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Corporate Income Tax
Impact of BEPS in Asia Pacific: Latest developments and updates
23 August 2022
Host: Hooi Beng Tan
Presenters: Jonathan Culver and Amelia Teng
The new BEPS initiatives around Pillar One and Pillar Two will have significant impacts on Asia Pacific. Pillar Two is an issue for any countries in Asia Pacific who offer various tax incentives and investment regimes that can be impacted by the Pillar Two rules. It is likely to cause changes to tax rules and regulations, change the financial benefit of current Asia Pacific business structures and create incremental compliance and reporting obligations. In this session, we'll discuss:
- The latest developments of BEPS.
- Impact of Pillar Two in Asia Pacific.
- Potential challenges and way forward.
Corporate Income Tax
Taxation of Cryptocurrency in Asia Pacific: Current and proposed tax regimes
16 August 2022
Host: Neil Pereira
Presenters: Promod Batra, Matthew Lovatt, and Roy Phan
The environment for digital currencies is changing rapidly with tax authorities becoming even more focused on ensuring that these assets are appropriately taxed but can we even agree on what digital currencies are and therefore how they should be taxed? There is no clear consensus and tax authorities are at the moment focused on ensuring that individuals report on gains in their tax returns but what about the broader institutional framework. We'll discuss:
- The current and proposed regimes for taxation of Cryptocurrencies in Asia Pacific.
- Key takeaways.
Indirect Tax
Digital Trade in Singapore and Malaysia: Implementation and moving forward
11 August 2022
Host: Richard Mackender
Presenters: Senthuran Elalingam and An Vo Hiep Van
The OECD has recently released an Indirect Tax Digital Toolkit for the Asia Pacific which provides comprehensive and detailed guidance for policy design, implementation and operation of a comprehensive indirect tax strategy targeted at digital trade in the region. How will these developments impact your business? We'll discuss:
- The principles covered in this toolkit.
- Comparison to the recent and upcoming implementations of indirect tax on digital trade, including the 1 January 2023 implementations announced for Singapore and Malaysia under their respective indirect taxes.
- Impact of new electronic and digital services rules in Vietnam.
- The way forward.
Indirect Tax
Tackling EU CBAM's impact to structure sustainable supply chain
2 August 2022
Host: Lily Li
Presenters: Dolly Zhang and Roger Chen
Climate change is a global issue which should be addressed with global solution. The EU Commission unveiled new policy of Carbon Border Adjustment Mechanism (CBAM) to mitigate the risk of "carbon leakage" for certain imported products embedded with high carbon emissions. The essence of CBAM is considered as one of international trade measures which has intensive impact not only on export business but also passing the impact through the entire supply chain. With more details of CBAM being released and the implementation date approaching, companies are suggested to keep close attention and take actions by adopting more sustainable supply chain where necessary. In this session, we'll discuss:
- The latest development and impact of CBAM.
- Insights on resilient and greener supply chain.
- Suggested steps/actions toward sustainable supply chain.
Transfer Pricing
Transfer pricing dispute resolution: A focus on China
19 July 2022
Host: Dolly Zhang
Presenters: Victor Zhang and Roger Chen
In China, transfer pricing is currently a key area that is attracting a great attention from tax authorities and customs. Due to the different standing point in the area of taxation and the legal basis of enforcement, a covert conflict between two authorities exists in the review of transfer pricing related matters, which may give rise to management overlapping and double taxation for MNCs from time to time. How to establish and manage transfer pricing, how to secure certainty and alignment between the two fiscal authorities have always been a challenge for MNCs. Recently, Shenzhen Tax Bureau and Shenzhen Customs jointly announced pilot programme regarding the collaborative management of transfer pricing of related-party imports, on the basis of existing Customs advance ruling policy and advanced pricing arrangement (APA) with tax authorities. The cooperation between customs and tax in the field of transfer pricing is a breakthrough in China. To help businesses to obtain a comprehensive understanding of the latest policy and trends, we'll discuss:
- Transfer pricing trends by China Customs and tax authorities.
- Highlight of the collaborative management pilot programme.
- Implications and practical considerations of the pilot programme.
- Future outlook and suggestions to businesses.
Global Mobility, Talent & Rewards
Labour Codes: Update on State rules and overall status
14 July 2022
Host: Saraswathi Kasturirangan
Presenters: Tarun Garg, Saraswathi Kasturirangan, and Radhika Viswanathan
In an attempt to consolidate and simplify labour regulations in India, the four labour codes, subsuming 29 central legislations, have been approved by the Indian President. While the notification of the effective date is pending, the States and union Territories have issued the draft rules. In this session, we'll discuss:
- What is the status of the central labour codes?
- What kind of changes do we expect?
- What is the status of the various state rules?
- How would this be impacted by the central regulations?
Special Edition - Geography Updates
Secondment Arrangements – Recent ruling and key impact
7 July 2022
Host: Sumeet Hemkar
Presenters: K Baskar, Aarti Raote, and Suchint Majmudar
In the contemporary global economy, to leverage on talent available within the group companies, employees are frequently seconded by group companies. The issue of levy of indirect tax on such cross border secondment arrangements had settled over the last few years by way of multiple favorable rulings. Thus, in cases where seconded employees were working under the control and supervision of the Indian company and salary was being paid in India after deducting taxes as per the Indian tax laws, largely, the position that was taken that the seconded employees have employer employee relationship with Indian company and no indirect tax was applicable on such transactions. Recently, the Supreme Court of India in the matter of Northern Operating Systems held that one factor is not sufficient to conclude that employer employee relationship exists between the secondee and the Indian company. Multiple factors such as salary payment, nature of task assigned, responsibility for task performed, eligibility to terminate employment, duration of the secondment, overall arrangement between Indian and overseas company have to be considered. To understand the impact of the aforesaid ruling on taxability of secondment agreements, we'll discuss:
- Alignment of position under direct tax and indirect tax laws.
- Review of secondment arrangements to review tax position.
- Impact of the ruling on the service tax position taken for taxability of secondment contracts.
- If service tax is paid for the past period, whether benefit of credit/refund can be claimed now.
- Requirement to pay tax on secondment arrangements under GST regime, eligibility to claim credit/refund for the previous years.
Corporate Income Tax
M&A and Carve-Out strategy in Southeast Asia
31 May 2022
Host: Daniel Ho
Presenters: Soo Earn Keoy, John Lauwrenz, Ngan Dang, Kwang Gek Sim, and Niorn Yukolthong
Several carve-out deals have recently been announced, indicating that in the current economic context, carve-outs are proving to be an interesting option for big corporations to achieve strategic benefits and to bring value to its shareholders. In the past, companies have considered carve-outs when a part of their business is too weak or troubled to keep, or when they want to monetize it. Today, companies are increasingly seeing value in separating non-strategic business units and building a more focused portfolio. Professionals from various geographies will discuss:
- Overview of carve-out.
- Market trends and transaction life-cycle.
- Benefits and challenges of carve-out from a tax perspective.
Financial Services Industry
Financial Services Series: Tax policy developments and reform in Asia Pacific
30 May 2022
Host: Michael Velten
Presenters: Senthuran Elalingam, Junwei Han, Matthew Lovatt, Terence Tan
As businesses settles into the post-pandemic era, the focus of businesses and markets will likely be on how to “build back better”. It is important for businesses to respond with agility to a changing landscape, to weather market events with minimal service disruptions, and to work towards long-term sustainability of their business models. On this backdrop, we'll discuss:
- Overview of the economic and business impacts of COVID-19 in Asia Pacific and the impact on tax policy and administration.
- An update on current OECD projects and initiatives, including the proposed two-pillar solution for the digitalization of the global economy and the role of tax policy in stimulating global economic growth.
- The overall themes in Asia Pacific financial services tax will be distilled as well as the impact on the tax management agenda for 2022-2023.
Financial Services Industry
Financial Services Series: Tax developments in Australia
26 May 2022
Host: Siew-Kee Chen
Presenters: Nari Kye, Alison Noble, Manu Sriskantharajah, and Amelia Teng
As we enter this next phase of the recovery, the future is unfolding. Financial services organizations are operating in a changing world—one they can help define. Financial services firms face in 2022 a pivotal, no-turning-back opportunity to shape their future. This session will explore the key tax developments in Australia for financial services, including:
- Current tax authority focus, and enforcement approach, including the latest developments and anticipated scope expansion in the Common Reporting Standard (CRS) and third party data.
- Key international tax issues impacting the Australian financial services industry, including the latest developments in the OECD/ G20 Two Pillar Solution.
- The new fund structure in Australia (the Corporate Collective Investment Vehicle) operative from 1 July 2022.
Financial Services Industry
Financial Services Series: Tax developments in India
17 May 2022
Host: Russell Gaitonde
Presenters: Rajesh Gandhi, Bahroze Kamdin, Madhav Kanhere
The Indian economy is recovering from the COVID-19 impact and is gradually picking up amidst these uncertain times and volatile environment, caused by various disruptions, high inflation, and geo-political tensions. The financial services sector can help define the economy and would need to be its backbone, by playing a pivotal role for strength and stability, while operating in a changing world. With the recent developments in the tax environment, what is the impact to the financial services industry? We'll discuss:
- Key tax developments for financial services in India.
- Tax policy priorities and current tax audit focus.
Indirect Tax
China customs and trade policies: Updates and development
12 May 2022
Host: Dolly Zhang
Presenters: Roger Chen and Shelly Ma
Since 2021, facing continuously serious Covid-19 situation, China government has carried out policies to move foreign trade growth steadily. The total value of China's trade in goods imports and exports is 39.1 trillion RMB, which is an increase of 21.4% over 2020, and it is the highest record in history. In this session, we will discuss the updates in the field of China customs and international trade, including:
- The latest China foreign trade facilitation policies.
- New opportunities and risks on cross-border trade by importers/exporters.
- Relevant practical considerations and our suggestions.
Financial Services Industry
Financial Services Series: Tax developments in Japan and South Korea
10 May 2022
Host: Scott Oleson
Presenters: Stephen Baker, and Mickey Vandre
With the recent Tax Reform and new tax developments in South Korea and Japan, what is the impact to the financial services industry? We'll discuss:
- Key developments in Japan and South Korea.
- The overall tax environment including tax audit priorities.
- Our relevant experiences in Japan and South Korea.
Tax Technology
SAP S/4HANA: SAP Document and Reporting Compliance
14 April 2022
Host: Piyus Vallabh
Presenters: Haryati Hamzah, Madhav Sarvesararao, and Amit Verma (SAP)
Changes to the tax legislative landscape mean that tax compliance and reporting is becoming more immediate, digitalized, and more data intensive. Ensuring that the business can keep pace with these changing demands means that tax needs more accurate transactional data captured or calculated correctly, first time and businesses are therefore looking at how they can better leverage their ERP system. In many countries it is becoming a legal requirement for organizations to issue documents electronically to their business partners and tax authorities. The 'digital tax authorities' now require to be provided more frequently with invoices, ledgers/registers/books on a (near) real time-basis. Due to the continuously changing digital reporting requirements, it can be a difficult process for tax functions to manage. Within the S/4HANA suite one such module is SAP Document and Reporting Compliance (SAP DRC). What does your organization need to know? We'll discuss:
- How SAP DRC can boost the value of your SAP S/4HANA implementation.
- Key characteristics and functionality.
- Key considerations in assessing the suitability of SAP DRC.
Financial Services Industry
Financial Services Series: Tax developments in China
12 April 2022
Host: Natalie Yu
Presenters: Johnny Foun, Wang Qing, Simon Tan, and Julie Zhang
In the most recent year, there are changes in terms of tax administration environment as well as investment environment in China. What is the impact and implications to financial services? We'll discuss:
- Trend of tax administration, including utilizing more digitalized tools, cross-function information sharing to bring more transparency, piloted advantage rulings and etc.
- Uncertainties toward direct investment into China security market by foreign financial institutions under the expansion/promotion of more investment into China capital market.
Global Mobility, Talent & Rewards
Global Mobility and Workforce: Time to transform
7 April 2022
Host: Gillian Waite
Presenter: May Myat Thu
Global mobility has demonstrated exceptional value through helping maintain business continuity in turbulent times and responding to the wider mega trends driven by the future of work. With expanding scope, greater business scrutiny and increased expectation of talent, there is significant transformation occurring to elevate and re-imagine global mobility and the management of global workforces to support the wider business in preparation for post-COVID. We'll discuss:
- Global mobility trends: Developed by Deloitte Center for the Edge analyzing broader business and Human Capital trends, as well as deep-dive interviews with Global Talent leaders.
- Opportunities for global mobility to re-imagine, with deep dives on the hot Asia Pacific topics such as remote work and employee communication.
- Present a framework to evaluate global mobility and workforce to understand practical next steps.
Corporate Income Tax
M&A and Carve-Out strategy in China and India
31 March 2022
Host: D.V. Manohar
Presenters: Jean Luo, Bimal Modi, and Tarun Soneja
Several carve-out deals have recently been announced, indicating that in the current economic context, carve-outs are proving to be an interesting option for big corporations to achieve strategic benefits and to bring value to its shareholders. In the past, companies have considered carve-outs when a part of their business is too weak or troubled to keep, or when they want to monetize it. Today, companies are increasingly seeing value in separating non-strategic business units and building a more focused portfolio. Professionals from various geographies will discuss:
- Overview of carve-out.
- Market trends and transaction life-cycle.
- Benefits and challenges of carve-out from a tax perspective.
Financial Services Industry
Financial Services Series: Tax developments in Hong Kong and Singapore
29 March 2022
Host: Michael Velten
Presenters: Jessica Chu, Jonathan Culver, Han Junwei, Richard Mackender, Kevin Ng, and Roy Phan
In the wake of budget statements in both Hong Kong and Singapore, this session will reflect on the fiscal policy considerations currently driving policy making in both jurisdictions. Both jurisdictions have recently suggested a Domestic Minimum Tax will be introduced to respond to the OECD's BEPS 2.0 initiative. Also, asset management is a strength of both locations, and the respective legal and tax frameworks continue to develop. We'll discuss:
- The potential design of Domestic Minimum Tax rules and how they could interact with the current tax law and incentive regimes. We will also consider potential pitfalls for policymakers to consider.
- The existing and future proposed developments in the asset management sector.
- The GST changes that will apply from 1 January 2023 and the considerations as organizations commence to prepare for these.
Corporate Income Tax
M&A and Carve-Out strategy in Japan, Korea, and Taiwan
24 March 2022
Host: Scott Oleson
Presenters: Masato Iwajima, Masaaki Kaneko, and Cheli Liaw
Several carve-out deals have recently been announced, indicating that in the current economic context, carve-outs are proving to be an interesting option for big corporations to achieve strategic benefits and to bring value to its shareholders. In the past, companies have considered carve-outs when a part of their business is too weak or troubled to keep, or when they want to monetize it. Today, companies are increasingly seeing value in separating non-strategic business units and building a more focused portfolio. Professionals from various geographies will discuss:
- Overview of carve-out.
- Market trends and transaction life-cycle.
- Benefits and challenges of carve-out from a tax perspective.
Corporate Income Tax
M&A and Carve-Out strategy in Australia and New Zealand
23 March 2022
Host: James Doidge
Presenters: Aaron Black and Ian Fay
Several carve-out deals have recently been announced, indicating that in the current economic context, carve-outs are proving to be an interesting option for big corporations to achieve strategic benefits and to bring value to its shareholders. In the past, companies have considered carve-outs when a part of their business is too weak or troubled to keep, or when they want to monetize it. Today, companies are increasingly seeing value in separating non-strategic business units and building a more focused portfolio. Professionals from various geographies will discuss:
- Overview of carve-out.
- Market trends and transaction life-cycle.
- Benefits and challenges of carve-out from a tax perspective.
Geography Updates
Hong Kong SAR Budget 2022/2023 Commentary
17 March 2022
Host: Polly Wan
Presenters: Alfred Chan, Raymond Tang, and Roy Phan
The Financial Secretary for the Hong Kong Special Administrative Region (HKSAR), Mr. Paul Chan, delivered his sixth annual budget on Wednesday, 23 February 2022. As an international financial center, the HKSAR Government has recently been rolling out a number of initiatives and tax incentives on how the city can address emerging challenges facing the pandemic and promote economic diversification for sustainable development in the future. We'll discuss:
- A summary of the Budget highlights and the new Budget measures.
- Measures to promote development of Hong Kong capital market.
- Environmental, Social and Governance (ESG) related measures to realize carbon neutral in the long term.
- Tax incentives for financial and maritime and port sectors.
- New international tax standards and introduction of domestic minimum top-up tax.
Indirect Tax
Indirect Tax developments on electronically supplied services (ESS) and e-invoicing in Asia Pacific
3 March 2022
Host: Richard Mackender
Presenters: Shrenik Shah, Candy Tang, and Nu To Van
The digitization of indirect taxes continues to gain momentum across the region as more countries adopt or expand e-invoicing requirements. On a similar front, we continue to see adoption of rules imposing indirect taxes on the provision of electronic services by foreign service providers. This session will chart the implementation and development of these rules across the Asia Pacific. We'll discuss:
- Recap on e-invoicing and ESS requirements.
- The current state of play across the region in terms of jurisdictions that have adopted, announced or proposed e-invoicing or ESS rules.
- An overview of recent expansions and implementations including China and Thailand.
- A retrospective on the implementation of e-invoicing in India.
Geography Updates
2022 Japan Tax Reform Proposals: Pursuit of Post-Pandemic priorities
1 March 2022
Host: David Bickle
Presenters: Brian Douglas, Ken Leong, Brian Mayer, and Fumiko Mizoguchi
The 2022 Japan Tax Reform reflects the Japanese government's desire to look beyond the pandemic and towards sustainable economic recovery. Proposals include measures to boost consumer spending, smooth the path towards digital transformation, and to continue the reform of the Japanese Consumption Tax (JCT) system. We'll discuss:
- Revisions to tax credits for wage increases and R&D spending.
- Developments in connection with record storage under the Electronic Record Retention Law.
- Latest updates in preparation for the introduction of JCT qualified invoicing.
Global Mobility, Talent & Rewards
Reward in future of work: Operating an equity plan
22 February 2022
Host: Senthuran Elalingam
Presenters: Larry James Sta Maria and Eng Yew Tan
Equity compensation is a constantly expanding landscape and its role is becoming more and more important for companies in pursuit of key talents and ultimately their success. In the context of Asia Pacific, the use of equity compensation is a critical part of remunerations strategy led by mature market such as Australia and Japan, and rising generation of start-up companies such as China and India. Unsurprisingly, this is where most governments around the world continue to increase their attention on corporate governance around equity plans ensuring regulatory and tax compliance remaining high on companies' agendas. We'll discuss:
- Recent tax and regulatory development in key countries and/or government/audit focus on employer's obligation on equity compensation and how to manage the challenges.
- Tax considerations in designing the equity plan to deal with the changing landscape under the future of work.
Indirect Tax
Malaysia Indirect Tax Special Voluntary Disclosure and Amnesty Program
15 February 2022
Host: Senthuran Elalingam
Presenters: Larry James Sta Maria and Eng Yew Tan
The Malaysian Government has announced a voluntary disclosure and amnesty program covering the majority of indirect taxes that are levied within the country. The program will operate for a period of nine (9) months commencing from 1 January 2022 and concluding on 30 September 2022. There are a range of benefits that accrue to participants in the program including a full waiver of applicable penalties and a partial waiver (up to 30%) of any underpaid taxes. The indirect taxes covered include Sales Tax, Service Tax, the former GST and Customs and Excise Duties. We'll discuss:
- Which taxpayers are eligible to participate?
- The specific benefits that will be provided to eligible participants.
- The process from applying through to closure.
- The documentation and information requirements.
Indirect Tax
Updates on Regional Comprehensive Economic Partnership (RCEP) and Free Trade Agreements (FTA) related origin documentation audits
10 February 2022
Host: Payal Tuli
Presenters: Meng Yew Wong, David Ware, Jin Kon Jung, Dolly Zhang, and Mitsuko Fukunage
The Regional Comprehensive Economic Partnership agreement (RCEP), signed on 15 November 2020, took effect on 1 January 2022 (1 February 2022 in Korea). It is the largest and most significant regional agreement concluded in terms of market size, coverage on trade and investment, and population. Apart from RCEPs, we will also discuss the increase in complexity and risks associated with FTA related origin documentation. We'll discuss:
- The Highlights and latest updates on RCEP with special highlights from Australia, China, Korea, Japan, and South East Asia.
- Benefits and what this may mean for your business.
- Experience in relation to origin documentation related queries/audits and best practices to mitigate the risk of denial of the FTA benefit.
Geography Updates
India Budget 2022: Enabling India’s big leap
2 February 2022
Host: Hemal Zobalia
Presenters: Jatin Kanabar, Sanjay Kumar, and Bela Sheth Mao
India Budget 2022 will be presented in the Parliament on 1 February 2022. The Union Budget is expected to put the economy on an accelerated growth path after the impact caused by the pandemic. Amendments in the tax law to bring about sustainable growth, infrastructure investment, focus on R&D spending, nurturing incentives to the core sectors including manufacturing and services, tapping the huge experience of running captive centres are some of the priority items on the agenda of the Government as the preparation gets underway to unveil the budget. Ease of tax compliances, simplification, and digitization are the cornerstones to enhance the ease of doing business in India. With an optimistic outlook towards sustained growth, all eyes are on the announcements. We'll discuss:
- The Government's tax initiatives on reviving the industries and boosting optimism.
- Key policy announcements towards making India self-reliant.
- Analysis and impact of new tax proposals on your sectors and the way forward.
