Stay tuned in. Program Guide July - September 2014

Transcription

1 Stay tuned in Program Guide July - September 2014

2 China Spotlight Earmarked Investments in Shenzhen Qianhai and Zhuhai Hengqin: What do You Need to Know? > 24 July, 2:00 3:00 PM HKT (GMT +8) Host: Lillian Xiao Presenters: Ellen Tong and Caesar Wong The Qianhai Shenzhen-Hong Kong Modern Service Industry Cooperation Zone (Qianhai) and the Zhuhai Hengqin New Area (Hengqin) are two key economic zones in China. As of May-end 2014, more than 12,000 entities were approved to register. As the two key constituent zones in the pending Guangdong- Hong Kong-Macau Free Trade Zone (FTZ), what are the opportunities available? We'll discuss: The developments within the two zones and how they are strengthening the international competitiveness of China, Hong Kong, and Macau. The business and market opportunities available including Individual Income Tax equalization subsidies for qualified expatriate employees, and the reduced Enterprise Income Tax rate of 15% on qualified income. The differences among Qianhai, Hengqin, and other parts of China. Join us as we discuss how zones such as Qianhai and Hengqin will help to mitigate China tax risks and enhance cost efficiency of non-resident companies. M&A Tax Debt Push Down in Asia Pacific: Techniques and Case Studies > 31 July, 2:00 3:00 PM HKT (GMT +8) Host: Danny Po Presenters: Tom Kwon, Jun Takahara, and Davy Yun It has always been a challenge for investors to obtain tax deductions on financing costs incurred in connection with M&A. Given the rapid development of BEPS in Asia Pacific, the structuring of debt push down will become even tougher. What are the techniques and challenges to overcome in order to push down the interest costs to the operating entities? We'll discuss: Basic debt push down techniques. How to overcome regulatory and tax restrictions such as thin capitalization rules and exchange control measures. Illustrative case studies in China, Hong Kong, Japan, and Korea applying these techniques; considering how to align interest expense with taxable operating income, taking into account cross-border transfer pricing considerations and beneficial ownership requirements. Understand the techniques and challenges on debt push down that might affect your M&A deals. India Spotlight India's Budget 2014: Great Expectations? > Date and time to be confirmed Host and presenters to be confirmed The recent Indian elections have brought in a new government with a strong growth focused agenda. Expectations are riding high as India prepares for a crucial Budget in July At the top of the new government's agenda will be ensuring an amiable business environment for investors both in India and abroad, and reining in inflation. It is expected that the Government will look at reducing regulatory uncertainty and simplifying procedures to enhance the business environment. What about a roll-back on retrospective tax laws? Any anticipated moves to revive the investment climate and any intentions to introduce GST in the near future? We'll discuss: Impact of key budget proposals to the business environment. The larger ramifications from a direct and indirect tax perspective for organizations. Given the new changes, what can organizations do to plan more effectively. Tune in to keep up with the latest changes being considered in India's Budget Know more The Companies Act, 2013 seeks to replace the Companies Act, Securities and Exchange Board of India (SEBI) has amended Equity Listing Agreement w.e.f. 1 October 2014 and expanded the scope of Related Party Transactions. Visit or reach out to your Deloitte contact to learn more. 1

3 Industries Financial Services Operational Taxes in Asia Pacific: Are You Keeping Pace? > 12 August, 4:00 5:00 PM HKT (GMT +8) Host: Carl Church Presenters: Johnny Foun, Michael Velten, and Martin Walker Operational taxes, including technical aspects, governance, compliance considerations, and reviews, are affecting financial institutions based in Asia Pacific. What do you need to know to stay updated on operational taxes and related risk management in the region? We'll discuss: Financial transaction tax (FTT) an update on latest developments. Qualified Foreign Institutional Investors (QFII) / Renminbi Qualified Foreign Institutional Investors (RQFII) / Shanghai-Hong Kong Stock Connect where do we currently stand in relation to capital gains tax and withholding tax on China securities? Philippines Tax Identification Numbers, specifically custodian requirements, options, and solutions. Update on China VAT for the banking industry. Understand the implications of the latest developments and management of operational taxes in Asia Pacific. Industries Energy & Resources Oil & Gas in Myanmar: Issues, Challenges, and Opportunities > 23 September, 2:00 3:00 PM HKT (GMT +8) Host: Chris Roberge Presenters: Aye Cho and Anthony Loh Myanmar has attracted significant interest from foreign investors as it has the 10 th largest gas reserves in the world plus significant oil reserves most of which remains largely unexplored. Moreover, oil and gas has been identified by the Myanmar Government as a focus industry to drive national economic progress. What should you know as an international company interested in delving into this market? We'll discuss: New social and economic reforms that have allowed for more international companies to enter this market. Oil and gas developments. Key tax incentives and regulatory matters such as Production Sharing Contract (PSC) with Myanmar Oil and Gas Enterprise (MOGE) and Foreign Investment Law (FIL) with Myanmar Investment Commission (MIC). Practical tax strategies including appropriate holding company locations to minimize Myanmar tax exposures for investing into this market. Gain insights on the latest oil and gas developments in Myanmar. International Tax Road-testing BEPS Action 6 (Prevent Treaty Abuse): Case Studies > 13 August, 2:00 3:00 PM HKT (GMT +8) Host: Steve Towers Presenters: Claudio Cimetta, Leonard Khaw, and David Watkins BEPS Action 6 (prevent treaty abuse) involves the insertion, into double tax treaties, of a range of anti-abuse provisions. In this webcast, we will analyze a number of case studies which will illustrate the operation of these provisions. Issues covered in the case studies will include: The "limitation on benefits" (LOB) article, including the operation of the "qualified person" definition, the "active trade or business" test, and the "derivative benefits" provision. The "main purpose" provision: scope and evidentiary support. Several of the "specific anti-abuse" provisions, such as exclusion of third country permanent establishments, the "saving clause", and the dual resident "tie-breaker" provision. Learn how these new treaty anti-abuse provisions will likely operate in various practical situations. Inbound Investment into Australia: Do You Have a Complete Picture? > 19 August, 2:00 3:00 PM HKT (GMT +8) Host: Vik Khanna Presenters: Claudio Cimetta and Colin Little Australia is currently experiencing an increase in M&A activity with significant investment flows coming from Asia Pacific. As the world's international tax architecture is evolving, legislative changes are occurring in Australia and the Australian Taxation Office (ATO) is refining its approach to managing risk to the Government. What are the tax risks associated with the investment process into Australia, and how can you proactively manage them? We'll discuss: The main industries into which investments are being made and typical tax issues that arise. Important legislative tax changes, enacted and proposed, as well as recent ATO rulings. Typical inbound investment structures and issues. Tax risks that the ATO is focusing on. Hear about the latest inbound investment climate in Australia, and what might affect your benefits when investing in Australia. For program information, visit 2

4 International Tax Inbound Investment into Japan: The Road Ahead > 11 September, 2:00 3:00 PM HKT (GMT +8) Host: Jun Takahara Presenters: David Bickle, Mark Brandon, and Brian Douglas Japan's ruling party continues to look to tax reform as a way to support its efforts to engineer sustainable economic growth. Pushing on the one hand for tax incentives and a reduction in the headline rate of corporation tax, the government must also decide whether to proceed with its plans for a second hike in the consumption tax rate from 8% to 10% in October But what will the impact of these proposals be for companies and individuals? We'll discuss: The impact of the consumption tax hike in April 2014 and the increase planned for next year. BEPS and the potential impact of Japan's response. Recent tax audit experience and focus in respect to inbound investments. Highlights on what to expect in Japan's 2015 tax reform. Gain valuable insights on the latest Japan tax issues what to expect and how to prepare. International Assignments Global Employment Companies: Old Vehicle, New Driver? > 26 August, 2:00 3:00 PM HKT (GMT +8) Host: Don Riegger Presenters: Rohit Shah and Jill Storey Global Employment Companies (GECs) have been around for a while, but in the past their creation was often a vehicle for global talent management and maintaining equity among assignees. Now the business drivers for setting up a GEC are more focused on the corporate issues associated with a mobile employee population rather than the needs of the employees themselves. We'll discuss: What is a GEC and how are they structured, including any GST / VAT implications. The latest business drivers for implementing GECs. The latest worldwide attention to BEPS impact upon the GEC. The PE issues associated with GECs. Examples of GECs including best practices and service delivery models from specific countries in Asia Pacific Singapore and India. Discover why GECs remain an enduring and attractive structure for handling mobile employees. Private Business Private Wealth Structuring for Individually-Owned Thai Companies > 21 August, 2:00 3:00 PM HKT (GMT +8) Host: Michael Pfaar Presenters: Mark Kuratana and Anthony Loh Recent transactions, such as the battle for a well-known food and beverage company, have shown the skills and resourcefulness of Thai business families. Many individually-owned Thai businesses include the 2 nd or 3 rd generation in leadership positions, demonstrating how developed the intergenerational transfer of wealth has become in Thailand. However, it is still unclear from a Thai tax point of view how companies can efficiently hold assets and businesses, particularly those involving overseas trusts and companies. We'll discuss: Common structures. Respective legal and tax treatments for common structures. Commentary on open issues. Find out how private wealth structures are developing in Thailand. 3

5 Indirect Tax Malaysian GST in April 2015: Final Preparations > 28 August, 2:00 3:00 PM HKT (GMT +8) Host: Robert Tsang Presenters: Bruce Hamilton, Eng Yew Tan, and Poh Geng Wong As the Malaysian Government and businesses get into the final flush of preparations for GST in April next year, it is important to find out about the latest developments in law, regulations, guides, and practice in this fast changing area. What should Malaysian businesses be doing in the 6 month countdown to April 2015? We'll discuss: The latest rules. How industry bodies are getting on with clarification requests of Customs and the Ministry of Finance. Case studies and the latest thinking on GST implementation approaches or methodologies. Find out what Malaysian business should be doing to prepare for the introduction of GST in Malaysia. Managing the Continuous Evolution of China's VAT Reforms: Theory vs. Reality > 30 September, 2:00 3:00 PM HKT (GMT +8) Host: Robert Tsang Presenters: Sarah Chin and Li Qun Gao Since the pilot reform program was introduced in Shanghai on 1 January 2012, the Chinese National VAT Reform has been introducing significant changes to the old VAT and business tax regimes. Taxpayers have witnessed continuous policy changes and implementation challenges. Although the planned completion date of the reform, the end of 2015, is only 18 months ahead, there are many sectors to be covered in the reform. What are the latest changes and what is expected in the next batch of changes? We'll discuss: Announcements for the latest sectors, including the telecommunications industry announcement in early May Developments in the implementation of the reform including the exemption of cross-border services. Practical steps to be taken by businesses, suppliers, and customers to handle the new reality of China's VAT system. Understand the latest changes and developments in China's National VAT reform and how you can address them. Gain insights 2014 Asia Pacific Tax Complexity Survey How are tax policies affecting businesses in Asia Pacific? In this year's report, over 800 business and tax professionals share how they feel about the tax regimes in 20 jurisdictions across the region. Visit and use this survey as a benchmark to help you make business decisions and enhance tax management practices in the region. For program information, visit 4

6 Transfer Pricing Profit Split Analysis and the Role of Intangibles, Capital, and Risk > 18 September, 2:00 3:00 PM HKT (GMT +8) Host: Arindam Mitra Presenters: Jun Sawada and Jacques Van Rhyn The profit split method is receiving renewed attention as tax authorities look to apply this method in innovative ways to challenge existing transfer pricing methodologies. The OECD's BEPS initiative is likely to provide added impetus to this trend, especially in the context of location savings, hard to value intangibles, and transactions that rarely occur between third parties. We'll discuss: The regulatory foundations for the application of this method. The economic foundations of this method including the role of intangibles, capital, and risk. Some recent approaches taken by tax authorities for example, functional profit split. Guarding against formulary or subjective approaches. Explore important details of this rapidly changing area of transfer pricing and recent developments. BEPS Central Korean Language Webcasts High Net Worth Individual과 Family의다국적세무이슈와최근동향 > 9월17일, 2:00 3:00 PM KST (GMT +9) 진행자 : 강나리발표자 : 김희술, 김중래 국제거래및투자의기회가증가하는국제경제환경변화에따라고액자산가및가족의국가간이동이증가하여, 이에따른국제조세와관련된다양한이슈가양산되고있습니다. 특히, 상속 증여세과세강화, 신탁법의전면개정, 금융분야에서는해외금융계좌신고제도강화, FIU 금융정보의과세당국제공증가, 미국과의조세정보자동교환협정체결등으로인한국제조세이슈는더욱심화될전망입니다. 딜로이트안진회계법인에서는 Global Presence 를가지고있는고액자산가및가족들의국제조세의이슈들과동향을주제로온라인세미나를개최할예정이며아래와같은주제가포함될것입니다. 한국의세법과법률개정의주요이슈사항 FATCA 와해외금융자산신고의동향 외국인의한국자산과내국인의해외자산의상속과증여의주요이슈사항 Stay ahead Your one-stop shop Visit BEPS Central at your one-stop shop for information on the BEPS Project. Here you can find all the official documents on the BEPS Project, as well as related Deloitte comments. You can also find information on Dbriefs Webcasts on BEPS. 이브로셔는고액자산가기업오너및패밀리그룹그리고공익법인에게세무회계컨설팅관련통합자문서비스를제공하는 Deloitte Private-Korea 에대한소개입니다. 자세한사항은첨부된연락처에문의해주세요. 5

7 Our Presenters Carl Church, Chris Roberge Australia Claudio Cimetta, Bruce Hamilton, Vik Khanna, Colin Little, Jill Storey, Jacques Van Rhyn, David Watkins China Sarah Chin, Johnny Foun, Li Qun Gao, Leonard Khaw, Danny Po, Ellen Tong, Caesar Wong, Lillian Xiao, Davy Yun Japan David Bickle, Mark Brandon, Brian Douglas, Arindam Mitra, Jun Sawada, Jun Takahara Korea Tom Kwon Malaysia Eng Yew Tan, Poh Geng Wong Myanmar Aye Cho Singapore Michael Pfaar, Don Riegger, Rohit Shah, Steve Towers, Robert Tsang, Michael Velten Thailand Mark Kuratana, Anthony Loh United Kingdom Martin Walker 온라인세미나 Korean Language Webcasts 강나리 (Kang Nalee), 김희술 (Kim Hee Sool), 김중래 (Kim Joong Rae) For program information, visit 6

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