Dbriefs Podcasts

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Pillar Two—Mechanisms and effect on inbound businesses

The OECD’s Pillar Two imposes a global minimum tax, and its recent implementation in Japan will impact large foreign multinational companies in Japan in different ways depending on their global structure. In this episode of The Japan Perspective, Deloitte Tokyo’s tax professionals Joanna Hazel and Brian Douglas discuss the various mechanisms of Pillar Two and their impact on Inbound businesses’ tax considerations, as well as how to prepare for the implementation of the Income Inclusion Rule. They also discuss how businesses with subsidiaries in Japan can approach any potential future implementation of the other mechanisms of Pillar Two. 

The Japan Perspective is a podcast series committed to communicating the latest Japanese tax developments and the potential impact on foreign multinational companies operating in Japan.

APA/MAP developments and updates 

Are Advance Pricing Agreements (APAs) on the upswing? In recent months, the Central Board of Direct Taxes has released its fourth and fifth annual reports in quick succession on the APA programme, interestingly including information on Mutual Agreement Procedures (MAP).

Here is an engaging conversation between experts Sobhan Kar (Senior Advisor, Deloitte India) and Tarun Arora (Partner, Deloitte India), decoding these APA and MAP reports and sharing their valuable insights on the trends and what these reports indicate.

Recent increase in tax rates for royalties/FTS for foreign taxpayers 

The recent increase in taxation rates for royalties and fees for technical services or FTS earned by foreign companies from India—from 10% to 20%, which was not part of the original Finance Bill 2023, was introduced subsequently in the parliamentary amendments to the Bill. Quite a noteworthy change, this will impact several Indian companies borrowing technical expertise/know-how from foreign parent, affiliates, or other foreign suppliers at large.

Global remote work policy

There has been a paradigm shift when it comes to reimagining the workplace prompted by COVID-19. An employee-friendly measure that several global organisations are evaluating is a ‘Global – Work from Anywhere’ policy. This podcast gives you an overview of the reason this policy is reflective of a post COVID-19 ‘future of work’ and sums up the Indian tax implications to be borne in mind by employers and employees, with regards to employees opting to work out of India for the permitted duration.

Italian Incentives provided by the Italian Recovery Plan (PNNR)

The Italian recovery plan is being introduced with a goal of enhancing the Italian recovery after the crisis induced by the pandemic. Part of the measures introduced provide a wide range of tax credit to boost the transformation of the Italian industrial system by driving more and more investment in innovation, industry 4.0 asset, R&D expenses, design and digital transformation. Tax credit introduced are easy to be calculated and suitable to offset any type of tax liabilities, so that they can be considered cash grant equivalent . The new rules offers a number of benefits from a tax perspective and is an exciting development for companies that have invested or are investing in Italy. This podcast provides an update on the legislative process and a brief overview of the rules.

The UK Asset Holding Companies Regime

The new UK Asset Holding Companies (AHC) regime is being introduced as part of a wider review of the UK funds regime, with a goal of enhancing the UK's competitiveness as a location for asset management and for investment funds. The new regime offers a number of benefits from a tax perspective and is an exciting development for our clients operating in this space. This videocast provides an update on the legislative process and a brief overview of the rules.

Company Provided Housing Scheme in Japan

Company provided housing, if structured properly can provide tax benefits to employees. It is a popular employee benefit scheme that will help companies retain and attract the best talent in a competitive market. In this podcast, our Japan professionals will present the general conditions that should be met in structuring the company provided housing scheme and how Deloitte can help from a tax and legal perspective with the implementation of the plan or reviewing the existing programs.

Extra Territorial Taxation – Germany focused

A number of countries have introduced the taxation of royalties based only on the registration of intellectual property. The Asia Pacific based owner of IP may have tax obligations in Germany on royalties received from outside of Germany but where the underlying IP is registered in Germany. Hear what Claus Schuermann (Tax Partner, Deloitte APICE) has to share on the current developments in Germany.

Crypto tax in Australia

With the resurgence of Cryptocurrencies, there are an increasing number of traders, mining and companies worldwide using them for a host of investment, operational, as well as transactional purposes.In this episode, Neil Pereira (Tax Partner, Deloitte Australia) will speak to us about the current tax treatment of cryptocurrency gains in Australian context.