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Hot topics in Asia PacificMay 2015
Dr Veerinderjeet Singh, Taxand Malaysia
Balaji Balasubramanian, Standard Chartered Bank
Sumeet Hemkar, Taxand India
1
1. Introduction
2. New and updated tax treaties
3. Latest rulings on permanent establishments
4. The approach of Asia Pacific governments to BEPS
5. Impact of FATCA on banks/funds in Asia Pacific
6. Maximising tax incentives – recent developments
7. ASEAN & The ASEAN Economic Community (AEC)
Contents
Quality tax advice, globally
Introduction
3
Asia tax environment continues to change rapidly
Becoming more complex
Beneficial ownership
Indirect transfers
Substance requirements
Becoming more uncertain
GAAR, etc
Tax audits are increasingly aggressive
Tighter enforcement of the existing and new tax rules/regulations
Asia tax environment today
4
Beneficial ownership
Anti-abuse legislation to limit treaty benefits
Indirect equity/share transfers
Aggressive tax audits
Competition for FDI
Hot topics
Quality tax advice, globally
New & updated tax treaties
6
Tax treaties – emerging issues
Increased focus of Revenue Administration to
regulate benefit availed under tax treaties
Emerging issues for claiming tax treaty benefit:
Tax Residency Certificates – a pre-requisite
Entity structure (LLP, LLC, etc) whether eligible to
avail benefit
Establishing beneficial ownership
Closer scrutiny of international transactions
Substantive test – whether transaction is tax
motivated
7
Asia Pacific – tax treaties statistics
0
20
40
60
80
100
120
India China Hong Kong Singapore Malaysia Indonesia
Treaties signed till 2012 Treaties signed after 2012
Protocols entered after 2012Basis: Secondary sources
8
Recent developments
Principal recent updates in tax treaties:
Limitation of Benefit (LoB)
Exchange of Information (EOI)
Non-discrimination
Treaty benefit to tax transparent entities
9
LoB - developments
India
China
Hong Kong
Singapore
10
LoB – India developments
Existing tax treaties amended to include LoB
clause - UK and Poland
LoB clause specifically included in the new tax
treaties entered by India
Malaysia, Sri Lanka, Fiji, Bhutan, Albania, Croatia,
Latvia, Malta, Romania
11
LoB – India developments
India-Malaysia Treaty – LoB clause
“1. The provisions of this Agreement shall in no case prevent
a Contracting State from the application of the provisions of its
domestic law and measures concerning tax avoidance or
evasion, whether or not described as such.
2. A resident of a Contracting State shall not be entitled to the
benefits of this Agreement if its affairs were arranged in such
a manner as if it was the main purpose or one of the main
purposes to take the benefits of this Agreement.
3. The case of legal entities not having bonafide business
activities shall be covered by the provisions of this Article.”
12
LoB – India developments
Critical issues
Denial of tax treaty benefit even if main purpose or
one of the main purpose to avoid taxes
Treaty override clause
General Anti Avoidance Rules (under domestic laws)
13
LoB – China developments
New tax treaties entered by China
France, Germany, Russia, Netherlands, Switzerland,
Ecuador
LoB clause include in all new tax treaties
Either as separate clause applicable to entire tax
treaty - France, Germany, Russia, Ecuador;
Or restrictive applied to income streams like dividend,
interest and royalty - Netherlands, Switzerland
14
LoB – Hong Kong developments
New tax treaties entered by Hong Kong
Qatar, Guernsey, Italy, UAE, South Africa and Korea
No LoB clause present in the tax treaty with UAE
and Guernsey
LoB clause in the new tax treaties entered is
applicable to specific streams of income (like
dividend, interest and royalty)
15
LoB – Singapore developments
New tax treaties entered by Singapore
Barbados, Belarus, Ecuador, France, Guernsey, Laos,
Liechtenstein, Luxembourg, Rwanda, San Marino,
Seychelles, Sri Lanka, Uruguay
LoB clause absent in many of the new tax treaties
entered
Tax treaty with Ecuador and France include LoB
clause
16
EoI - India developments
India on account of lack of effective EOI has designated
Cyprus as a notified jurisdiction, thereby
Transactions with Cyprus entity will be subject to transfer
pricing regulations
Deduction of expenses shall not be allowed unless
Authorization for seeking information from the financial
institution is submitted; or
In other case, prescribed information is maintained
Sum received from Cyprus entity deemed to be income –
unless source of income for Cyprus entity is explained
Higher withholding rate @ 30% prescribed for remittance
made to Cyprus entity
17
EOI - India developments
New tax treaties
Malaysia, Malta,
Romania, Sri Lanka,
Latvia, Albania, Bhutan,
Croatia, Fiji
Tax treaties amended
UK, Netherlands,
Poland, South Africa,
Sweden, UAE,
Bangladesh, Brazil,
Denmark, Morocco,
List of tax treaties wherein EOI clause is included
18
Non-discrimination - India developments
Permanent Establishment (PE) of non-residents
shall not be taxed less favourably as compared to
residents
Maximum difference in the tax rate applicable to
PE of non-resident v/s resident prescribed
Poland – 10%
Romania – 15%
Latvia – 10%
19
Tax transparent entities - India developments
India-UK tax treaty
Tax transparent entities (like partnership, trusts)
will be eligible for treaty benefit to the extent of
income derived is taxable in UK either in the
hands of partners / beneficiaries
In the past, Indian courts had upheld that Limited Liability
Partnership firms should be eligible to claim benefit under
India - UK tax treaty
20
Measures for risk mitigation
Substantive test
Commercial rationale behind the transaction entered
Tax treaty benefit should not be the primary motive
Documentation
Tax Residency certificate –to claim tax treaty benefit
Substance test – place of business, operations size,
employees strength, conduct of board meetings
Dispute resolution mechanism
Obtaining Advance Ruling – to achieve certainty
Obtaining legal opinions – to safeguard penal risk
Quality tax advice, globally
Latest rulings on permanent establishments
22
India: centrica – Delhi High Court (2014)
CIOPL
India
Overseas
Centrica Plc
(UK)
Reimbursement -
salary
1
Employees
3rd party
vendor
Quality control services2
3
Shareholding
Transactions
WOS
Facts:
Centrica Plc, a company in the UK
outsourced back office support functions
(eg: debt collection, consumer’s billing, etc)
to third party vendors in India
CIOPL, a company in India, acted as an
interface to ensure third party vendors
meet requisite quality guidelines
CIOPL sought some employees on
‘secondment’ for fixed tenure
Such employees were operationally
working under the control, direction and
supervision of CIOPL
Salary of such secondees was paid directly
by overseas entities and cross-charged to
CIOPL, without any mark-up
Issue:
Whether service PE is created?
3rd party
vendor
3rd party
vendor
23
India: centrica – Delhi High Court (2014)
Held - Act of secondment created service PE
Centrica Plc was real employer of secondees
Seconded employees continued to have ‘lien’ over the employment with home country
employer – following Morgan Stanley principle
Home country employer continued to be liable for employees’ social security
contributions, emoluments, additional benefits, etc during the period of secondment as
per the applicable policies of home country
No documentation to prove that Indian entity was liable to bear salary costs of
seconded employees and that seconded employees didn’t have right to sue the Indian
entity for default in payment of their salary
Original employment relationship was beyond the control of CIOPL
24
India: Brown and Sharpe – Allahabad High Court (2014)
India
US
Facts:
B&S Inc established LO in India to
undertake advertising / marketing activities
LO also co-ordinated commercial activities
like purchase orders, letter of credit,
shipment, discussion on commercial issues
pertaining to contract
Incentive plan for employees was based on
orders generated, which was inadvertently
mentioned in employment contracts
Issue:
Whether LO constituted PE for B&S in
India?
B&S
Inc
LO
25
India: Brown and Sharpe – Allahabad High Court (2014)
India
US
Held:
Activities of LO extended beyond being
channel of communication, hence not an
excluded activity for PE purposes
Whether or not any incentive was, in fact,
paid to employee is not material
Transnational business with range of
advisors – cannot readily be assumed to
commit inadvertent mistake on significant
issues
Income attributable to LO is taxable in India
B&S
Inc
LO
26
Australia: ATO interpretative decision –Australia-Canada DTA (2014)
Australia
Canada
Facts:
C Co deputed a Canadian resident
employee for a period of 4 months to
execute a contract in Australia
C Co also leased out equipment to A Co for
execution of contract
C Co constituted PE in Australia
C Co also entered into agreement with A
Co to provide essential services for the
contract
Issue:
Whether remuneration paid to Canadian
employee would be taxable in Australia?
Whether such remuneration would be
deductible while computing attributable
profits of C Co in Australia?
C Co
A Co
Employee of C Co Equipment of C Co
27
Australia: ATO interpretative decision –Australia-Canada DTA (2014)
Australia
Canada
C Co
A Co
Employee of C Co Equipment of C Co
Held:
Remuneration paid to employee of C Co
would be taxable in Australia
Since, substantial equipment is used in
Australia, income of C Co is attributable to
its PE in Australia
C Co entitled to deduction of expenses
while determining taxable profits in
Australia
Remuneration paid to employees is
attributable to the PE and is allowable as
deduction
28
Changing times: Update on change of PE definition – BEPS influence
on tax treaty
Develop resources and systems for tax risk management
Robust documentation; careful drafting of agreements/ contracts
Seek the help of a tax advisor – needed more than ever
Taxand’s Take
Quality tax advice, globally
The approach of Asia Pacific governments to BEPS
30
Current UN & OECD model tax conventions broadly based on concept
that residual income for global corporate income tax purposes be
allocated to the country of residence of MNEs
Source based tax systems retain right to first tax the income from
underlying activities in the local jurisdiction
Model conventions allow States to reconcile frictions arising from
interactions between tax rules and , to a large degree, achieve
coherence
This thus serve to safeguard fundamental principles of enhancing
cross-border trade, FDI and economic growth while allowing
economies to retain sovereignty over their tax policy in support of their
own social and fiscal policy objectives
Introduction
31
Why BEPS? Response to concern that gaps in current framework
allow an unfair allocation of income between economies and unilateral
measures (due to lack of a concerted and coordinated effort) may give
rise to re-emergence of unresolved double taxation
So BEPS intended to restore source and residence-based taxation to
an appropriate level
Not aimed at changing existing international standards but the
multitude of permutations of possible interactions between BEPS
actions along with unilateral actions already taken by some
economies and potential future unilateral actions may possibly extend
beyond the recalibration of the measurement of source and residence
based taxation----possibility of a threat to the fundamental concepts of
source and residence that have underpinned economic growth,
foreign investment and cross border trade since the 1920s
Introduction
32
Source rules – royalty, service fees, etc
Permanent Establishment Income Attribution
Domicile/ Central Management rules
Beneficial Ownership
Indirect Equity Transfers
Recent developments
33
Why BEPS?
Aggressive tax
planning by
corporates; need
to restore source
and residence-
based taxation to
an appropriate
level
Traditional tax
principles –
unable to tap
modern era
business
environment
Address cross-
border
restructuring in
a co-ordinated
manner
34
Scope of domestic taxation is a matter for domestic tax policy.
Assume that tax policy is to tax all economic activity within a jurisdiction as equally as
possible, subject to:
Economic policies discriminating between activities
Conceptual limits, e.g. definitions under domestic law and internal coherence
Practical mechanisms, e.g. withholding taxes
DTA as an inter-governmental agreement to allocate taxation rights.
Have the fundamental norms changed? Depends
Catalyst for change in domestic rules?
Best practices on economic policies, e.g. treatment of hybrid instruments, interest deduction
rules, CFC regimes, IP regimes. Mandatory or just recommendations?
BEPS recommendations may give momentum to realignment of internal coherence? Depends
on jurisdiction.
Greater transparency and disclosure enabling more effective and practical collection
mechanisms? Unlikely – see Action 1.
BEPS
35
Shift in DTA balance?
Greater subjectivity in PE identification – practical thresholds seem less relevant;
avoidance of bright line rules
Greater subjectivity in profit allocation – TP rules already complex and subjective; if
there is less consistency for crossing source taxation threshold, profit allocation
may also become more problematic, e.g. lack of good comparables
Denial of treaty benefits – BEPS Action 6 provides for options to meet minimum
standard; apparent trade-off between complexity with certainty and flexibility with
subjectivity
Risk of understanding gaps between authorities
Residence relief:
Conceptually, no change. Residence state is obliged to give relief for source state
taxation in accordance with DTA.
If residence state does not agree with source state’s application of DTA, giving of
relief will be to transfer revenue from residence state to source state.
Result will be double taxation unless mutual agreement or domestic law remedy.
BEPS
36
Jurisdictions move to impose tax on what is perceived to
be derived/sourced in the jurisdiction
For example, Malaysia in 1984 created a Special Classes
of Income in domestic law and imposed withholding tax on
technical fees/management services despite the fact that
the non-resident was not carrying on a business in
Malaysia and did not have a PE
Some tax treaties were later amended to include a
technical services article but gaps exist.
Territoriality/ source
37
Approach by Asia Pacific governments
India
Wait and watch approach; may adopt some aspect of
proposals to suit domestic needs
Greater focus on challenges of digital economy
Introduction of GAAR
Re-negotiation of India – Mauritius treaty – LoB
Listing of Cyprus as non-cooperative
Expansion in network of TIEAs
38
Approach by Asia Pacific governments
China
Participates as an Associate Member; strong support to
BEPS
Establishment of task force to study and implement
BEPS result
Administration Plan on International Tax Compliance –
focus on alignment of TP result with value creation,
transparency in TP documentation, revisiting taxation
right of source state in digital economy
Transfer pricing aspect of intra-group services –‘benefit test’
Administrative measures of General Anti-Abuse Rules
39
Approach by Asia Pacific governments
Japan
Expressed strong support to BEPS
Mature tax system including anti-avoidance rules
Priority to Action Plans 2, 3, 8 and 13
Foreign dividend exemption rules
Additional SAAR on income attributable to PE
40
Approach by Asia Pacific governments
Singapore
Aims to retain balance between countering tax avoidance
and maintaining attractive climate for business
Main focus on TP – alignment between allocation of
profits and economic substance
New guide on taxation of hybrid instruments
Averse to ‘one size fits all approach’
41
Approach by Asia Pacific governments
Malaysia
Leverage on TP to align with OECD approach
Deferment of thin-capitalization; no CFC rules & SAAR
42
Approach by Asia Pacific governments
Indonesia
No official reaction to BEPS report; may await final outcome
Proposal – tighter application of thin capitalization rules,
broader application of CFC rules, higher penalties for tax
evasion
43
Fundamental premise: to prevent base erosion/profit shifting. Objective is to protect
taxation in jurisdiction of value creation
Sub-text of fair taxation. Impact of pressure groups and sensationalisation of technical matters.
Outcome would generally strengthen taxation in country of source and prevent profit shifting to
other jurisdictions: for example, Actions 2, 4, 6 and 7.
Unprecedented level of co-operation between tax administrations
Exchange of information
Expect full transparency
Greater reporting and disclosure, e.g. Actions 12 and 13
Multinational endeavour – complexity and compromises
Not possible to align all domestic interests
Some legal systems require more complex rules than others
Some tax administrations may not even need detailed rules
Realistic outcome may be an imperfect compromise
Risk of false expectations of certainty and operational/intention mismatches
Potential impact of BEPS
44
Many jurisdictions are not involved in discussions and the
level of awareness or understanding may not be
consistent
Rules were already complex to begin with, e.g. transfer
pricing guidelines
BEPS recommendations are complex and can be
confusing even for a reader proficient in English/French
Flexibility for acceptability, hence greater subjectivity
Good chance of misunderstanding/misapplication
Limited progress on Action 14
Potential impact of BEPS
45
Likely short-term consequences:
Risk assessment, re-organisation and restructuring by
businesses. Would that in itself be BEPS?
Period of uncertainty: treaty changes, domestic rule
changes, compliance obligations.
Increased number of disputes; unresolved disputes will
result in double taxation.
Likely medium-term consequences:
New norms and acceptable expectations of certainty.
Risk of double taxation should be factored in as
commercial cost for doing business in countries with
less established norms.
Perspective/ outlook
46
Risk for taxpayers
Uncertainty on
outcome of
BEPS project
Tax and
controversy
risk on entry in
new markets
Further
disputes and
instances of
double taxation
- potential
outcome of
uncoordinated
or unilateral
actions.
Quality tax advice, globally
Impact of FATCA on banks/funds in Asia Pacific
48
General FATCA update
Key FATCA Dates
1 July 2014 – Pre Existing Obligations/Accounts
1 January 2015 – Commence Withholding
30 June 2016 – Completion of Onboarding
Reporting Financial Accounts
Scalability of Product offerings in the FATCA
world
Process and system efficiencies
Automated Tools for FATCA implementation
FATCA – impact to banks & funds
49
Inter-governmental agreements (‘IGA’)
Model 1 IGA (eg, Singapore)
Model 2 IGA (eg, Hong Kong)
Withholding on US-sourced FDAP (fixed,
determinable, annual, periodic income)
Eg, Interest, Dividends, Fees, etc
Extra-territorial application of WHT provisions
Increased scrutiny by IRS on compliance with
US laws
US Tax forms and classification of clients
Recalcitrant/ Others
FATCA – impact to banks & funds
5050
Case study
FATCA Financial Account Reporting (Model 1 IGA)
Reporting of Bank accounts in Singapore
Mr Lee worked in the US for 8 years and returned to
Singapore with his family during April 2015. Mr Lee’s
cumulative balances accounts with domestic and
foreign banks exceed US$100,000. Should Mr Lee’s
account balances be reported to the IRAS in
Singapore?
5151
Case study
FATCA Financial Account Reporting (Model 2 IGA)
Reporting of Bank accounts in Hong Kong
XYZ (Cayman) Limited is a 100 subsidiary of a US
incorporated group and has a bank account in Hong
Kong. XYZ is a tax transparent entity. What US Tax
forms should be obtained and how would this
information be reported to the US IRS directly?
Quality tax advice, globally
Maximising tax incentives –recent developments
53
Understand the rationale for the tax incentives
Evaluate the long-term impact of the business
model
Consider home country tax/ political and supply
chain tax issues
Choose the appropriate tax incentives
Pragmatic tax incentives – ie, pre-approved
projects
Could lead to subjectivity
Maximise tax incentives
5454
Case study
Wind Energy Tax incentives in India
Choosing the appropriate tax incentives
There is a 10-year tax holiday for wind energy
generation units. In addition to the tax holiday, there
is also an additional tax incentive in the form of
accelerated depreciation (@80%). In lieu of the
accelerated depreciation, there is a Generation
Based Incentive. What should be the choice of the
CFO in presenting financials for Project Financing?
5555
Case study
Tax Incentives in Malaysian Budget 2015
Principal Hub Incentives
International Trading (Malaysia) Sdn Bhd has been
set-up to trade in commodities and manage supply
chain risks for the Australian group’s ASEAN
business. The auditors have requested for a tax
evaluation of the ASEAN supply chain model
56
The Malaysian Government announced in its 2015 Budget that a new
customised Principal Hub incentive would be introduced, making
Greater Kuala Lumpur more compelling for MNCs to locate their
Asia/ASEAN Principal Hub
The new incentive was developed in recognition of the changing
regional headquarters trends, global supply chain models and also with
the upcoming implementation of the ASEAN Economic Community
(AEC)
Malaysia- principal hub incentive framework
57
MNCs establish Principal Hubs to maximise operating efficiency,
improve quality and speed at lower cost. By centralising strategic
global/regional intangibles, functions, activities, risks, and their
associated revenue streams, a Principal Hub provides better sharing of
resources, services (such as management, R&D, payroll, accounting,
logistics and quality control), technology and commercialisation of
products
Akin to a control tower, the Principal Hub serves as a regional nerve
centre for decision making where critical operational, management and
legal functions are located
Malaysia- principal hub concept
58
A locally incorporated company that uses Malaysia as a base for conducting its regional
and global businesses and operations to manage, control, and support its key functions
including management of risks, decision making, strategic business activities, trading,
finance, management and human resources
Definition of principal hub
59
Benefits of an approved principal hub: Tax Incentives
Benefits of an approved principal hub : Non-tax Incentives
Bring in raw materials, components or finished products with customs duty
exemption into free industrial zones, LMW, free commercial zones and bonded
warehouses for production or repackaging, cargo consolidation and integration
before distribution to its final consumers for goods-based companies
No local equity / ownership condition
Expatriate posts based on requirements of applicant’s business plan subject to
current policy on expatriates
Foreign Exchange Administration flexibilities will be accorded in support of business
efficiency and competitiveness of companies under the Principal Hub
Principal hub incentive framework
60
Local incorporation under Companies Act 1965
Paid-up capital of more than RM2.5 million
Minimum annual sales of RM300 million (applicable only to goods-
based applicant company)
Serve and control network companies in at least three (3) countries
outside Malaysia
Carry out at least three (3) qualifying services, of which one (1) of the
qualifying services must be from the strategic services cluster as
follows:
Strategic Services
Business Services
Shared Services
Eligibility criteria for principal hub incentives
61
Eligibility criteria for principal hub incentives
Quality tax advice, globally
ASEAN & The ASEAN Economic Community (AEC)
Quality tax advice, globally
Taxand’s Take
64
Keep your ears to the ground on BEPS initiatives and local
developments
Be prepared—have to be nimble on your feet!
Substance, substance & substance.....
Scope to maximise on tax incentives is still there in certain Asian
economies
ASEAN Economic Corridor—watch this space!
Taxand’s Take
65
Speaker profiles
T. + 65 9710 9350
T. +603 2032 2799
Singh
Balaji
BalasubramanianBalaji is an international tax expert who has worked in India, Middle East and now
Singapore. Over more than a decade He has advised on inbound/ outbound investments,
renewable & conventional energy projects, tax litigation, tax forensics audits. In his
current role, he is the Global tax lead for Financial Markets – Fixed Income products at
Standard Chartered Bank. In addition to advising on global rules such as FATCA, He
advises business on tax developments in Asia, Africa and the Middle East. Balaji is also
currently the Co-Chairman of the India Sub-Committee of the Capital Markets Tax
Committee of Asia
Dr. Veerinderjeet Singh is a member of the Taxand Board. Veerinderjeet is the
Chairman of Taxand Malaysia, which is Taxand Malaysia Sdn. Bhd Veerinderjeet
has extensive tax experience, having been a tax partner in international accounting
firms and having worked with the Malaysian Inland Revenue Department. He is a
member of the Malaysian Institute of Certified Public Accountants (MICPA), the
Malaysian Institute of Accountants (MIA), the Chartered Tax Institute of Malaysia
(CTIM), as well as CPA Australia. He is a member of the ICC’s Commission on
Taxation based in Paris as well as a member of the Board of Trustees of IBFD in
Amsterdam.
66
Speaker profiles
T. +65 6408 8004
E. [email protected] Hemkar
Sumeet Hemkar is based in Taxand India where he is a Partner with BMR &
Associates LLP and is in-charge of the firm’s Singapore office. He has over 13
years of experience in corporate and international tax
Thank You
6868
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