Latest Developments on Pillar Two in the Asia-Pacific Region
Description
Date & Time:
August 23, 2023
8:00 AM - 9:30 AM IST (New Delhi)
9:30 AM - 11:00 AM WIB (Jakarta)
10:30 AM - 12:00 PM CST (Beijing)
11:30 AM - 1:00 PM KST (Seoul/Tokyo)
12:30 PM - 2:00 PM AEST (Sydney)
In October 2021, close to 140 countries in the OECD’s Inclusive Framework agreed to major building blocks for a new global tax framework called BEPS 2.0 rules. These are divided into two parts: Pillar One and Pillar Two. This webinar will focus on Pillar Two in the context of countries in the Asia-Pacific region, namely India, South Korea, Indonesia, China, and Australia.
Our subject matter experts will first explain the basic building blocks that comprise the Pillar Two model rules and outline the implementation progress in various countries in the APAC region. They will then debate the future of various tax subsidies and incentives frequently used by countries in the region in order to attract foreign direct investments, such as special economic zones, tax holidays, industry and activity-based tax incentives, R&D incentives and others.
With all this in progress, the speakers will highlight the areas that multinational corporations should be thinking about: From group structure, and IP holdings, to global supply chains, process and system upgrades need to manage Pillar Two compliance.
Please join us for a timely discussion on how your business can prepare for the changes to come and how you can manage new compliance and reporting requirements.
Learning Objectives:
- Outline the basic components of Pillar Two
- Understand the timelines of implementation in Asian countries
- Discussing the impact of BEPS on future of various existing tax incentive systems
- OECD guidance on the Globe Information Return
- Comprehend how currency volatility as well as region-specific circumstances might influence the implementation of Pillar Two in APAC
- Potential controversy arising out of Pillar Two
Who would benefit most from attending this program?
- Multinational corporate tax professionals
- Corporate tax attorneys/counsel, CPA’s/accountants
Mukesh Butani
- Founder & Managing Partner
- BMR Legal (India)
Mukesh Butani specialized in domestic corporate international tax and transfer pricing, and has over three decades of experience in advising multinationals and Indian conglomerates on a wide range of matters relating to FDI policy, business re-organizations, cross-border tax structuring, tax controversy and regulatory policy across a range of sectors. He has led International Tax & Transfer Pricing practice for 2 of the Big 4 firms and was co-founder & tax practice leader of BMR Advisors, a leading tax & transaction advisory a firm which transitioned into big 4 firms in 2017. Immediately, after qualifying as a chartered accountant, he spent most of his professional life with Arthur Andersen wherein he became a national partner in 1995 and a partner in Andersen worldwide firm in 1998. Mukesh has participated in many committees of the Indian government & deposed before them on a host of tax issues pertaining to e-commerce, APA, safe harbor, GAAR, indirect transfers tax and in particular, the Kelkar Task Force Tax Reforms (2002) & Tax Administrative Reforms Commission (2013). He is often called upon by Indian policy makers including in particular by NITI Aayog and Prime Ministers Economic Advisory Council on Income-Tax and GST policy matters.
Flora Fan
- Of Counsel
- Jones Day (Beijing)
Flora Fan is a tax advisor with a demonstrated history of serving clients in various sectors, especially in the energy, natural resources, life science and infrastructure industries. Flora advises foreign investors on holding structures and operation models with a view to realizing enhanced tax-efficient outcomes and in navigating China's complex regulatory and foreign exchange environment.
Flora regularly advises multinational corporations (MNCs) and state-owned enterprises (SOEs) on international tax and regulatory implications regarding cross-border transactions and restructuring planning. She also provides supply chain planning to help MNCs minimize their China transactions tax costs, including value-added tax, customs duty, and consumption tax.
Seema Kejriwal
- Partner
- BMR Legal (India)
Seema Kejriwal is a Partner in BMR Legal, specializing in international corporate tax and transfer pricing with over two decades of experience in advising Fortune 500 multinationals and large Indian business houses. Seema focuses on advisory, policy, transaction due diligence and litigation in international tax and transfer pricing matters. She has worked with Big 4 firms, including India and the US, and across industries such as FMCGs, Financial Services, Pharmaceuticals, Shipping, Energy, Chemicals & Utilities, etc. Seema has co-authored several contributions in transfer pricing compendiums and books by leading organisations and authors, such as Vienna University’s publication on Transfer Pricing Developments Around the World. She regularly speaks at global seminars such as IFA, Pacific-Rim, contributes to research papers and columns on tax and transfer pricing policy.
Tom Kwon
- Senior Foreign Attorney and Co-head of International Tax Practice
- Lee & Ko (South Korea)
Tom is the Co-head of Lee & Ko’s International Tax Practice. He advises Korean and foreign companies, investment funds and other investors on tax matters. He practices primarily in international tax and M&A tax, including inbound and outbound acquisition structuring, financing, reorganization, cross-border transactions and offshore/onshore fund formation and structuring from tax perspective. Tom’s practice also involves advising clients on tax controversies and disputes as well as matters involving investor’s protection. Tom has over 20 years of international tax experience in Korea and in the U.S. Prior to joining Lee & Ko, Tom was a director in Deloitte’s M&A and International Tax Group. Tom has been involved in many of the major transactions (both buy and sell-side) in Korea for foreign and Korean investors, including private equity funds, since 2008.
Tom is a member of the International Bar Association, the International Fiscal Association Korea, the Inter-Pacific Bar Association and the American Chamber of Commerce in Korea.
Tom has been recognized as a “national expert” in Korea and recommended for International Tax by Global Law Experts (GLE).
Ichwan Sukardi
- Head of Tax
- RSM (Indonesia)
Ichwan is a Managing Partner and Head of Tax in RSM Indonesia with more than 25 years of experience. Ichwan spent most of his career with the Big Four public accounting firm and also experienced in the largest oil and gas listed company in IDX in 2012-2015.
Ichwan has been providing tax advisory to a wide range of multinational and domestic companies. Ichwan is experienced in a range of international tax issues, including tax treaties, international transfer pricing, tax structuring and international tax planning.
Ichwan is the engagement partner for some leading international clients about tax advisory, restructuring, tax disputes, and other strategic advice. Ichwan led the global tax re-structuring project of some high-profile multinational companies. He led some high-profile Merger and Acquisitions in various sectors with primary services of Due Diligence, Tax Structuring, and Sales and Purchase Agreement drafting and negotiation.
John Walker
- Partner
- Baker McKenzie (Australia)
John has been a partner at Baker McKenzie for almost 20 years, and head of the tax group for most of that time. John has held a variety of global, regional and local management roles and is a former member of the Firm’s Management Committee. John is widely recognized as one of Australian leading tax lawyers, including in various editions of the Australian Financial Review’s Best Lawyers, Chambers Asia Pacific, APL 500, Euromoney's International Tax Review's World Tax and the Tax Directors Handbook and was last year’s Lawyers Weekly Tax Lawyer of the Year. He writes and teaches broadly, and is currently a lecturer in the Sydney University LLM program and a writer for Thompson’s loose leaf income tax service and the author of Bloomberg Tax Management Portfolio: Business Operations in Australia. He is also the head of the Firm's Structured Assets group in Australia, which incorporates the Tax, Financial Services, Commercial Real Estate and Hotels, Resorts & Tourism groups.
John McManus (Moderator)
- Practice Lead – International Tax
- Bloomberg Tax
John manages the Bloomberg Tax Analysis & Content group that focus on technical tax issues and developments impacting U.S. companies with international business operations. John is a former public company tax director, as well as a managing director in a Big 4 international tax firm, and has extensive experience on a wide range of business tax issues impacting both large and small corporations.
