 March

Encouraged by the success of the Indirect tax dispute resolution scheme, the Finance Minister tabled "The Direct Tax Vivad se Vishwas Bill, 2020" (the scheme) in the parliament on 5 February 2020. The key objective of the scheme is to collect taxes and reduce the number of litigation cases pending before various appellate forums. Under the scheme, a taxpayer can settle a litigation pending before any forum on 31 January 2020 by paying the tax on the disputed income, and get a full waiver of interest and/or penalty. After the introduction of the bill, various stakeholders made several representations to make the scheme more attractive and practical. The amended Bill was passed by the lower house of the Parliament on 4 March 2020. Further, the government has also issued FAQs to clarify the provisions of the Bill and some practical aspects. We discussed:

  • An overview of the scheme.
  • Procedural aspects of the scheme.
  • Critical business considerations to be evaluated before opting for the scheme.
  • Q&A with PCIT.


Tune in to the recording here.

G20/OECD The digitalized economy and beyond - outline architecture for an international framework | 3 March

The G20/OECD Inclusive Framework continues to develop the technical aspects of proposals, including the allocation of taxing rights between countries (Pillar One). All businesses, not just those that are highly digitalized, will need to understand how the proposals could affect them. Countries are working towards reaching a consensus-based solution by 2020. What might these changes mean for your organization? We'll discuss the January 2020 Statement on the outline of the architecture for an international framework, including:

  • Scope and threshold
  • Nexus rules
  • Profit allocation rules
  • Next steps

Tune in to the recording here.

Vivad se Vishwas scheme | 11 February

Considering the current pendency of over 4,80,000 cases at various Direct Tax Appellate Forums, the Finance Minister tabled ‘The Direct Tax—Vivad se Vishwas Bill 2020’ before the Parliament on 5 February 2020. This is indeed a welcome step to reduce the burden of pending litigation in India. Taxpayers may preferably analyse their appeals and decide whether they wish to avail the scheme.

We have organised a panel discussion through a webcast on ‘Vivad se Vishwas scheme’. This session will throw light on the critical nuances of the scheme and also discuss some issues which need further clarification from the government.

Our subject matter experts for the session are:

  • Ashutosh Dikshit
  • Karishma Phatarphekar
  • Vishal Kalra

FDI policy changes: The way forward | 28 January 2020

Governments across the globe have begun to take cognizance of the benefits that FDI brings in; boost of economy, human resource development, surge in exports, and supply chain improvement, to name a few. Today, India thrives to ride the wave of development alongside its peers and establish itself as an advantageous ally for collaborations synonymous to growth.

There is much optimism around the recent FDI policy changes announced by the Union Cabinet of India, as it is expected to attract FDI investments in the Manufacturing and Retail sector.With the potential upside, it is also important to have a clear understanding of the complex tax implications that the changes and the resulting investments can entail.

Are you up to speed on the recent changes announced by the government?

Have you assessed how this may impact your business now or in the near future?

Have you taken a 360-degree view on the potential implications?

We are delighted to invite you to a webinar that will help you address these questions and take a deeper look at the matters that matter – to you and your organisation.

Agenda

  • Introduction (5 minutes)
  • Guest speaker (30 minutes)
    – Invest India
    – Industry Speaker
  • Insights session (20 minutes)
    – Nuances in FDI Policy
    – Typical business models being used by global retailers 
  • Q&A session (5 minutes)

We look forward to your participation in the webinar.

Transfer pricing and GST implications for brand equity payments | 21 January 2020

Brand equity is a significant business driver, created over a period based on consumers perception and trust in the standard and quality of the products or services. Multinational enterprises (MNEs) leverage on the established brand equity, trademarks, and other marketing intangibles to maintain its competitiveness in the market. Group affiliates to reap the benefits of the competitive advantage make payment for brand royalty to the MNE headquarters. OECD transfer pricing guidelines 2017 recognises the importance of marketing intangibles and allows arm's length payment for the use of intangible if it results in generating profits for the business. Questions have also been raised by the tax authorities' in many MNE headquarters' tax jurisdiction on non-charging or under-charging for the brand from their group affiliates. We'll discuss:

  • The emerging tax controversy areas encompassing both transfer pricing and indirect taxation.
  • The relevant OECD transfer guidance on marketing intangible, prevailing business models for brand royalty payments, and emerging transfer pricing and GST tax controversies.
  • Key considerations and take-away.

Join us to understand the challenges and implications of brand equity payments and explore actions your business can take to prepare.

Tune in to the recording here.

E-invoicing and new GST returns | 14 January 2020

The Government has announced 1 April 2020 as the date of implementation of the e-invoicing system and new returns.

Over the past few months, we have seen concept papers, presentations, FAQs, and schemas being released by the GSTN clarifying several aspects of the proposed mechanism. In fact, the APIs for e-invoices have been released on 7 January 2020 in the sandbox and we at Deloitte have worked towards creating a modular yet comprehensive, on-demand solution to meet the e-invoices requirements along with changes in the GST compliance process through new returns.

Though, initially, the e-invoicing scheme aims to cover large business houses with a turnover of more than 100 Crores for their B2B supplies, the umbrella is set to be broadened over a period of time.

With the above background and to help you navigate through this paradigm shift, Deloitte invites you to join the e-invoicing webcast scheduled on 14 January 2020.

The session will cover an update on e-invoicing topics such as the following:

  • Understand the nitty-gritty of the proposed e-invoicing system and new returns including list of interfaces and the proposed methodology of interface with the Invoice Registration Portal (‘IRP’), and carry out compliances through new returns
  • Walk-through of the latest key clarifications, updates provided by the Government
  • Demo of Deloitte’s solution
  • Q&A

Our Subject Matter Experts for the session are:  

  • Mahesh Jaising
  • Jaskiran Bhatia
  • Atul Gupta
     
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