Dbriefs Take the lead

Transcription

1 Dbriefs Take the lead Program Guide Asia Pacific Webcast series July September 2016

2 Industries Financial Services Common reporting standard (CRS) in Asia Pacific: Developments and next steps > 14 July, 2:00 3:00 PM HKT (GMT +8) Host: Michael Velten Presenters: Candy Chan, Nalee Kang, Brian Mayer, and Alison Noble CRS commencement is just over a year away for the Wave 2 countries in Asia Pacific. In a number of jurisdictions, local regulation and guidance is pending which is a crucial input to any project plan. In others, language can be a constraint to a detailed understanding of the local environment. At the same time, there is a need to develop new processes and procedures and prepare customers and staff for a new reporting regime. We'll discuss: Detail of the local regulations in Japan and Korea. Recent developments in Australia, Hong Kong, and Singapore. The 15 options: current scorecard in the Wave 2 locations in Asia. Preparing for CRS with 6 months to go: lessons from the Wave 1 countries. Current project focus in Asia and key challenges. Stay up to date with the latest developments on CRS in these Asia Pacific countries. Developments in VAT financial services rules: Everything is changing > 22 September, 2:00 3:00 PM HKT (GMT +8) Host: Michael Velten Presenters: Sarah Chin, Senthuran Elalingam, and Robert Tsang Indirect tax rules in respect of financial services entities become ever more complex across Asia Pacific. New rules inaugurated in China in May 2016, India's dual GST, and Malaysia's one year old GST, are stirring up waves of changes. Even mature VAT and GST systems like Singapore, continue to refine and adapt rules. What are all these changes and what trends are emerging that you should be aware of? We'll discuss: China's new rules that tax a broad range of financial services, foregoing the approach of exemption adopted in many countries. How is the experience of these new rules shaping up? What will India do when it introduces dual GST in this sector? Malaysian financial institutions grapple with the now one year-old GST as the new tax beds down. What are the impacts so far? What are the rules that the mature VAT and GST systems like Singapore are refining and adapting? Gain insights from Deloitte experts on how major changes in indirect tax rules are impacting financial services firms. International Tax Japan's Authorized OECD Approach (AOA): What does Japan's new AOA rules mean for permanent establishments? > 21 July, 2:00 3:00 PM HKT (GMT +8) Host: Gary Thomas Presenters: Sam Gordon and Mickey Vandre Japan's adoption of the Authorized OECD Approach for attributing income to Permanent Establishments (PEs) into domestic law makes Japan an important first mover in Asia adopting key OECD PE principles into domestic law. The new Japanese rules are applicable for PEs of corporations for years beginning on or after 1 April 2016 and for individuals beginning from the calendar year There are key aspects of the new rules that corporations and individuals are seeking to understand to evaluate and apply the rules in the best manner going forward. We'll discuss: The guidance from the OECD report underpinning the new Japanese rules. The new domestic law and how it interacts with some of Japan's key tax treaties. The mechanics of attributing income (and capital) under the new approach. The specific implications for PEs of foreign financial services firms and professional services firms. Practical considerations for taxpayers. Gain an understanding of the new Japanese rules as well as their impact on tax compliance, risk management, and how one of the region's key countries is adopting key OECD PE principles into domestic law. Expansion of source country corporate income tax jurisdiction: Deemed permanent establishments (PEs), enhanced transfer pricing, and similar unilateral BEPS changes > 23 August, 2:00 3:00 PM HKT (GMT +8) Host: Steve Towers Presenters: Leonard Khaw, Rohinton Sidhwa, Cam Smith, and Manu Sriskantharajah The "source country vs. residence country" jurisdictional debate is not formally part of the BEPS project but it has caused a significant amount of the friction in the project. This has been exacerbated by a number of source countries making unilateral law changes which might be viewed as going beyond the consensus position which was agreed in the BEPS Reports. We will review the major examples of such unilateral law changes: Deemed PEs under The UK's Diverted Profits Tax (DPT) Australia's Multinational Anti-Avoidance Law Expansion of source concepts in regard to digital transactions: Israel and Turkey Equalization levy: India Enhanced transfer pricing "Upfront" taxation on "diverted profits", in support of transfer pricing rules: DPT in the UK and Australia China's draft "value contribution allocation method" Interaction with double tax treaties Gain an understanding of the major examples of BEPS-inspired source country unilateral law changes. 1

3 India Spotlight Using limited liability partnership (LLP) option for tax and regulatory efficiencies > 28 July, 2:00 3:00 PM HKT (GMT +8) Host: Hemal Zobalia Presenters: Promod Batra, Jimit Devani, and Rashmi Maskara The LLP entity was introduced into India in It has gained more prominence over the last two years, with the number of registered LLPs increasing substantially during that period. This unique form of business entity integrates the features of corporations and partnerships, offering cost efficiency and operational flexibility. The Indian government has promoted the use of LLPs by issuing FAQs and guidance, as well as simplifying the process for setting-up an LLP. We'll discuss: An overview of using an LLP for inbound investment into India. How an LLP provides tax cost efficiency a saving of 20% dividend distribution tax and tax structuring options. Cross-border issues. Practical case studies. Understand the technical and practical implications and opportunities from using an LLP for inbound investment into India. Stay informed To implement the BEPS actions, India is likely to amend its domestic tax law as well as tax treaties (either through the multilateral instrument being developed as part of the BEPS project, or bilaterally). Visit or contact your Deloitte contact to learn about the key issues around BEPS as well as the Indian perspective in relation to these issues. Tax impact of Indian Accounting Standards (IndAS) > 1 September, 2:00 3:00 PM HKT (GMT +8) Host: Vijay Dhingra Presenters: Geeta Ramrakhiani, Harsha Rawal, and Krishnamani Subramanian Many Indian companies are required to adopt the new Indian Accounting Standards (IndAS) in a phased manner. IndAS brings in the concept of fair valuation and much more rigour in accounting for a transaction in accordance with its substance, rather than form. This raises the potential for notional income or expenses to be recognised for accounting purposes. But how will IndAS impact the calculation of taxable income for Indian tax purposes? We'll discuss: Which companies are required to adopt IndAS? Income tax treatment of accounting notional items. Permanent vs. timing differences. Impact on minimum alternate tax (MAT) and withholding tax obligations. Gain a better understanding of the new Indian Accounting Standards and how they might impact your Indian tax position. For program information, visit 2

4 Transfer Pricing Value chain analysis: Definitions and methods > 18 August, 2:00 3:00 PM HKT (GMT +8) Host: Fiona Craig Presenters: David Bell, Arindam Mitra, and Alan Shapiro Governments around the world are increasingly demanding that multinationals align transfer pricing outcomes with economic substance. The result has been a greater focus on how the value generated by functions, assets and particularly the assumption of risks is attributed to different tax jurisdictions. We'll discuss: What is value chain analysis and how is it consistent with the arm's length principle. How a value chain analysis using a profit split based on economic drivers aligns with the new BEPS requirements. How a value chain analysis can help you prepare for government inquiries. Learn about these important developments and ways to plan for the new global tax environment. Australia's new diverted profits tax: Are you prepared? > 6 September, 2:00 3:00 PM HKT (GMT +8) Host: Paul Riley Presenters: Claudio Cimetta and Geoff Gill Australia's recently announced diverted profits tax (DPT) is intended to discourage profit shifting to offshore entities that lack economic substance and to provide the Australian Taxation Office (ATO) with significant additional leverage when resolving disputes. The Australian DPT will be modelled on the UK DPT and is likely to be a "game changer", especially in light of how we have seen the ATO operating recently. We'll discuss: The basis for the introduction of the DPT in the Australian political and tax environment. The key features of the proposed DPT regime. Approaches to the issue of economic substance. Practical implications for multinational companies operating in Australia. Find out how these changes will affect your business and their likely practical implications. 3

5 Global Mobility, Talent & Rewards North Asia spotlight: Challenges and opportunities for outbound mobility for companies in the region > 30 August, 2:00 3:00 PM HKT (GMT +8) Host: Homi Mistry Presenters: Russell Bird, Joe Choi, and David Luo North Asia is home to the headquarters of many Asia-founded multinational corporations who are expanding their operations and sales to locations outside of the HQ country, both in Asia and outside the Asia region. What can be learnt from their challenges and experiences when implementing mobility policies to send employees from Asia to the rest of the world? With our speakers from China, Korea, and Japan drawing on the experiences of their outbound clients, we'll discuss: Managing immigration and compliance risks and exposure for outbound assignees. What are the approaches to mobility policies, dealing with tax equalization and similar for outbound assignees from North Asia? What can be done to help Asia-outbound assignees deal with the cultural and different business styles outside of their home countries? What are the regulatory, corporate, and other pitfalls to be avoided? What trends are we seeing in the global mobility functions in the region as more Asia-HQ businesses try to grow beyond Asia? Learn new perspectives on the mobility of employees as we focus on the nuances of moving people from business based in North Asia to the rest of the world. China Spotlight China tax update: Issues, challenges, and opportunities > 8 September, 2:00 3:00 PM HKT (GMT +8) Host: Sarah Chin Presenters: Victor Li and Jennifer Zhang Despite growing at a slower rate than before, China continues to be a key priority for global multinationals. Constantly monitoring and being on top of recent developments in the local tax system is a must. What are the issues, challenges, and opportunities from the recent local developments? We'll discuss: Effective ways to structure and finance investments in China. Implementation of efficient supply chain and repatriation planning, and address traps for the unwary. The trends in the approach taken by China's State Administration of Taxation. Learn about the latest China's tax developments impacting multinationals. Gain insights VAT Reform Things You Need to Know on the tax@hand app and WeChat Find the latest updates and insights on the recent VAT Reform in China at this column, including the latest regulations, thought pieces, FAQs, case studies, etc., to help you understand the potential impacts and strategize accordingly. You may access all archived articles (contents in Chinese only with bilingual subject lines) via the Deloitte tax@hand app (taxathand.com/world-news/china), or follow us on WeChat to receive future issues by scanning the QR code. hand 及微信版 改增 你必知道的 您来中国改增的及与独到洞, 包括最新法 先理念 解答 案例分析等, 助企切了解改增的潜在影响并考量相决策 您可透德勤 tax@hand 移用程序 (taxathand.com/world-news/china) 所有往期内容 ( 各期正文限中文, 中英双 ), 亦可描二关注德勤中国官方微信号, 及跟踪的后内容 For program information, visit 4

6 M&A Tax Tax considerations of pre-deal restructuring: Focus on China, Japan, and India > 27 September, 2:00 3:00 PM HKT (GMT +8) Host: Danny Po Presenters: David Bickle and Hemal Mehta To facilitate a deal completion, certain corporate restructuring exercises, such as business carve-out and debt selldown, would have to be conducted from both the seller's as well as the potential buyer's perspective. Other major stakeholders' interests, including major creditors and senior executives, would also need to be taken care of. There could be significant tax liabilities and risks arising from these pre-deal corporate restructuring exercises. In the previous quarter, we illustrated case studies in Australia, Korea, and Southeast Asia. In this quarter, we will continue the discussion of this topic with a focus on China, Japan, and India. We'll discuss: Local tax law and regulations relevant to corporate restructuring in a deal context. The best practice in managing tax liabilities and risks from both the seller's and the buyer's perspectives. Anti-avoidance rules. Practical case studies and lessons learned. Stay informed about these significant tax considerations and gather insights into how they may affect your decisions in the next transaction. 5

7 Our Presenters Australia David Bell, Claudio Cimetta, Fiona Craig, Geoff Gill, Alison Noble, Paul Riley, Cam Smith, Manu Sriskantharajah China Candy Chan, Sarah Chin, Leonard Khaw, Victor Li, David Luo, Danny Po, Jennifer Zhang India Promod Batra, Jimit Devani, Vijay Dhingra, Rashmi Maskara, Hemal Mehta, Homi Mistry, Geeta Ramrakhiani, Harsha Rawal, Rohinton Sidhwa, Krishnamani Subramanian, Hemal Zobalia Japan David Bickle, Russell Bird, Sam Gordon, Brian Mayer, Arindam Mitra, Alan Shapiro, Gary Thomas, Mickey Vandre Winner INTERNATIONAL TAX REVIEW ASIA TAX AWARDS 2016 Tax Innovator Award Dbriefs Webcasts & Bytes Korea Joe Choi, Nalee Kang Malaysia Senthuran Elalingam Singapore Steve Towers, Robert Tsang, Michael Velten For program information, visit 6

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