The attribution of profits to permanent establishments (PEs) is gaining complexity in India, with the Indian tax authorities often taking diverse and aggressive stand on attribution approach. This has resulted in significant tax litigation in India culminating in varied judicial precedents.
Though India has a comprehensive tax treaty network and transfer pricing regulations based on OECD framework, unfortunately the close connection between PE attribution and transfer pricing has not been clarified in judicial rulings in the past, up until very recently when a Tax Tribunal emphasised the need to have a transfer pricing analysis for profit attribution purpose. At the same time, due to lack of concrete administrative or procedural guidance, India’s tax authorities are reluctant or hesitant to consider PE attribution issues based on transfer pricing fundamentals. This results in significant tax risks for taxpayers on account of PE exposure in India.
In this webcast, experts from PwC will discuss some of the recent judicial rulings in India on this issue and best practice approaches that can be adopted by taxpayers to deal with the issue of attribution of profits to PEs.
PwC Speakers: Rahul K Mitra (Executive Director and National Leader - Transfer Pricing) and Ajay Kumar (Executive Director and National Leader - Tax Markets)
International Tax Review: Ralph Cunningham
RecordedOct 13 2011101 mins
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Hosted by ITR and TMF Group, the live webinar will take place on June 30 at 1pm BST (2pm CEST).
The paradigm shift in our current economic climate calls for the digitalisation of tax administration. The digitalisation agenda of tax authorities will be advancing over the next few years and pressure mounts on businesses implementing ERP systems. The right configuration of ERP systems is more crucial than ever.
TMF Group's Head of Global Accounting and Tax Consultancy, Csaba Farkas, will discuss the current digitalisation trends and the ERP configuration challenges ahead such as local accounting and tax compliance issues as well as the race for talents skilled in ERP localisation.
Join ITR and TMF Group on June 30th at 1pm BST to learn more about the digitalisation of tax administration and its impact on ERP configuration.
In association with Vertex Inc, the live webinar will take place on June 22 at 2pm BST (3pm CEST / 9am EDT).
Given today’s trends of real time reporting, authorities increasingly require more granular data when filing reports – and there is a real need to collate, validate and submit accurate information in the right format.
A manual spreadsheet-based approach to preparing VAT/GST filings is labour-intensive, with an increased chance of errors, missed deadlines and potential penalties. Likewise, companies who manage VAT/GST compliance manually in-house face growing costs to keep up with the changing compliance requirements. There could be a tailor-made solution.
Join Vertex Inc’s Ellen Van Daal and Thermo Fisher Scientific's Daan Jansen on a webinar to learn more about:
(1) How global businesses can automate their compliance processes using tax technology;
(2) How Vertex VAT Cloud Compliance solution can help analyse, validate and transform your data into actual electronic submission to the tax authorities; and to
(3) View a live demo of the solution.
The 1-hour webinar at 2pm BST (3pm CEST / 9am EDT) will be moderated by ITR’s Prin Shasiharan. The webinar will be followed by a Q&A session.
Hosted by ITR and KPMG China, the live webinar will take place on May 27 at 10am London time (5pm Beijing time).
China started to pilot electronic tax invoices for B2C transactions as far back as 2013 and has made significant progress in the meantime. Recently, China announced a nationwide rollout of electronic invoices to B2B transactions starting from 2021 and to be completed by 2025. Therefore, electronic and paper invoices will circulate in parallel for the next three to four years.
Electronic invoices are expected to create both cost saving opportunities for businesses through a reduction in manual invoicing processes, and allow businesses to accelerate the digital transformation of their business-finance-tax ecosystems.
In parallel, ever more large enterprises are digitalising their tax risk management. Enterprise tax digitalisation involves the integration of invoice management, tax compliance, tax management reporting and tax risk monitoring, and requires comprehensive tax knowledge and complex analytical procedures.
In response to the needs of enterprises, KPMG has specially gathered experts in tax, management consulting, IT advisory and other aspects to set up a ‘tax transformation services’ team to support customers on their path to vastly improved tax risk management.
In this session, KPMG experts will share their insights on China e-invoice and tax digitalisation developments, and how to get ready for the resulting business transformation.
Hosted by ITR and TMF Group, the live webinar will take place on March 24 at 2pm GMT (3pm CET / 10am EDT).
Companies who are looking to consolidate and centralise their finance and accounting functions typically have in mind a few goals such as process standardisation and efficiency, cost savings, and more relevant business insight. While the benefits are many, there are also challenges that need to be considered and addressed. One of the most common challenges refers to the management of local compliance requirements. While certain knowledge can be centralised, the local expertise cannot be built and maintained centrally.
Setting up shared service centres (SSCs) can help companies save money and operate more effectively. However, the pros should also be weighed against the cons.
Join Emine Constantin, global head of accounting and tax at TMF Group, to learn more about the pros and cons of moving to a shared service centre environment.
Jon Moore, Editor World Tax and World Transfer Pricing
Join editor Jon Moore for this exclusive webinar to learn more about the research process for World Tax and World Transfer Pricing 2022.
What to expect:
1. Preview of the 2022 questionnaire.
2. Research guidelines / timelines for surveys and interviews.
3. How firms are selected / ranked.
4. Best practice for completing submissions and client lists.
Juan Frers, director of the Worldwide TaxNet, discusses the new laws coming into effect in various countries across the Latin America region, offering practical insight for technology companies and the advisors who serve them.
Angelika Thies, Xavier Daluzeau, Annabelle Bailleul-Mirabaud, Finn Fechner
The Covid 19 crisis has impacted businesses in several respects: in many cases with the reduction of their profitability, changes in the working conditions of their management and teams via the use of digital tools or negotiation of financing to overcome the crisis.
Now multinational groups may need to consider a restructuring of their operations (taking into account relocation opportunities) and a review of their transfer pricing policy, a better identification of the places where the management or activity is performed or a refinancing of their operations.
Besides, in the near future, many new or potential rules are expected to modify the taxation of the digital industry (and could possibly affect other industries).
This webinar will address these post-Covid 19 tax challenges and, in particular, discuss the following:
1.Corporate tax challenges in the context of business restructurings / reorganizations:
Use of tax losses by reorganizing the group
Transfer tax issues
Nexus approach and IP utilization
2.Transfer pricing aspects 2021:
Remuneration of routine entities
Transfer and remuneration of intangible assets
3.Potential impact of home office on the places of management or establishments of multinational groups:
OECD analysis proposed in April 2020
Applicability in 2021?
Will the concepts of permanent establishments and effective place of management survive to the sanitary crisis ?
4.New tax environment for the digital industry:
Update on the works at OECD level
Implementation of a digital services tax in a number of countries
Potential new obligations imposed by DAC 7 on digital platforms
In association with KPMG China, ITR will host a live webinar on October 21 at 9am GMT / 10am BST / 5pm CST.
Multinational enterprises (MNEs) have had much to consider for their tax functions in 2020, amid widespread economic and digital change.
China, the world’s second largest economy, has observed a trend of increasing business restructuring. MNEs have actively sought to re-align their China operations with their group’s value chain transformation.
Register to listen to Patrick Lu, partner of KPMG global transfer pricing services, shed light on how MNEs could further improve operational and tax efficiency via value chain re-imagination.
The 60-minute webinar will be moderated by ITR's Prin Shasiharan. The webinar will be followed by a Q&A session.
ITR and Vertex Inc will host a live webinar at 3pm CET / 2pm BST / 9am EST on Tuesday, October 20 to discuss the advantages of tax automation in SAP S/4 HANA, and discover how to improve accuracy and efficiency across your tax and IT processes.
The migration to SAP S/4 HANA provides a unique optimisation opportunity for both tax and IT but also a range of challenges. A problem shared is a problem halved.
For IT, when considering work across multiple jurisdictions, product groups and frequent changes in legislation, there is a challenge to maintain the numerous tax customisations and condition records when rebuilding these in SAP S/4 HANA, where there would be a more effective solution.
For tax, the migration provides a unique opportunity to regain control over indirect tax processes and harmonise settings, controls and processes globally.
The solution could be to add a Vertex tax engine. But how do tax and IT work together towards this solution?
Join our webinar at 3pm CET / 2pm BST / 9am EST on October 20 to learn more about the advantages of tax automation in SAP S/4 HANA, and on how to improve accuracy and efficiency across your tax and IT processes.
Richard Asquith, VP - global indirect tax, Avalara
As the Brexit transition period comes to an end within just a few months' time, what chance is there of a trade deal being struck? What will it look like, and will it be meaningful?
Topics to be discussed:
+ Progress on negotiations
+ What has the UK's HMRC already put in place for VAT and customs?
+ What is the EU doing?
+ What are the 10-planning points any business selling goods should take care of?
ITR and KPMG will host a live webinar on Tuesday, September 29 to discuss the most prominent credit and distressed assets opportunities in China.
The impact of COVID-19 on corporate groups’ earnings is in many cases making access to typical lines of credit more difficult. However, from an another viewpoint, this is presenting funds with opportunities to provide alternative financing.
Although investments in single credit opportunities, or portfolios of non-performing loans, may not give rise to immediate tax charges, tax may feature prominently if an investment ultimately turns around. If tax is not addressed at the time of making the investment, unintended tax leakages, on restructuring debt or on eventual exit, can significantly impact the investment’s overall internal rate of return (IRR).
At the same time, consideration needs to be given to how distressed investments are permitted to be made and returns repatriated to investors, since structures used in more sophisticated markets cannot simply be replicated in highly regulated markets in Asia such as China.
In this webinar, Henry Wong and Nigel Hobler of KPMG will discuss the regulatory and tax aspects of the following:
•General regulatory and tax regimes in China;
•Different types of debt investment opportunities in China;
•Offshore and onshore structures and associated tax and regulatory issues involved in acquiring, restructuring and realising investments; and
•Repatriating investment gains to investors.
The 60-minute webinar at 9am GMT (10am London time / 5pm Beijing time) will be moderated by ITR’s Commercial Editor Prin Shasiharan. The webinar will be followed by a Q&A session.
Accounting and tax principles are becoming standardised. However, local differences remain and those requirements must be factored in when a company moves to a shared service centre model.
Companies should also keep in mind that alongside compliance, cross-border variances also impact the cost of doing business and determine the systems and processes to implement.
Join us during this webinar to learn about the issues and challenges related to complexity and local financial compliance.
Emine Constantin and Jessica Nunes will discuss:
•How local GAAP compares with international reporting frameworks; and
•What international companies need to do to adapt group reporting to meet local requirements, and how they can effectively manage these changes.
The 30-minute webinar at 2pm GMT (3pm London time / 10am EST) will be moderated by ITR’s Commercial Editor Prin Shasiharan. The webinar will be followed by a Q&A session.
ITR and KPMG will host a live webinar on Tuesday, July 21 to discuss the business implications of China's development of the Hainan free trade port.
On June 1 2020, the Chinese government released a master plan for policies to support the development of the Hainan free trade port. The aim is to build Hainan Island, on China’s south coast, into a globally-significant free trade port by 2050 that marks a new stage in China’s opening-up.
Policies will be rolled out to facilitate trade, liberalise investment, allow capital to flow freely cross-border, make transit more convenient for people, and ensure the safe flow of data. Improvements to the tax and legal systems will be made to support the development of the free trade port.
In this webinar, Han ShengJian, Director General of Hainan International Economic Development Bureau, and Nicole Zhang, partner-in-charge of Hainan initiatives in KPMG China, will share their insights on the plan for Hainan free trade port and explore how businesses can best seize the new opportunities that will emerge from the development.
The 60-minute webinar will be moderated by ITR’s Commercial Editor Prin Shasiharan. The webinar will be followed by a Q&A session.
ITR and professional services firm TMF Group will host a webinar on July 16 on the tax dimensions of carve-outs, discussing how professionals can plan to successfully implement them in a cross-border setting.
Carve-outs have become increasingly popular among global dealmakers, with a threefold increase in volume since 2016. Post COVID-19, this impetus should continue as a mixture of pent-up demand, distressed and non-core assets, and lower valuations that lure cash-rich private equity firms and corporates back to the deal table.
But what about the accounting and tax aspects of carve-outs?
During this webinar, Emine Constantin, TMF Group’s head of accounting and tax, will tackle the common accounting and tax pitfalls in a carve-out such as:
• Set-up of tax structures: tax registrations and administrative processes;
• Impact on the cost of compliance; and
• Tax compliance processes: main items to be considered.
Broadcast live at 13:30 GMT / 8.30 EDT on Thursday, July 16 2020. Register your place today.
Richard Asquith, VP - global indirect tax, Avalara
As the UK's transition period within the EU Customs Union and VAT regime runs down, negotiations on the future trade relations between the UK and EU are stuttering. Little progress on the major issues has been made, and the COVID-19 crisis has distracted all sides. At stake is the imposition on full tariffs and burdensome VAT compliance obligations if a trade deal is not struck. This webinar summarise the progress on the talks, and what's at stake for businesses in the UK and EU if there is no breakthrough.
This webinar will cover:
- What progress has been made on the talks so far
- What is the timetable and flash points until the transition period ends this year?
- How will the Northern Ireland dual regimes work?
- Is an extension of the Brexit transition a possibility?
- Update on tax authorities’ Brexit planning
- What you should be doing now to mitigate the risks
Luis Carrillo, senior director tax & transfer pricing solutions Bureau van Dijk, A Moody’s Analytics Company
The world is trying to comprehend the implications of a pandemic and associated economic downturn. Multinational companies’ transfer prices, analyses and documentation process are all under review. The BEPS Action Plans are in full force, and the level of transfer pricing scrutiny is high across all markets. Social distancing is affecting current documentation methods that previously involved manual processes and face to face meetings – what impact is all this having on workflow and accuracy?
This webinar will explore why the current situation has heightened awareness of the advantages and necessity of digital and automated documentation practices.
Join this webinar to:
•understand the internal challenges facing businesses in terms of managing TP workflows due to social distancing
•learn how automating TP documentation and management workflows can increase accuracy
•examine how some multinationals are already successfully leveraging technology and tools to facilitate documentation globally