| Dbriefs Conversations: Our New Video! Don Riegger and Steve Towers discuss tax issues related to deferred compensation for expatriates in Asia. | |
Dbriefs Korean Language Webcasts: For more program details, click here. Dbriefs Legal helps you stay on top of all the legal issues for your day-to-day activities and corporate life events. For details and to register for upcoming webcasts, click here. |
| China Spotlight |
| Thursday, 24 July, 2:00 – 3:00 PM HKT (GMT +8) | |
Earmarked Investments in Shenzhen Qianhai and Zhuhai Hengqin: What do You Need to Know? The Qianhai Shenzhen-Hong Kong Modern Service Industry Cooperation Zone (Qianhai) and the Zhuhai Hengqin New Area (Hengqin) are two key economic zones in China. As of May-end 2014, more than 12,000 entities were approved to register. As the two key constituent zones in the pending Guangdong-Hong Kong-Macau Free Trade Zone (FTZ), what are the opportunities available? We'll discuss: - The developments within the two zones and how they are strengthening the international competitiveness of China, Hong Kong, and Macau.
- The business and market opportunities available including Individual Income Tax equalization subsidies for qualified expatriate employees, and the reduced Enterprise Income Tax rate of 15% on qualified income.
- The differences among Qianhai, Hengqin, and other parts of China.
Join us as we discuss how zones such as Qianhai and Hengqin will help to mitigate China tax risks and enhance cost efficiency of non-resident companies. |
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| M&A Tax |
| Thursday, 31 July, 2:00 – 3:00 PM HKT (GMT +8) | |
Debt Push Down in Asia Pacific: Techniques and Case Studies It has always been a challenge for investors to obtain tax deductions on financing costs incurred in connection with M&A. Given the rapid development of BEPS in Asia Pacific, the structuring of debt push down will become even tougher. What are the techniques and challenges to overcome in order to push down the interest costs to the operating entities? We'll discuss: - Basic debt push down techniques.
- How to overcome regulatory and tax restrictions such as thin capitalization rules and exchange control measures.
- Illustrative case studies in China, Hong Kong, Japan, and Korea applying these techniques; considering how to align interest expense with taxable operating income, taking into account cross-border transfer pricing considerations and beneficial ownership requirements.
Understand the techniques and challenges on debt push down that might affect your M&A deals. |
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| Industries – Financial Services |
| Tuesday, 12 August, 4:00 – 5:00 PM HKT (GMT +8) | |
Operational Taxes in Asia Pacific: Are You Keeping Pace? Operational taxes, including technical aspects, governance, compliance considerations, and reviews, are affecting financial institutions based in Asia Pacific. What do you need to know to stay updated on operational taxes and related risk management in the region? We'll discuss: - Financial transaction tax (FTT) – an update on latest developments.
- Qualified Foreign Institutional Investors (QFII) / Renminbi Qualified Foreign Institutional Investors (RQFII) / Shanghai-Hong Kong Stock Connect – where do we currently stand in relation to capital gains tax and withholding tax on China securities?
- Philippines Tax Identification Numbers, specifically custodian requirements, options, and solutions.
- Update on China VAT for the banking industry.
Understand the implications of the latest developments and management of operational taxes in Asia Pacific. |
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| International Tax |
| Wednesday, 13 August, 2:00 – 3:00 PM HKT (GMT +8) | |
Road-testing BEPS Action 6 (Prevent Treaty Abuse): Case Studies BEPS Action 6 (prevent treaty abuse) involves the insertion, into double tax treaties, of a range of anti-abuse provisions. In this webcast, we will analyze a number of case studies which will illustrate the operation of these provisions. Issues covered in the case studies will include: - The "limitation on benefits" (LOB) article, including the operation of the "qualified person" definition, the "active trade or business" test, and the "derivative benefits" provision.
- The "main purpose" provision: scope and evidentiary support.
- Several of the "specific anti-abuse" provisions, such as exclusion of third country permanent establishments, the "saving clause", and the dual resident "tie-breaker" provision.
Learn how these new treaty anti-abuse provisions will likely operate in various practical situations. |
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| International Tax |
| Tuesday, 19 August, 2:00 – 3:00 PM HKT (GMT +8) | |
Inbound Investment into Australia: Do You Have a Complete Picture? Australia is currently experiencing an increase in M&A activity with significant investment flows coming from Asia Pacific. As the world's international tax architecture is evolving, legislative changes are occurring in Australia and the Australian Taxation Office (ATO) is refining its approach to managing risk to the Government. What are the tax risks associated with the investment process into Australia, and how can you proactively manage them? We'll discuss: - The main industries into which investments are being made and typical tax issues that arise.
- Important legislative tax changes, enacted and proposed, as well as recent ATO rulings.
- Typical inbound investment structures and issues.
- Tax risks that the ATO is focusing on.
Hear about the latest inbound investment climate in Australia, and what might affect your benefits when investing in Australia. |
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| Private Business |
| Thursday, 21 August, 2:00 – 3:00 PM HKT (GMT +8) | |
Private Wealth Structuring for Individually-Owned Thai Companies Recent transactions, such as the battle for a well-known food and beverage company, have shown the skills and resourcefulness of Thai business families. Many individually-owned Thai businesses include the 2nd or 3rd generation in leadership positions, demonstrating how developed the intergenerational transfer of wealth has become in Thailand. However, it is still unclear from a Thai tax point of view how companies can efficiently hold assets and businesses, particularly those involving overseas trusts and companies. We'll discuss: - Common structures.
- Respective legal and tax treatments for common structures.
- The potential BEPS impact under the GEC.
Find out how private wealth structures are developing in Thailand. |
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| International Assignments |
| Tuesday, 26 August, 2:00 – 3:00 PM HKT (GMT +8) | |
Global Employment Companies: Old Vehicle, New Driver? Global Employment Companies (GECs) have been around for a while, but in the past their creation was often a vehicle for global talent management and maintaining equity among assignees. Now the business drivers for setting up a GEC are more focused on the corporate issues associated with a mobile employee population rather than the needs of the employees themselves. We'll discuss: - What is a GEC and how are they structured, including any
GST / VAT implications. - The latest business drivers for implementing GECs.
- The latest worldwide attention to BEPS impact upon the GEC.
- The PE issues associated with GECs.
- Examples of GECs including best practices and service delivery models from specific countries in Asia Pacific – Singapore and India.
Discover why GECs remain an enduring and attractive structure for handling mobile employees. |
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| Indirect Tax |
| Thursday, 28 August, 2:00 – 3:00 PM HKT (GMT +8) | |
Malaysian GST in April 2015: Final Preparations As the Malaysian Government and businesses get into the final flush of preparations for GST in April next year, it is important to find out about the latest developments in law, regulations, guides, and practice in this fast changing area. What should Malaysian businesses be doing in the 6 month countdown to April 2015? We'll discuss: - The latest rules.
- How industry bodies are getting on with clarification requests of Customs and the Ministry of Finance.
- Case studies and the latest thinking on GST implementation approaches or methodologies.
Find out what Malaysian business should be doing to prepare for the introduction of GST in Malaysia. |
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| International Tax |
| Thursday, 11 September, 2:00 – 3:00 PM HKT (GMT +8) | |
Inbound Investment into Japan: The Road Ahead Japan's ruling party continues to look to tax reform as a way to support its efforts to engineer sustainable economic growth. Pushing on the one hand for tax incentives and a reduction in the headline rate of corporation tax, the government must also decide whether to proceed with its plans for a second hike in the consumption tax rate from 8% to 10% in October 2015. But what will the impact of these proposals be for companies and individuals? We'll discuss: - The impact of the consumption tax hike in April 2014 and the increase planned for next year.
- BEPS and the potential impact of Japan's response.
- Recent tax audit experience and focus in respect to inbound investments.
- Highlights on what to expect in Japan's 2015 tax reform.
Gain valuable insights on the latest Japan tax issues – what to expect and how to prepare. |
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| Transfer Pricing |
| Thursday, 18 September, 2:00 – 3:00 PM HKT (GMT +8) | |
Profit Split Analysis and the Role of Intangibles, Capital, and Risk The profit split method is receiving renewed attention as tax authorities look to apply this method in innovative ways to challenge existing transfer pricing methodologies. The OECD's BEPS initiative is likely to provide added impetus to this trend, especially in the context of location savings, hard to value intangibles, and transactions that rarely occur between third parties. We'll discuss: - The regulatory foundations for the application of this method.
- The economic foundations of this method including the role of intangibles, capital, and risk.
- Some recent approaches taken by tax authorities – for example, functional profit split.
- Guarding against formulary or subjective approaches
Explore important details of this rapidly changing area of transfer pricing and recent developments. |
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| Industries – Energy & Resources |
| Tuesday, 23 September, 2:00 – 3:00 PM HKT (GMT +8) | |
Oil & Gas in Myanmar: Issues, Challenges, and Opportunities Myanmar has attracted significant interest from foreign investors as it has the 10th largest gas reserves in the world plus significant oil reserves – most of which remains largely unexplored. Moreover, oil and gas has been identified by the Myanmar Government as a focus industry to drive national economic progress. What should you know as an international company interested in delving into this market? We'll discuss: - New social and economic reforms that have allowed for more international companies to enter this market.
- Oil and gas developments.
- Key tax incentives and regulatory matters such as Production Sharing Contract (PSC) with Myanmar Oil and Gas Enterprise (MOGE) and Foreign Investment Law (FIL) with Myanmar Investment Commission (MIC).
- Practical tax strategies including appropriate holding company locations to minimize Myanmar tax exposures for investing into this market.
Gain insights on the latest oil and gas developments in Myanmar. |
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| Indirect Tax |
| Tuesday, 30 September, 2:00 – 3:00 PM HKT (GMT +8) | |
Managing the Continuous Evolution of China's VAT Reforms: Theory vs. Reality Since the pilot reform program was introduced in Shanghai on 1 January 2012, the Chinese National VAT Reform has been introducing significant changes to the old VAT and business tax regimes. Taxpayers have witnessed continuous policy changes and implementation challenges. Although the planned completion date of the reform, the end of 2015, is only 18 months ahead, there are many sectors to be covered in the reform. What are the latest changes and what is expected in the next batch of changes? We'll discuss: - Announcements for the latest sectors, including the telecommunications industry announcement in early May 2014.
- Developments in the implementation of the reform including the exemption of cross-border services.
- Practical steps to be taken by businesses, suppliers, and customers to handle the new reality of China's VAT system.
Understand the latest changes and developments in China's National VAT reform and how you can address them. |
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