Deloitte Touche Tohmatsu Limited | Dbriefs Asia Pacific | 5 October 2015
| Reach new heights Dbriefs Asia Pacific Tax Webcasts Join us for these upcoming webcasts |
Dbriefs Legal helps you stay on top of all the legal issues for your day-to-day activities and corporate life events. For more program details, click here.
International Tax
Base Erosion and Profit Shifting (BEPS): The Final Reports (Part 1: Transfer Pricing)
Wednesday, 28 October, 11:00AM – 12:00 PM HKT (GMT +8)
With the publication of the final BEPS reports in early October, it is now time to consider the significant changes to transfer pricing (both technical and practical) which have been described in the reports. In particular, it is time to focus on the big "judgement calls" which the OECD has made in finalizing the reports. Our discussion will include:
· Allocation of risk between related parties: contracts versus conduct.
· Intangibles.
· Cost contribution arrangements.
· Fragmented activities.
· Transfer pricing documentation: Country-by-Country Report, Master File, Local File.
· "Adoption" of the changes by individual countries: issues and challenges.
· "2016 issues" – in particular, profit splits.
Find out the important changes to transfer pricing which have been described in the BEPS final reports.
International Tax
Base Erosion and Profit Shifting (BEPS): The Final Reports (Part 2: Non-Transfer Pricing)
Wednesday, 4 November, 2:00 – 3:00 PM HKT (GMT +8)
With the publication of the final BEPS reports in October, it is now time to consider the significant recommendations (in regard to non-transfer pricing topics) which have been described in the reports. In particular, it is time to focus on the big "judgement calls" which the OECD has made in finalizing the reports. Our discussion will include:
· Action 2: hybrid mismatch arrangements.
· Action 4: interest deductions.
· Action 6: treaty abuse.
· Action 7: PE definition.
· "2016 issues".
Find out the important changes to non-transfer pricing topics which have been described in the BEPS final reports.
Transfer Pricing
Recent Learnings from Advance Pricing Agreement (APAs): China and India
Tuesday, 17 November, 2:00 – 3:00 PM HKT (GMT +8)
Transfer pricing controversies are growing and tax authorities are adapting their APAs for the increased caseload. We will discuss the key learnings from recently concluded APAs in China and India:
· Accepted TP methods and specific adjustments by function and industry.
· Some accepted approaches for dealing with location specific advantages.
· Deviations from historical globally accepted approaches.
· Best practices for speedy bilateral resolution.
· Bilateral and multilateral APAs.
Stay up to date with these latest developments on APAs in these two countries.
Indirect Tax
Recharges, Disbursements, and Reimbursements:
Indirect Tax Field of Dreams or Minefield?
Indirect Tax Field of Dreams or Minefield?
Thursday, 24 November, 2:00 – 3:00 PM HKT (GMT +8)
Recharge of expenditure or costs from one entity to another entity is a globally accepted practice and is used to accomplish various objectives. They come under increasing scrutiny given the BEPS developments and changes in Transfer Pricing requirements. What does this mean for Indirect Tax purposes? Are such charges within the scope of Indirect Tax – do you charge VAT or GST? Is a tax invoice required, and if so, what needs to be on the invoice? Is there a tension between Direct Tax / Business Tax and Indirect Tax here?
We'll discuss:
We'll discuss:
· Recharges, disbursements, and reimbursements – experience in Asia Pacific.
· Nature of typical inbound and outbound recharges.
· Typical indirect tax issues and guidelines – Singapore, Malaysia, and India in particular.
· Case studies on some of the practicalities.
Gain a better understanding of the potential impacts and get input on devising an appropriate strategy and process..
Transfer Pricing
BEPS: Implementation of Transfer Pricing Changes
(Part 1: Australia, Japan, China, and Korea)
(Part 1: Australia, Japan, China, and Korea)
Thursday, 26 November, 2:00 – 3:00 PM HKT (GMT +8)
As the OECD / G20 BEPS project has moved into the implementation phase, we will provide an update of domestic legislative activities and timelines to incorporate the various BEPS transfer pricing changes into specific domestic tax regimes. We will also cover harmonization efforts for transfer pricing documentation rules and requirements from local perspectives. In this Part 1 webcast, our focus will be on Australia, Japan, China, and Korea. We'll discuss:
· Changes to the OECD's Transfer Pricing Guidelines (TPG): will they be applied by the respective countries?
| Accountancy Age | Advisory Update |
The Big Four have rebuilt their consultancy arms. But what cost to their traditional accounting practices? Asks Liz Loxton |
 |
Competition and Markets Authority (CMA) provides advice to help accountants warn clients of competition rules
 |
Trustee and compliance advisory business Competition Rx snapped up by Mazars
 |
Simon Collins reiterates KPMG's commitment to audit market despite business lines being overtaken by consultancy
 |
Haines Watts to run the finances of AIM-listed leisure business, as its part-time CFO leaves to focus on other work
 |
EY acquires digital design consultancy Seren as firm continues to expand beyond traditional accounting services
 |
Many smaller practices have ramped up to deal with auto enrolment for clients, while others are taking a more tentative approach, Accountancy Age research finds
 |
KPMG continues to build its advisory expertise with sector-focused consultancy acquisition
 |
Drivers behind the Big Four's deal rush, and the real challenge now is the above radar deals, reveals Margaret Cameron-Waller, M&A lead from Source Information Services
 |
As the firm prepares to mark its centenary in 2019, Lee is on the cusp of celebrating his own major company milestone - amassing a solid quarter century of continuous service
 |
Baker Tilly acquires Outperform UK to broaden its offering in portfolio management support
Govt. proposes FDI policy simplification, faster FIPB nod; Google files patent for glass holograms
Quashes summons against Religare directors for Accounting Standards non-compliance as 'hopelessly time-barred'
HC quashes summoning order passed by Additional Chief Metropolitan Magistrate against Religare Finvest Ltd.'s Managing Director, Company Secretary, Ex-Wholetime Directors and Directors ('Petitioners') on complaint filed by Registrar of Companies (ROC) for violation of Sec. 211(3A), (3B) and (3C) of Cos. Act, 1956 read with AS – 16 and AS – 26; Notes the fact that show cause notice was issued to Petitioners for non-disclosure of capitalization of borrowing costs, computer software, and certain classes of intangible assets in Balance Sheets for 3 Financial Years, observes that Regional Director submitted its report (confirming the allegations) on June 24, 2013, however the complaint was filed by Registrar of Companies before the Magistrate on Sept. 18, 2014; HC accepts petitioners' contention that offence u/s 211 of Cos. Act is not a continuing offence and is complete the moment Balance Sheet is issued by co.; HC holds that u/s 469 (1) (b) Cr.P.C. the limitation period of one year commences when actionable knowledge was gained by competent authority (i.e. ROC), rules that "complaint which was filed on 18th September, 2014 was hopelessly barred by limitation"; HC rejects ROC's submission for excluding time period taken by Regional Director / Central Govt. in taking decision to direct ROC for launching prosecution under Cr.P.C., states that "there is no provision under the Act whereby any consent/sanction of the CG is required for prosecution of the offences u/s 211(7), 211(3A), (3B) and (3C) of the Act and therefore the complainant cannot take shelter of Section 470 (3) Cr.P.C. for exclusion of such time taken by the CG to give instructions to the ROC":Delhi HC
The order was passed by Justice Manmohan Singh.
Senior Advocates Aman Lekhi, S. Ganesh, Advocates Anirban Bhattacharya, Gauhar Mirza and Sukriti Mago argued on behalf of Petitioners, while Advocates Ajay Digpaul, Rishika Katyal for UOI along with Ms. Aparna Mudiam, Assistant Registrar of Company in person represented respondents.
__._,_.___
No comments:
Post a Comment