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Dbriefs Asia Pacific webcasts library
Explore archived webcasts
Webcasts archived in the last 6 months can be accessed on this page.
For a complete program schedule and topic information on upcoming webcasts, select the Program Guide.
您可以在本网页登入过去6个月内举办的网络讲座。如欲获取快将举行的网络讲座的详细时间表及讲题信息，请点选网页右栏的网络讲座指南。
過去6カ月間に配信されたWebcastのアーカイブはこのページに掲載されています。今後配信予定のWebcastについては、右の欄にあるプログラムガイドをご覧ください。
International Tax
BEPS: Discussion Draft on Action 1 (Digital Economy)
4 April 2014
* Length of webcast: 75 minutes
Host: Steve Towers
Presenters: Leonard Khaw, Richard Mackender, Ben Pickford, and David Watkins
On 24 March 2014, the OECD issued, for public comment, its long-awaited discussion draft on BEPS Action 1 ("address the tax challenges of the digital economy"). What does the document say and how might it impact your organization? We'll discuss:
- The OECD's view that other actions within the BEPS project will significantly restrict BEPS tax planning in regard to the digital economy.
- The OECD's list of possible options to fully address the tax challenges of the digital economy.
- Modifications to the PE definition, to restrict the exceptions in Article 5(4).
- New nexus based on the notion of "significant digital presence".
- A "virtual fixed place of business PE", a "virtual agency PE", and a "virtual on-site business presence PE".
- Withholding tax on digital transactions.
- VAT options, in regard to: (i) exemptions for imports of low valued goods, and (ii) remote digital supplies to consumers.
- Reading between the lines: what the discussion draft tells us about the "behind the scenes" conflict within the BEPS project.
Keep up to date with significant changes in international taxation under the BEPS project.
International Tax
BEPS: Discussion Drafts on Action 2 (Hybrid Mismatch Arrangements)
2 April 2014
* Length of webcast: 80 minutes
Host: Steve Towers
Presenters: Mark Brandon, Peter Madden, and Jun Takahara
On 19 March 2014, the OECD issued, for public comment, two related discussion drafts as part of Action 2 (hybrid mismatch arrangements) of the BEPS project. One discussion draft deals with recommendations for domestic law changes, whilst the other discussion draft covers treaty issues. What are the proposals and how might they affect your organization? We'll discuss the OECD's recommendations in regard to:
- Hybrid financial instruments (such as deferred payment structures) and hybrid transfers (such as repos).
- Hybrid entity payments, such as payments by disregarded entities under the U.S. "check the box" rules and by permanent establishments.
- Imported mismatches and reverse hybrids, where the effect of the bilateral hybrid structure is effectively "imported" into a third country.
- Ordering rules in regard to which country should have the primary responsibility for the relevant law change.
- Proposed amendments to the OECD model treaty in regard to hybrid transactions and entities.
Keep up to date with significant changes in international taxation under the BEPS project.
International Tax
BEPS: Discussion Draft on Action 6 (Prevent Treaty Abuse)
28 March 2014
* Length of webcast: 75 minutes
Host: Steve Towers
Presenters: Claudio Cimetta, Alyson Rodi, and Rohinton Sidhwa
On 14 March 2014, the OECD issued, for public comment, a discussion draft called: "Preventing the granting of treaty benefits in inappropriate circumstances". The discussion draft is part of Action 6 ("prevent treaty abuse") of the BEPS project. What are the proposals and how might these affect your organization? We'll discuss:
- Proposed U.S.- style "limitation-on-benefits" and "savings clause" provisions, and a UK-style "main purpose" rule.
- A proposal to exclude from treaty benefits income derived via third country permanent establishments.
- A proposal to change the corporate residence tie-breaker test in Article 4(3).
- Proposed clarification that tax treaties are not intended to be used to generate double non-taxation.
- Inclusion of new treaty provisions into existing double tax treaties via a multilateral instrument (BEPS Action 15).
Keep up to date with significant changes in international taxation under the BEPS project.
Indirect Tax
Malaysian GST: Turning Promises into Hard Realities by April 2015
27 March 2014
Host: Robert Tsang
Presenter: Kah Seong Fan
In its October 2013 budget, the Malaysian government announced a new goods and services tax (GST) with an implementation date of April 2015. Since then, many revisions have been made to the law, along with industry and sector specific implementation guidance. What should multinationals know about the new law and guidance? We'll discuss:
- Insights into the government's new online registration portal, including the latest on industry guides (particularly in the banking and consumer business sectors).
- The latest updates on special schemes and industry-focused rules – for example, how will the requirements of the Approved Trader Scheme work in practice?
- Important issues businesses should begin to prepare for now – what pitfalls are there lurking in systems work undertaken by businesses for the new GST? What are the ramifications for businesses of the anti-profiteering rules and GST – where is the burden of proof and what level of evidence is required?
Hear the latest details on Malaysia's new GST program and how you should be preparing for implementation in 2015.
International Tax
"Permanent Establishment" Definition: Current "Frictions" in Interpretation
25 March 2014
Host: Steve Towers
Presenters: Claudio Cimetta, Leonard Khaw, and Julie Zhang
The "permanent establishment" (PE) definition in double tax treaties continues to be subject to changing, and conflicting, interpretations, quite apart from any redrafting of the definition under the OECD's BEPS Project. What are the current areas of "friction" in the interpretation of this important determinant of source country entitlement to tax business profits? We'll discuss:
- The "at the disposal" condition in Article 5(1) and its application in toll manufacturing, logistics, visiting employees, and other situations.
- The "furnishing of services" PE in Article 5(3)(b) of the UN model treaty.
- The "binding" condition in Article 5(5).
- The circumstances, if any, in which a non-contract-concluding dependent agent can cause a PE for its principal.
Understand the current "friction" areas in the interpretation of the PE definition in double tax treaties.
Industries – Financial Services
Cash Pooling among Banks and Corporate Clients: The Tide is Rising?
20 March 2014
Host: Michael Velten
Presenters: Leon Cane, Ian Clarke, Frederic Bertholon-Lampiris, and Natalie Yu
Across Asia, banks and their corporate clients are increasingly focused on cash and liquidity management, as well as financial supply chain solutions. Why is cash pooling such a focus now and what are important considerations for your organization? We'll discuss:
- Factors driving the development of cash pooling in Asia, including bank and corporate perspectives and the prevalence of cash pooling in Asia.
- Recent Asia Pacific regulatory changes impacting cash pooling, including developments in China that are expected to prompt further development of cash management products in China.
- Transfer pricing issues and considerations, including allocation of the interest savings from cash pooling.
Gain insights into this developing trend and what it could mean for your organization.
Industries – Financial Services
Financial Services Update: Developments in the China (Shanghai) Pilot Free Trade Zone
18 March 2014
Host: Steve Towers
Presenters: Patrick Cheung, Hal Davis, Johnny Foun, and Jeff Tao
Potential internationalization of the RMB, introduction of market interest rates, and facilitation of cross-border trade and investment flows are a few of the sweeping financial markets reforms possible with establishment of the China (Shanghai) Pilot Free Trade Zone (the Zone) in September 2013. What could these and other development mean for financial services providers? We'll discuss:
- Current status of market reforms in the Zone and steps Chinese and foreign businesses are taking to benefit from them.
- What financial institutions are doing in the Zone, including liquidity management, risk trading and cross-border investment flows.
- Tax considerations for Zone participants and potential entrants, including transfer pricing and transaction tax management.
Understand the financial services implications of developments in this important Chinese experiment with market reforms and related tax considerations.
Transfer Pricing
Pricing Intercompany Financial Transactions: Controversies on the Rise
13 March 2014
Host: Shanto Ghosh
Presenters: Ian Clarke and Geoff Gill
Transfer pricing issues surrounding pricing of intercompany debt and guarantees remain at the forefront of discussions and controversies across Asia Pacific. What are the latest developments multinationals should consider? We'll discuss:
- Issues related to the arm's length pricing of intercompany debt and financial guarantees, including the classification of loan arrangements, implementing practical intragroup financing policies, and anticipating potential guarantee pricing issues.
- Passive association and the latest OECD thinking on group synergies.
- Debt quantum, terms, and other commerciality considerations.
- Learnings from recent transfer pricing audits, including approaches to determine credit rating, guarantee recognition (distinguishing financial from non-financial), supporting financial transactions where local comparables are preferred, and establishing core components of comparability for financial transactions.
Gain the latest insights on this contentious area of transfer pricing and recent developments across the region.
India Spotlight
Tax on Services Rendered under Global Arrangements: Perspective and Challenges in India
11 March 2014
Host: Prashant Deshpande
Presenters: Jatin Arora and Debasis Ghosh
Indian tax authorities continue to challenge multinationals that provide services from India under global agreements and claim them as export services, despite a number of decisions upholding the position of export. What recent developments should multinationals consider? We'll discuss:
Types of business models being adopted when performing services in India under global arrangements, including arrangements for soliciting orders for global parent and providing after sales service to customers in India.
- Service tax provisions that have prevailed, including export of service and point of taxation and their implications.
- Judicial precedents and pending litigation in a significant matter.
- Recent experiences when seeking input credit refunds on export claims.
Learn how multinationals might approach planning and documentation to reduce negative business consequences of challenges to global arrangements.
Indirect Tax
Indirect Tax: Update on China's Business Tax and VAT Regime
6 March 2014
Host: Robert Tsang
Presenters: Sarah Chin and Li Qun Gao
The comprehensive VAT reform in China marches on, with an announcement or change nearly every week. What recent news and changes should multinationals be aware of? We'll discuss:
- Whether the China Business Tax is really on its way out and, if so, what it means, particularly in the transition phase to the comprehensive national VAT promised by 2015.
- Requirements of the new VAT regime and multinationals' options for managing compliance and risk, including transition rules from Business Tax and revised national VAT return formats, potentially in simplified form.
- Software and other tools that can help multinationals address new VAT requirements effectively and efficiently – what is out there to help businesses monitor compliance and simplify VAT return obligations in the context of the Golden Tax System?
Learn the latest news about the new national VAT regime.
并购
中国海外投资 并购:中俄投资之兴
2014年3月5日
主持人：朱桉
主讲人：陶然及蒋俊
中俄投资者投资俄罗斯的热潮已然到来。这位能源巨人正张开双臂，欢迎境外投资者参与其经济自由化和开放运动，藉此通过长期投资项目分享所带来的好处。这一变化会带来什么样的机会？投资者的担忧是什么？他们应该采取什么样的投资策略？我们将讨论：
- 开放的俄罗斯市场纵览，包括面向境外投资者的政策红利所带来的各种投资机会、如特别经济区、远东和西伯利亚地区的发展大潮、国企私有化运动，繁荣的基础设施建设以及依靠快速成长的中产阶级的新兴消费市场。
- 详细的行业分析，主要集中在具有过往出众表现和强劲潜力的行业，如能源资源业、制造业和农业。
- 细致的当地投资环境介绍，包括外国投资者风险，政府近期关于提高营商环境所做的努力，以及在跨境并购过程中，中国投资者在税务、会计和产权方面应注意的事项。
- 中俄投资的案例分析。
请参与此网络讲座，了解更多中国投资者投资俄罗斯的活动及重点。
(请收听于2月26日播放的相关英语讲座。详情请访问 Mergers & Acquisitions 网页 。)
International Tax
Centralized Procurement and Shared Services: Emerging Issues and Opportunities
4 March 2014
Host: Tom Ewigleben
Presenters: Rohinton Sidhwa and Paul Zanker
Greater competition, an increasingly complex global business environment, and pressures to squeeze more profits out of the value chain are driving companies to consider shared services and procurement as functions which can drive value creation and operational performance. What are specific operational and tax considerations for setting up and operating procurement companies (Procos) and shared services centers (SSCs)? We'll discuss:
- Proco and SSC models' best practices being adopted in various industries and how they may fit into regional operating models.
- Potential operational benefits of operating under a Proco or SSC model.
- Transfer pricing issues arising around these models in Asia Pacific jurisdictions and supporting deductions for related payments.
- Asia Pacific incentive opportunities for Procos and SSCs.
- Direct tax, indirect tax, and customs considerations of Procos in the region.
- Conversion considerations around the transformation to a Proco or SSC model.
Learn about opportunities and issues associated with centralized procurement and SSCs, and how multinationals are addressing them across the region.
Mergers & Acquisitions
China Outbound Investments
Mergers and Acquisitions: A Sino-Russia Investment Boom
26 February 2014
Host: Andrew Zhu
Presenters: Alexander Krylov and Anna Slobodenyuk
A Sino-Russia investment boom is unfolding as Russia welcomes foreign investors and shares the benefits of economic liberalization. What M&A opportunities, risks, and strategies are likely to emerge? We'll discuss:
- An overview of Russia's opening up and resulting opportunities, including Special Economic Zones, Far East and Siberia regional development wave, state-owned enterprise privatization campaign, infrastructure boom, and a bourgeoning middle-class consumer market.
- Hot industries with outstanding investment records and strong M&A potential, including energy and resources, manufacturing, and agriculture.
- A close look at the local investment environment, including potential investment risks and important M&A considerations relating to tax, accounting, and property rights.
- A recent case study of a Chinese company's investment in Russia.
Learn more about this fast-developing opportunity.
(Tune in to the Chinese version of this webcast aired on 5 March. Please visit Chinese language webcasts page for program details.)
Country Focus
Australia's New Part IVA General Anti-Avoidance Rules: Uncertainty Resumes?
25 February 2014
Host: Dwayne Sleep
Presenters: Ray Conwell and James Fabijancic
Years of uncertainty associated with general anti-avoidance provisions under Part IVA of Australian tax law prompted court judgments between 2009 and 2011 that clarified matters. The Australian government responded with amendments to Part IVA in 2012. What has happened in the year since the new rules were enacted? We'll discuss:
- A review of the cases driving the changes and key elements of the new regime.
- Impacts of the new measures on the cases that necessitated change, including the so-called "do nothing" argument.
- Consideration of particular areas of uncertainty, including the new definition of "tax benefit".
- Guidance for taxpayers on dealing with the new rules.
Gain valuable insights on the regime that will be critical to taxpayers in their Australian dealings.
International Tax
International Tax: What Can We Learn from the Top Tax Cases of 2013?
20 February 2014
* Length of webcast: 80 minutes
Host: Steve Towers
Presenters: Leonard Khaw, Neil Pereira, and Sunil Shah
Fascinating court decisions have emerged in 2013 involving the interpretation of double tax treaties and other international tax issues. What do these cases reveal? We'll discuss:
- Permanent establishment cases in India and Korea, as well as Indian cases involving the application of the royalties definition to telecommunications and other transactions.
- A "mutual assistance" case in the UK, and cases on Article 15 (dependent personal services) in Austria and Finland.
- Anti-avoidance cases in Australia, India, and Singapore, and a case from the Philippines on failure to comply with domestic law administrative requirements to claim treaty benefits.
- Cases on partnerships and treaty benefits in Australia and India, and a case on "place of effective management and control" in Switzerland.
- A time and bareboat charter case from India.
Understand technical and practical implications of key rulings and discover how they apply to your company's international tax planning.
International Tax
BEPS: "Country by Country" Reporting to Tax Authorities and Standardized Transfer Pricing Documentation
19 February 2014
Host: Shanto Ghosh
Presenters: Eunice Kuo and Cam Smith
On 30 January 2014, the OECD issued, for public comment, a discussion draft on standardized transfer pricing documentation including the common template for reporting profits, taxes and other information to tax authorities on a "country by country" basis. The discussion draft is part of Action 13 of the BEPS project. What are the proposals and how might these affect your organization? We'll discuss:
- The proposed draft common template for providing information on a global basis.
- Proposals for master file and local file documentation.
- The OECD's questions seeking input from business.
- A framework for adapting systems and processes to deal with "country by country" compliance.
- Consultation, timetable, and next steps.
Keep up to date with significant changes in international taxation under the BEPS project.
M&A Tax
M&A and India: Cross Border Tax Issues
18 February 2014
Host: Vipul Jhaveri
Presenters: Rishiraj Khajanchi and Hemal Mehta
M&A activity is picking up again, especially inbound and outbound investments involving Indian companies. What are the important cross-border tax considerations and how can your company prepare for them? We'll discuss:
- Potential tax consequences of different M&A deal structures and post-merger operating structures, and the possible role of tax credits.
- Potential impact of double tax treaties between various Asian countries.
- Specific tax issues in India and other selected jurisdictions, including withholding taxes, transfer pricing, controlled foreign corporation rules, and general anti-avoidance rules (GAAR).
- Debt-push down techniques.
Explore possible tax issues associated with M&A activity involving Indian companies.
International Tax
Japan's 2014 Tax Reform Proposals and Consumption Tax Hike
13 February 2014
Host: David Bickle
Presenters: Mark Brandon, Frances Somerville, and Jun Takahara
Japan's 2014 tax reform proposals, some already announced and others still expected, are designed to boost Japan's competitiveness and encourage economic growth. What are expected impacts of these changes on companies and individuals? We'll discuss:
- Drivers behind the reforms, including fiscal and stimulus measures intended to reduce the deflationary impact of the recently announced consumption tax rate increase.
- Enhanced tax measures, including measures to encourage investment in production facilities and improvements to certain tax credits.
- Other tax reform proposals, including early abolition of the Special Reconstruction Corporation Tax.
- Planned increases in consumption tax, including transition rules and possible changes to the treatment of cross border supplies.
Gain the latest insights on direct and indirect tax matters affecting companies and individuals in Japan.
Japanese Language Webcast
平成26年度税制改正大綱
2月13日
司会進行： 望月 伸彦
講師：春木 伸治、黒田 孝次
平成25年12月12日に公表されました「平成26年度税制改正大綱」について、改正のポイントをタイムリーに解説します。 また、消費税率引上げに伴う経済対策と成長力強化のための総合的な対策が必要であることから、通常の年度改正から切り離して前倒しで決定された「民間投資活性化等のための税制改正大綱」が平成25年10月1日に政権与党より公表されました。
それぞれの重要な改正点を、法人税を中心に税務の専門家がわかりやすくご説明します。
「平成26年度税制改正大綱」および「民間投資活性化等のための税制改正大綱」の解説
- 法人税
- その他改正点について
China Spotlight
2014 Preview: Rules that will Shape Inbound Investment into China
23 January 2014
Host: Martin Lin
Presenters: Li Qun Gao, Jennifer Zhang, and James Zhao
With the year of the snake departing and the galloping horse arriving, what upcoming rule changes may have material impacts for multinationals investing into China? What lessons can be learned from issues experienced by inbound investors into China during 2013? We'll discuss:
- Common issues in VAT reform implementation and latest VAT rules.
- Transfer pricing developments and year-end cases of interest.
- Continued focus on non-resident taxation – recent rule changes and cases of interest.
- The impact of the China (Shanghai) Pilot Free Trade Zone on multinationals, as well as other expected tax policy changes and their potential effects on businesses.
Explore important developments from the past year and learn which issues to watch for in the new year.
International Assignments
Global Mobility: Talent Strategies and Trends in Asia Pacific
16 January 2014
Host: Russell Bird
Presenters: Weina Ang, Mario Ferraro, and Huan Wang
Increasing opportunities in the emerging economies of Asia are driving businesses to move talent to and recruit talent in the region. What does the talent landscape look like and how are leading companies navigating it? We'll discuss:
- Insights on the talent priorities and strategies of organizations operating across the region.
- The challenges of talent scarcity, recruitment, retention, and HR maturity, and actions multinationals are taking to address them.
- A focus on talent trends in China and Malaysia, including specific immigration challenges of moving people into and out of each country and tax implications for employers and employees.
Explore the talent issues multinationals face in China, Malaysia, and across the region, and learn about the ways they are turning challenges into opportunities.
Industries – Financial Services
Financial Services Tax Update: GATCA - Globalization of FATCA and Multilateral Exchange of Tax Information
19 December 2013
Host: Jim Calvin
Presenters: Denise Hintzke and Alison Noble
The OECD is developing a framework for multilateral automatic exchange of tax information based on the Model 1 Intergovernmental Agreements (IGAs) for the U.S. Foreign Account Tax Compliance Act. This global Automatic Exchange of Information (AEoI) is sometimes referred to as global FATCA or "GATCA". Delivery of this framework is on an ambitious timetable, with the requirements to be finalized in early 2014 and exchange of information scheduled to commence by the end of 2015 among G20 members. We'll discuss:
- What are the main requirements of GATCA?
- What are the significant differences between FATCA and GATCA, particularly for exemptions and concessions?
- What are the key issues and concerns raised by financial institutions and advisers to date?
- What might financial institutions in Asia Pacific consider doing now to prepare for GATCA?
Understand how your financial institution will be affected by GATCA and consider the impact of GATCA on current FATCA implementation programs.
International Tax
Base Erosion and Profit Shifting (BEPS): What's Happened So Far? And What's Next?
18 December 2013
* Length of webcast: 80 minutes
Host: Steve Towers
Presenters: Anis Chakravarty, Leonard Khaw, Peter Madden, and David Watkins
The BEPS Project is the most important review of the world's international tax architecture in decades. Since its official launch by the OECD and G20 in July 2013, what have been the key developments, both globally and in Asia Pacific? And what's next? We'll discuss:
- Work currently being undertaken by the OECD, including country-by-country reporting, the transfer pricing aspects of intangibles, and the "permanent establishment" definition.
- Areas of potential "friction" amongst OECD / G20 countries.
- "BEPS scorecard" for Asia Pacific countries: current legislative position, perspectives of governments and the public, and unilateral BEPS actions.
- The (expected) way forward.
Find out the current position on this very important international tax initiative.
International Tax
Inbound Investment into Indonesia: Current Tax Issues and Challenges
17 December 2013
* Length of webcast: 75 minutes
Host: Steve Towers
Presenters: Roy David Kiantiong, John Lauwrenz, and Nazly Siregar
In recent years, Indonesia has been the recipient of significant amounts of foreign investment. What are current Indonesian tax issues and challenges facing such inbound investment? We'll discuss:
- Tax treatment of base erosion payments, such as interest, royalties, and service fees.
- Tax loss utilization, including time limitations and preserving tax losses that might expire.
- Tax treatment of corporate restructuring transactions.
- Recent tax audit experience.
Learn about current tax issues and challenges facing inbound investment into Indonesia and how multinationals are addressing them.
Indirect Tax
Indirect Tax Disputes and Litigation: Containing Fire or Playing with Fire?
12 December 2013
Host: Robert Tsang
Presenters: Debasis Ghosh and Turmanto
As tax authorities across the Asia Pacific region increase their scrutiny of multinational companies' compliance with indirect tax laws, more disputes and litigation are arising. What options do multinationals have for calming the fires? We'll discuss:
- A review of recent indirect tax disputes and litigation in various Asia Pacific countries with focus on Australia, China, India, and Singapore.
- The spread of mediation and tribunal processes from the UK and Europe to the Americas and most recently across Asia Pacific in jurisdictions like India and Malaysia.
- Comparing and contrasting the ways businesses manage indirect tax disputes and litigation – effective practices and lessons learned.
Explore the growing risks associated with indirect tax disputes and litigation, and learn how leading companies are effectively managing them.
Industries – Energy & Resources
Asia Pacific Power Utilities Update
10 December 2013
Host: Chris Roberge
Presenters: Brett Greig and Jonathan Hill
Australia's recent shift in energy policy and related taxes certainly has implications for multinationals operating in that country. But could changes there trigger new taxation efforts elsewhere across the region, too? We'll discuss:
- An overview of Australian tax issues relating to the energy and resources industry, including traditional power and utilities and modern renewables.
- How these issues may be relevant to foreign investors as compared to local investors, and possible competitive implications for bid modeling.
- Possible effects of Australia's actions on broader energy related policies across the Asia Pacific region, including carbon taxes and mining and petroleum taxes.
Explore the changing tax landscape for energy and resources companies in Australia and across the Asia Pacific region.
온라인 세미나
한국, 중국 및 인도 등 아시아 지역의 이전가격 세제의 최근 동향과 시사점
2013년12월5일
진행자: 김 영필
발표자: 김 태형, 정 병윤
다수 한국의 기업들이 이미 세계 각국에 제조, 판매 법인 등을 가지고 있고, 특히 인도, 중국을 포함한 아시아 지역은 한국기업의 사업에 있어서 중요한 기능을 수행하고 있습니다. 각국의 과세당국이 자국의 과세권 확보를 위하여 이전가격 관련 규정을 강화하고 있으며, 이는 한국기업들이 사업을 수행함에 있어 위험 요소가 되고 있습니다. 딜로이트 안진회계법인에서는 한국, 인도, 중국을 포함한 아시아 지역의 이전가격 세제의 최근 동향 및 시사점을 주제로 온라인 세미나를 개최할 예정이며 아래와 같은 주제가 포함 될 것입니다.
- 최근 OECD 이전가격세제관련 규정의 동향
- 한국 이전가격세제의 주요 이슈 사항
- 인도, 중국 및 기타 국가의 동향 및 시사점
Indirect Tax
OECD International Guidelines for VAT / GST: What's Next and How Should You Respond?
3 December 2013
Host: Robert Tsang
Presenter: David Raistrick
After releasing VAT / GST International Guidelines for comment in February 2013, the OECD recently hinted at how public input might shape ongoing guideline development. What should you know? We'll discuss:
- How the OECD guidelines are changing and evolving, and what can be learned from the recent IRAS / OECD Conference in Singapore.
- How multinationals can use the OECD guidelines to address operational issues and adjust their approach to indirect tax planning, compliance, and audits.
- Expansion of the guidelines to establishment rules and principal vs. agent for indirect tax purposes.
Explore the latest developments in this important area of indirect taxation and how your organization might need to respond.
M&A Tax
M&A in Asia: Vendor Due Diligence and Related Financial & Tax Matters
28 November 2013
Host: Danny Po
Presenters: Nick Cham, Muhunthan Kanagaratnam, and Edward Lavish
With constant changes in the economy, more foreign multinationals operating in Asia are reorganizing or disposing of their operations. What are some of the options available to such companies to achieve a smooth and positive result? We'll discuss:
- An overview of vendor due diligence and possible areas of value that such a process can create, including optimization of purchase price and less disruption to operating activities.
- Appropriate circumstances under which companies should consider vendor due diligence, including sales auctions and carve-outs.
- Other sales considerations similar to vendor due diligence
- Potential tax issues of interest to a vendor, such as pre-sale restructuring, possible use of a tax-free reorganization and tax implications of a direct or indirect transfer.
Understand different aspects of vendor due diligence and explore related tax structuring issues that may arise during a reorganization or disposition.
International Assignments
Get Set for the End of the Year: A Technical Update for Individuals and Employers in the Region
27 November 2013
Host: Tony Jasper
Presenters: Grace Cheong, Deepika Mathur, and Frances Somerville
As end of the year approaches, individuals and businesses across the Asia Pacific region are gearing up to fulfill their various year-end tax compliance obligations. What latest technical and regulatory developments in the region could impact your preparations? We'll discuss:
- The growing trend of tax authorities to require some level of asset reporting from individual taxpayers, including Japan's new foreign asset reporting requirement which will require many individual tax residents in Japan to disclose their foreign assets for the first time.
- A tax technical and regulatory update spotlighting Singapore, India, and Japan.
- Changes to immigration procedures in the region.
Prepare for the year end now with a look at technical and regulatory changes and trends across the region.
India Spotlight
Indian Tax Adjustments: The Intragroup Share Issuance Controversy
26 November 2013
Host: Neeru Ahuja
Presenters: Anis Chakravarty and Rohinton Sidhwa
In a recent high profile case involving a well-known multinational corporation, the Indian tax authorities have held that the Indian subsidiary had undervalued its shares while raising funds from its global parent. The tax authorities have proposed both primary and secondary tax and transfer pricing adjustments for the alleged under-pricing of intragroup shares issued. What could this mean? We'll discuss:
- Basics of the case, including India's rationale for the proposed adjustments – challenging the valuation methodology and claiming that the valuation difference created a deemed loan to an associated enterprise.
- Is an under-valuation of shares, a capital adjustment accruing to the share premium account and, therefore, not to be considered as income foregone?
- Implications of secondary adjustments proposed for the deemed loan, and global precedents for such secondary adjustments.
Learn how India may be trying to expand the tax and transfer pricing umbrella to include cross-border capital transactions and ways companies may need to respond.
India Spotlight
India's Outbound Workforce and Cross-Border Employment: Got Growth Pains?
21 November 2013
Host: Divya Baweja
Presenters: Homi Mistry and Poorva Prakash
As Indian companies grow more global in scope and make more overseas investments, they encounter a growing number of issues associated with cross-border employment of their outbound mobile workforces. How are leading companies addressing these issues? We'll discuss:
- The shift in the Indian outbound workforce paradigm and resulting employer and employee HR, tax, and social security issues.
- Regulatory compliance challenges faced by Indian multinationals, including immigration restrictions.
- Ways that companies can address these challenges, including planning and control strategies.
- Future considerations, including modified assignment packages and cost-reduction strategies.
Learn about the challenges Indian multinationals face with multifaceted tax laws, social security, and exchange regulations and the increasing focus of the authorities on compliance.
Mergers & Acquisitions
China Outbound Investment
An Expanded Footprint in Poland: A Spotlight on Chinese Investment Trends
20 November 2013
Host: Ronald Chao
Presenters: Joanna Dudek and Robert Pasternak
The influx of Chinese investments into Poland has grown substantially in recent years. What is the attraction of this market and what market entry strategies are various players using? We'll discuss:
- An overview of Chinese banks and other investors targeting Poland and examples of their business ventures there, including acquisition of machinery and bearing manufacturers.
- Preferred business legal structures selected by Chinese investors for various industries, including joint venture, branch office and private limited company in transport, manufacturing, banking and trading industries.
- A case study of successful Chinese investment through private and public acquisitions in manufacturing industry and the difference between both deals.
Learn how Chinese investors benefit from their presence in Poland and use that country as a gateway to Europe.
Transfer Pricing
Location Specific Advantages in Asia Pacific: Evidence from Local Markets
14 November 2013
Host: Shanto Ghosh
Presenters: Vishweshwar Mudigonda, Jacques Van Rhyn, and Betty Zhu
Location Specific Advantages (LSAs) continue to dominate the transfer pricing discourse in India and China. How has the recent OECD Revised Discussion Draft on Intangibles added to the debate, and are LSAs likely to assume relevance in other Asia Pacific countries? We'll discuss:
- Importance of geographic market factors that may lead to LSAs, including location savings, market premiums, and group synergies.
- Existing evidence indicating the relevance of LSAs in certain industries, such as automotive, electronics, and services, and geographic markets.
- Recent developments on the interpretation and quantification of LSAs in transfer pricing.
- Adapting transfer pricing analysis and documentation to address the inherent complexity of LSAs.
Gain new insights on LSAs and how your organization can prepare for potential tax authority scrutiny.
Tax Management
Indirect Tax Technology: Time for an Upgrade?
12 November 2013
Host: Richard Mackender
Presenters: Jan De Clercq and Rony Wuytjens
The tax-related capabilities of ERP systems, as well as tax-specific planning and compliance software, have become much more sophisticated in recent years. In addition to analytics, what other tax technology could your organization benefit from? We'll discuss:
- Various types of tax technology tools available today, including some embedded in ERP systems and other standalone tax management systems.
- The importance of the business case and how to build and articulate it to stakeholders and decision takers.
- Particular tax technology tools that companies find useful in Asia Pacific tax planning and compliance activities, including native ERP systems or Tax Engines such as SAP TradeTM, Oracle GTMTM, One SourceTM, and VertexTM.
- Implementation challenges and opportunities – lessons learned from early adopters of these technologies.
Explore recent developments in tax technology and opportunities for your organization to upgrade.
Japanese language webcasts
海外派遣者に係る最近の税務事情
～増加する海外派遣者に対する日本と海外諸国における税務トピック～
2013年11月7日
司会進行：川井 久美子
講師：杉本 浩二、高尾 圭輔、久宝 容平
今日、多くの日本の企業が海外進出を果たしており、日本から海外拠点へ人員が派遣されることも多く見られるようになりました。その派遣形態は、出張・出向・転籍など多様化しており、それぞれの形態によって個人所得税への影響が異なる可能性があり、派遣先国のみでなく、派遣元国である日本における税務についても考慮すべき点は多く、注意が必要となります。
また、海外派遣者を受け入れている海外諸国においては、グローバル経済の発展と派遣者の増加に伴い税制度や入国管理制度等、外国人労働者の管理に対する法整備が進められている傾向があります。
今回は、海外派遣者に関連する一般的な日本および派遣先国における税務上の問題点や注意点について、所得税務を中心に解説を行います。また、日本企業の進出が多い台湾とインドネシアにおける赴任者、出張者の留意事項についても併せて解説します。
- 海外派遣者に対する日本における所得税務一般
- 海外派遣者、出張者に係る費用負担（較差補填）の税務への影響
- 台湾における個人所得税務の留意点（PE認定、短期滞在者の特典の有無）
- インドネシアにおける個人所得税務の留意点（PE認定、人件費の損金算入） 等
International Tax
China's Double Tax Treaties: Under the Microscope
6 November 2013
* Length of webcast: 70-75 minutes
Host: Steve Towers
Presenters: Vicky Wang, Hong Ye, and Julie Zhang
China's double tax treaties have significant implications for inbound investment into the country. Which treaty is best in class for particular types of income, and what potential issues could you encounter using them? We'll discuss:
- Permanent establishment definitions.
- Withholding tax rates on dividends, interest and royalties, and capital gains exemptions.
- What to do with "residual income" – business profits article, "other income" article, or fall outside of the treaty?
- Unusual provisions in China's treaties.
- Domestic law and administrative aspects of treaty claims in China.
Compare and contrast China's double tax treaties and learn how to identify and use relatively superior treaties for inbound investment into China.
India Spotlight
India's Newly Released Safe Harbor Rules: A Barrier or a New Path Forward?
29 October, 2:00 PM – 3:00 PM HKT (GMT +8)
Host: Samir Gandhi
Presenters: Tarun Arora and Vishweshwar Mudigonda
Gain the latest intelligence on India's safe harbor rules and the likely impact of these rules on your transfer pricing compliance, potential audits, and existing and future APAs.
China Spotlight
China (Shanghai) Pilot Free Trade Zone: A New Model for Doing Business in China?
24 October 2013
Host: Leonard Khaw
Presenters: Vivian Jiang and Clare Lu (Partner, Qin Li Law Firm)
Gain the latest insights on the China (Shanghai) Pilot Free Trade Zone and potentially momentous economic reforms.
(Tune in to the Putonghua version of this webcast aired on 24 October. Please visit Chinese language webcasts page for program details.)
International Tax
Transfer Pricing and Business Model Optimization: Building and Operating a Sustainable Business Model
22 October 2013
Host: Tom Ewigleben
Presenters: Anis Chakravarty, Eunice Kuo, and Tim O'Brien
Gain new insights on transfer pricing issues that may arise with centralized management structures, and how companies are addressing them across the Asia Pacific region.