Program Guide
January - March 2014
Stay tuned in
International Assignments
International Tax
Global Mobility: Talent Strategies and Trends in Asia Pacific
> 16 January, 2:00 – 3:00 PM HKT (GMT +8)
Host: Russell Bird
Presenters: Weina Ang, Mario Ferraro, and Huan Wang
Japan's 2014 Tax Reform Proposals and Consumption
Tax Hike
> 13 February, 1:00 – 2:00 PM HKT (GMT +8)
Host: David Bickle
Presenters: Mark Brandon, Frances Somerville, and Jun Takahara
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.
China Spotlight
2014 Preview: Rules that will Shape Inbound Investment
into China
> 23 January, 2:00 – 3:00 PM HKT (GMT +8)
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.
• 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.
1
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.
(Tune into the Japanese version of this webcast. Please refer to page 5 for
program details.)
What Can We Learn from the Top Tax Cases of 2013?
> 20 February, 2:00 – 3:00 PM HKT (GMT +8)
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
M&A Tax
Centralized Procurement and Shared Services: Emerging
Issues and Opportunities
> 4 March, 2:00 – 3:00 PM HKT (GMT +8)
Host: Tom Ewigleben
Presenters: Rohinton Sidhwa and Paul Zanker
M&A and India: Cross Border Tax Issues
> 18 February, 2:00 – 3:00 PM HKT (GMT +8)
Host: Vipul Jhaveri
Presenters: Rishiraj Khajanchi and Hemal Mehta
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.
"Permanent Establishment" Definition: Current "Frictions"
in Interpretation
> 25 March, 2:00 – 3:00 PM HKT (GMT +8)
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.
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.
Country Focus
Australia's New Part IVA General Anti-Avoidance Rules:
Uncertainty Resumes?
> 25 February, 12 noon – 1:00 PM HKT (GMT +8)
Host: Dwayne Sleep
Presenters: Ray Conwell, James Fabijancic, and Ashley King
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.
Indirect Tax
Indirect Tax: Update on China's Business Tax and VAT
Regime
> 6 March, 2:00 – 3:00 PM HKT (GMT +8)
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.
For program information, visit www.deloitte.com/ap/dbriefs 2
Indirect Tax
Transfer Pricing
Malaysian GST: Turning Promises into Hard Realities by
April 2015
> 27 March, 2:00 – 3:00 PM HKT (GMT +8)
Host: Robert Tsang
Presenters: Kah Seong Fan, Chandran Ramasamy, and Eng Yew Tan
Pricing Intercompany Financial Transactions: Controversies
on the Rise
> 13 March, 2:00 – 3:00 PM HKT (GMT +8)
Host: Shanto Ghosh
Presenters: Ian Clarke and Geoff Gill
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 programme and
how you should be preparing for implementation in 2015.
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
Industries – Financial Services
Tax on Services Rendered under Global Arrangements:
Perspective and Challenges in India
> 11 March, 2:00 – 3:00 PM HKT (GMT +8)
Host: Prashant Deshpande
Presenters: Jatin Arora and Debasis Ghosh
Financial Services Update: Developments in the China
(Shanghai) Pilot Free Trade Zone
> 18 March, 2:00 – 3:00 PM HKT (GMT +8)
Host: Steve Towers
Presenters: Patrick Cheung, Hal Davis, Johnny Foun, and Jennifer Qin
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.
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.
Gain insights
Foreign Investment into India
Find out the key facts and Q&As
on the regulatory regime for
foreign investment in India. Visit
www.deloitte.com/in or contact
your Deloitte contact to learn more.
3
Mergers & Acquisitions
Industries – Financial Services
China Outbound Investments
Cash Pooling among Banks and Corporate Clients: The Tide
is Rising?
> 20 March, 4:00 – 5:00 PM HKT (GMT +8)
Host: Michael Velten
Presenters: Leon Cane, Ian Clarke, Frederic Bertholon-Lampiris,
and Natalie Yu
Mergers and Acquisitions: A Sino-Russia Investment Boom
> 26 February, 5:00 – 6:00 PM HKT (GMT +8)
Host: Andrew Zhu
Presenters: Alexander Krylov and Anna Slobodenyuk
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.
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 into the Putonghua version of this webcast. Please refer to page 5 for
program details.)
For program information, visit www.deloitte.com/ap/dbriefs 4
Chinese Language
Webcasts
Japanese Language
Webcasts
平成26年度税制改正大綱
> 2月13日 12:00 – 1:00 PM （日本時間、GMT+9）
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
※トピックは変更になる可能性がありますので予めご了承ください。
（同じテーマのWebcastを英語でも開催します。詳しくは、プログラムガイドの
P1をご覧ください。）
Know more
「平成26年度税制改正」関連トピック
税理士法人トーマツでは、「平成26年度税
制改正」に関するNewsletterや寄稿記事
およびセミナー開催状況をWebサイトで紹
介しています。詳しくは、
http://www.tohmatsu.com/tax/nl/
をご覧ください。
5
Our Presenters
Australia
Patrick Broughan, Claudio Cimetta, Ray Conwell, James Fabijancic,
Geoff Gill, Ashley King, Neil Pereira, Dwayne Sleep
China
Patrick Cheung, Sarah Chin, Hal Davis, Johnny Foun, Li Qun Gao,
Leonard Khaw, Martin Lin, Jennifer Qin, Huan Wang, Natalie Yu,
Paul Zanker, Jennifer Zhang, Julie Zhang, James Zhao
India
Jatin Arora, Prashant Deshpande, Debasis Ghosh, Vipul Jhaveri,
Rishiraj Khajanchi, Hemal Mehta, Sunil Shah, Rohinton Sidhwa
Japan
David Bickle, Russell Bird, Mark Brandon, Frances Somerville,
Jun Takahara
Malaysia
Weina Ang, Ian Clarke, Kah Seong Fan, Chandran Ramasamy,
Eng Yew Tan
Singapore
Frederic Bertholon-Lampiris, Tom Ewigleben, Mario Ferraro, Steve Towers,
Robert Tsang, Michael Velten
United Kingdom
Leon Cane
United States
Shanto Ghosh
Mergers & Acquisitions
Alexander Krylov, Anna Slobodenyuk, Andrew Zhu
For program information, visit www.deloitte.com/ap/dbriefs 6
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