On 5 October, the OECD has issued the Final Reports on the BEPS 15 Action points. The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project provides governments with solutions for closing the gaps in existing international rules that allow corporate profits to ‘disappear’ or be artificially shifted to low/no tax environments, where little or no economic activity takes place.
The new policy get immediate attention from all parties all over the world, major multinationals gave close attention on details and interpretation of the provisions. On 16 October, Mazars was invited by Bank of Tokyo-Mitsubishi Shanghai branch to organize a seminar on the new BEPS, in the afternoon, Mazars held another seminar for its Asia pacific clients separately.
Mazars Asia-Pacific regional experts attended the seminar as speakers
During this seminar, partners and senior management from Mazars Shanghai, Mazars Tokyo, Mazars Bangkok and Mazars Philippine office explained new action plan of BEPS from all aspects. The speakers include:
He has rich experience in audit, tax, transfer pricing, restructuring and M&A for Japanese, European and Hong Kong enterprises. He has deep knowledge in banking, service (Media, Hotel), construction and real estate industries.
Yokoyama Noboru: Partner, Mazars Tokyo office
He has more than 30 years’ experience in international taxation and was in charge of finance department for several well know banks worldwide. He specializes in providing transboundary tax planning, M&A, transfer pricing and other tax strategies for Japanese and transnational enterprises.
Koide Tatsuya: Partner, Mazars Bangkok office
He joined Mazars Japan desk in 2008 and has deep knowledge in financial audit and international financial strategy. He specializes in providing professional services to Japanese enterprises from a comprehensive financial perspective.
Kaneuchi Isamu: Manager, Mazars Philippine office
He has a Japan CPA and is Japanese Certified tax consultant. He possess a US CPA and is expert in tax services.
The seminar covers basic points of BEPS
The seminar was hosted by Mazars Shanghai partner Mochizuki Kazuhisa, focusing on the history, outlines, main achievements and potential impacts on taxation of Asia Pacific countries. The key points include:
Background and development of BEPS
Latest achievements of BEPS action plan
Explanation on the 13th topic “Transfer pricing Documentation and CBC”
Impect and solution of BEPS on taxation of Asia Pacific countries – Japan / China / Thailand / Philippine
Mazars China Partner Mr. Mochizuki explaining to the clients
How does China participate in BEPS Action Plan and how to understand the transformation of BEPS at domestic level?
This seminar focuses on the impact of the new BEPS Action plan on Chinese taxation and how does it transform at domestic level. Mochizuki reminded to pay close attention to relevant documents and policies issued by China State Administration of Taxation, which is important to help understand this problem.
The State Administration of Taxation established a G20 tax reform working group, issued work programs, responsibilities, schedule and roadmap to promote this work.
SAT pays high attention on transformation of BEPS achievement. During the past 2 years, SAT issued 4 regulations and normative documents to strengthen anti-avoidance management, such as General anti-avoidance measure and Non-resident enterprises indirect transfer of property management approach. It also added in the 2015 Avoidance of Double taxation agreement between China and Chile, the Anti-Abuse provisions agreement. Recently, the SAT is revising the “Implementation method of special tax adjustment”. This will be the guide of anti-tax avoidance based on the latest achievement of BEPS and China’s actual situation.