Dbriefs Asia Pacific

Take the lead
Asia Pacific Webcast series
Program Guide
October – December 2016
India Spotlight
Indirect Tax
Update on recent Indian transfer pricing cases and
their impact
> 13 October, 2:00 – 3:00 PM HKT (GMT +8)
Host: S.P. Singh
Presenters: Sanjay Kumar and Shuchi Ray
VAT / GST implementations: Hard lessons for soft landings
> 25 October, 2:00 – 3:00 PM HKT (GMT +8)
Host: Robert Tsang
Presenters: K Baskar, Kok Fei Ha, Bruce Hamilton, and Robert Tsang
Tax tribunals and courts in India have made a number of judicial
pronouncements on transfer pricing issues during the past 6
months. Some of them have been landmark in content, addressing
fundamental concepts of transfer pricing, and thereby they
contribute significantly towards the development of transfer pricing
law and practice. Some of these decisions have also gained
international traction and are being quoted in international tax
lexicons for their profundity and analysis. We'll discuss the
following cases:
• Instrumentarium Corporation: Tribunal (Special Bench) order on
principle of "base erosion".
• CUB: Delhi High Court order on situs of foreign trademark owned
by a foreign company.
• Ranbaxy: Tribunal (Delhi Bench) order on foreign tested party.
• Oracle: Delhi High Court order on payment of excess royalty.
Stay up to date with the latest developments on transfer pricing
cases in India.
Stay informed
Many countries are either introducing new VAT and GST rules
(India, Malaysia, countries in the Middle East), or evolving their
own approach to drive better indirect tax compliance amongst
taxpayers (China, Singapore, Australia, and others). What are the
keys to successful VAT / GST implementations? What lessons can
your business take from these experiences? If you are deploying
teams from China or Southeast Asia to help with VAT / GST
implementations in India and the Middle East, what approach
works best? We'll discuss:
• Latest GST developments, law, guidance, and decisions.
• The good practices to follow and the pitfalls to avoid.
• Next steps to consider.
Understand more on the VAT and GST developments and find out
how your business can manage indirect taxes more effectively.
Digital economy and GST: Brave new worlds in India and
New Zealand
> 29 November, 2:00 – 3:00 PM HKT (GMT +8)
Host: Robert Tsang
Presenters: Allan Bullot, Saloni Roy, and Robert Tsang
Digital economy and indirect tax are hot topics in many countries
around Asia Pacific as tax authorities seek to put both domestic and
international suppliers of digital products to consumers in-country on
the same footing. India's draft model GST law has extensive digital
economy rules; the new dual GST could be in place as soon as 1 April
2017. New Zealand has a new set of compliance obligations going
live in October 2016 for suppliers of digital services. How will the
digital platform for your business be affected? We'll discuss:
• Overview of the new digital economy rules, with a focus on India
and New Zealand.
• The comparison of these frameworks to the OECD VAT / GST
International Guidelines.
• The way forward.
Understand more about how these rules will work and discover how
they apply to your company's indirect tax planning.
The Indian Media and entertainment industry is identified by
the Indian Government under "Make in India" initiative and
it is one of the sectors with a rapid growth curve.
Visit www.deloitte.com/in or contact your Deloitte contact
to learn about the key challenges faced by the Media and
entertainment industry from a tax perspective.
M&A Tax
International Tax
Tax considerations and tax-free post-acquisition corporate
restructuring: A focus on India, Japan, and Korea
> 10 November, 2:00 – 3:00 PM HKT (GMT +8)
Host: Danny Po
Presenters: Yoshitaka Hasegawa, Shripal Lakdawala, and
Sung Soo Woo
Swimming between the flags: The new Australian Taxation
Office approach
> 15 November, 2:00 – 3:00 PM HKT (GMT +8)
Host: David Watkins
Presenters: Claudio Cimetta and Soulla McFall
As part of the post-merger integration of a global, regional, or
domestic acquisition, there could be different forms of corporate
restructuring and substantial income tax as well as indirect taxes may
be incurred. Tax-free internal restructuring may be available, but
subject to the satisfaction of prescribed conditions. We'll discuss:
• Overview of corporate restructuring with a focus on India, Japan,
and Korea.
• Considerations to be made to address the fair value for tax, cost
base step up, and deductibility of capital losses.
• 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
The Australian Taxation Office (ATO) is fast evolving the way in
which it engages with business and administers the law based on a
concept of "justified trust". The development of Law Companion
Guidelines (LCGs) and Practical Compliance Guidelines (PCGs) are
examples of the way in which it is seeking to manage significant or
emerging risks to the revenue given its available resources and
desire for real time administration. LCGs and PCGs, as well as
Taxpayer Alerts, set out the ATO's position on potential risk areas
thereby allowing taxpayers to take this into account in their
behaviours, activities, or transaction structures. We'll discuss:
• What is "justified trust"? What is a LCG, a PCG, and a Taxpayer
• What are the risk issues identified by the ATO, with a focus on
multinational tax issues?
• Reconciling the ATO views with your acceptable level of risk.
• Practical implications for multinational companies operating in
Find out details of these guidelines to swim safely between the flags.
Inbound investment into Korea: A clear view of the recent
> 8 December, 2:00 – 3:00 PM HKT (GMT +8)
Host: Sunny Kim
Presenters: Diana Lee and Jimmy Lee
Significant developments in Korea have caused an impact on
inbound investment into the country, including the 2017 tax
proposals and BEPS. What are the tax implications and risks
associated with the investment process into Korea, and how can
foreign investors proactively manage them? We'll discuss:
• Overview of the selected proposed changes to Korean tax
legislation in 2017 which may have implications on foreign
inbound investors in Korea.
• Implementation of BEPS Action 13 under the Korean domestic tax
legislation and new transfer pricing documentation requirements
for multinational enterprises in Korea.
• Recent decisions from the Tax Appeals and Supreme Court case
Discover the latest inbound investment climate in Korea, and what
might affect your benefits when investing in Korea.
For program information, visit www.deloitte.com/ap/dbriefs 2
Global Mobility, Talent & Rewards
Industries – Financial Services
Payroll operations and employment tax considerations for
today's and tomorrow's workforce: Emerging trends,
opportunities, and risks
> 17 November, 2:00 – 3:00 PM HKT (GMT +8)
Host: Elizma Bolt
Presenters: Steven Batrouney, Saraswathi Kasturirangan, and
Vivian Lam
Corporate treasury centers in Asia: The race is on
> 22 November, 2:00 – 3:00 PM HKT (GMT +8)
Host: Michael Velten
Presenters: Sam Gordon, Benny Koh, and Samantha Tan
The continually evolving regulatory and HR environment has driven
organizations to demand more from their payroll operations and
those responsible for employment taxes. Mobile employees and the
rise of contingent workers add complexity by triggering payroll and
other obligations in multiple jurisdictions and requiring additional
transparency regarding their pay. We'll discuss:
• How can employers best manage mobile workforces across
multiple jurisdictions in the context of immigration, delivery of
employee benefits and effective cost management for the
• Emerging challenges and opportunities for managing payroll
operations and employment tax risks.
• Considerations for employers and employees who maintain mobile
workforces who participate in employee share plans.
Gain insights from Deloitte experts on how payroll operations and
employment taxes are impacting your businesses.
Across Asia, corporations are increasingly focused on establishing
corporate treasury centers to better manage cash, liquidity, financial
risks, and provide financial supply chain solutions. What are the
factors driving the establishment of a corporate treasury center, and
what are important considerations for your organization? We'll
• Factors driving the development of corporate treasury centers in
• Practical aspects of the Hong Kong and Singapore tax incentive
regimes for corporate treasury centers including the relative merits
and disadvantages.
• Transfer pricing issues and considerations, including allocation of
the interest savings from cash pooling.
• Impact of Base Erosion and Profit Shifting (BEPS) Actions on cash
pooling, a common liquidity management solution.
Gain insights into this developing trend and what it could mean for
your organization.
Transfer Pricing
OECD Actions 8-10 and 13: How is transfer pricing guidance
playing out globally?
> 13 December, 2:00 – 3:00 PM HKT (GMT +8)
Host: Fiona Craig
Presenters: Eunice Kuo, Alan Shapiro, and Graeme Smith
In the year since the OECD issued BEPS guidance on transfer
pricing, there has been a flurry of legislative and rule-making activity
around the world. What major developments should you know
about? We'll discuss:
• A region-by-region review of how countries are adopting the
guidance, including in Asia Pacific, EMEA, and the Americas.
• An update on the guidelines, including revised rules for pricing
and reporting of intercompany transactions based on
Actions 8-10 and 13.
• Implications for multinational companies, including potential
impacts on business models.
Keep current with how the BEPS guidance is playing out and how
the global tax reset could impact your business.
For program information, visit www.deloitte.com/ap/dbriefs 4
Japanese Language
Stay tuned
> 11月2日 12:00 – 1:00 PM 日本時間 (GMT +9)
司会進行:橋本 純
講師:野邑 和輝、足立 佳寛、蜷川 義裕
デロイト トーマツ税理士法人では、タックス・コンプライアンスに係る
寄稿記事を Webサイトで紹介しています。
詳細はこちら: www.deloitte.com/jp/tax/kco
• グローバル税務コンプライアンスを取り巻く環境の変化
• 日系税務部門の課題と方策
• 税務テクノロジーのもたらす可能性
• 事例研究
Our Presenters
Asia Pacific
Sung Soo Woo
Steven Batrouney, Elizma Bolt, Claudio Cimetta, Fiona Craig, Soulla McFall,
Graeme Smith, David Watkins
Eunice Kuo, Vivian Lam, Danny Po, Samantha Tan
K Baskar, Saraswathi Kasturirangan, Sanjay Kumar, Shripal Lakdawala,
Shuchi Ray, Saloni Roy, S.P. Singh
Tax Innovator Award
Webcasts & Bytes
Sam Gordon, Yoshitaka Hasegawa, Alan Shapiro
Sunny Kim, Diana Lee, Jimmy Lee
Kok Fei Ha
New Zealand
Allan Bullot
Benny Koh, Robert Tsang, Michael Velten
United Arab Emirates
Bruce Hamilton
Japanese Language Webcasts
橋本 純 (Jun Hashimoto), 野邑 和輝 (Kazuteru Nomura),
足立 佳寛 (Yoshihiro Adachi), 蜷川 義裕 (Yoshihiro Ninagawa)
For program information, visit www.deloitte.com/ap/dbriefs 6
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