Dbriefs Asia Pacific Tax Webcasts

Global Mobility, Talent & Rewards
Reshaping the future: How generative AI will transform Global Mobility

Host: Jod Gill
Presenters: Jod Gill and Duleesha Koolasuriya
Date: 21 September, 2:00 – 3:00 PM SGT (GMT +8)

Generative AI is set to have a profound impact on the world and will transform the Global Mobility landscape. Much of this impact will be positive but many organisations are carefully considering the ethical dimensions of embracing AI. In this session, senior Deloitte technology and Global Mobility leaders will discuss:

•  The fundamentals of Generative AI
•  How Generative AI is likely to impact Global Mobility
• The ethical dimensions and risks that need to be navigated
• The practical steps that can be taken to start preparing for this significant change

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Geography Updates
Online gaming – Impact of recent changes in Indian regulatory & tax laws

Host: Madhava Yathigiri
Presenters: Neha Aggarwal, Shilpy Chaturvedi, and Hiren Shah
Date: 27 September, 2:00 – 3:00 PM SGT (GMT +8)

On 6 April 2023, The Ministry for Electronics and Information Technology (MEITY) notified amendments to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediary Rules, 2021”), to create additional obligations for online gaming intermediaries who enable access to real money games. Certain amendments relating to requirement of having physical contact address and appointment of compliance officers by online gaming intermediary could have tax implications. Having a physical contact address in India and appointment of compliance officers who are resident in India by a non-resident online gaming intermediary may result in Exposure under the Act and PE exposure for non-resident in India, Withholding tax obligations and Impact on equalization levy.

Further, the online gaming industry has been grappling with an unresolved issue of GST, which can impact the industry’s viability and sustainability. The GST council, in its meeting held on July 11, 2023, has recommended uniform rate of 28% on the full value of bets placed (irrespective of whether the activities are a game of skill or chance). The GST Council has recommended legislative changes in its meeting on August 2, 2023. GST Council has decided to bring into effect the proposed changes from 1 October 2023 (formal notification awaited). During the webcast, we will discuss: 

•  Amendment to Intermediary Rules which would be relevant for the online gaming intermediaries and impact of data privacy
•  Recent announcements by the GST council and impact on the online gaming industry
• Corporate tax considerations due to the amendment to the Intermediary Rules 
• Certain nuances pertaining to withholding tax on winning from online gaming
  

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Transfer Pricing
Treasury Transfer Pricing – Dept Pricing and Cash Pooling

Host: Trina Maitra
Presenters: Anushree Jagnani, Theppine Kyi, Philip Robert Moralee,
                     Priscilla Ratilal, Vrushang Seth, and Michael Yishun Sun
Date: 17 October, 2:00 – 3:00 PM SGT (GMT +8)

Traditional treasury roles are evolving in today’s world. Across regions, the importance of aligning tax and treasury pricing decisions is gaining momentum. In this space, Companies have witnessed major transitions like LIBOR replacements, increased reporting focus on financial transactions, and other market forces that are posing new challenges. Therefore, Treasuries need to revisit treasury policies regularly for capital/funding structure updates; changing investment strategies, to focus on better use of cash, e.g., increased appetite for Cash Pooling Arrangements and other considerations, such as local interest restriction rules (CIR). Additionally, transfer pricing issues revolving the treasury functions are becoming more and more complex given the close scrutiny of the tax offices across jurisdictions.

In this Dbrief session we will cover:

•  The treasury transfer pricing complexity with respect to the intercompany loans and cash pooling arrangements from treasury transfer pricing perspective across industries specifically touching upon the financial services sectors. 
•  The recent trends of the tax officers with respect to the debt transactions and cash pooling.
• Whether these jurisdictions have included any specific guidance to incorporate the principles of Chapter X of the OECD guidelines? Whether the outlook or focus on assessing these transactions have changed or are anticipated to change for the Chapter X inclusion?  
• How the interest limitation rules interacts with the transfer pricing analyses etc.

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Corporate Income Tax
Tax collection at source in India: The conundrum continues! 

Host: Pooja Dhokad
Presenters: Jimit Shah and Sameer Maniar
Date: 18 Octobber, 2:00 – 3:00 PM SGT (GMT +8)

In 2020, the Indian Government had introduced the provisions for collection of tax at source (‘TCS’) on payments made under Liberalized Remittance Scheme and on overseas tour programme package. The Finance Act, 2023 proposed a slew of amendments to the TCS provisions which further opened a pandora’s box of nuances and practical challenges for the travel and hospitality industry. Although recently, the Reserve Bank of India and the Ministry of Finance issued certain clarifications from a regulatory and tax perspective, companies in this space are still struggling on the applicability of the provisions along with practical challenges to implement. Through this webcast, we will cover the following aspects:  

•  Overview of the TCS provisions 
•  Applicability of the TCS provisions on certain transactions
• Nuances and practical challenges

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