Tax Reform: practical considerations for application of the AOA in relation to transfer pricing

Legal/Regulatory  

Event Report

Two experts from PwC provided an overview of the FY2014 tax reform, the details of which were publicized by the government at the end of December. The presentation focused on the introduction of new rules for branch profit attribution, as well as other aspects of the FY14 reform which may be relevant to the banking sector.
 
 
English

Legal/Regulatory

Akemi Kito CPA
Tax Partner – Financial Services, Tokyo
Zeirishi-Hojin PricewaterhouseCoopers

Ryann Thomas
Tax Partner – Transfer Pricing Consulting Group, Tokyo
​Zeirishi-Hojin PricewaterhouseCoopers

 

Two experts from PwC will provide an overview of the FY2014 tax reform, details of which will be publicized by the government at the end of December. The focus of the presentation will be on the introduction of new rules for branch profit attribution, as well as other aspects of the FY14 reform which may be relevant to the banking sector.

Attendees will leave the presentation with:

  • An understanding of the parts of the FY14 tax reform that touch on the banking industry. Depending on the government proposals, this may include one or more of corporate income tax, personal income tax, transfer pricing, consumption tax, withholding tax, or any other incentives or special taxes that may be relevant.
  • An understanding of the practical aspects of the reform in relation to branch profit attribution. PwC will provide guidance on the immediate practical considerations that banks should be prepared for by drawing on experiences from other countries where the branch profit rules have been changed.

 

Akemi Kito is a tax partner in the financial services group of Zeirishi-Hojin PricewaterhouseCoopers Tokyo (“PwC Japan Tax”), with over 9 years of experience dedicated to serving clients in financial services and asset management industry. Her specialties include consulting for financial institutions and on the development of various financial products and funds, e.g., inbound and outbound investment funds, J-REITs, investment trusts, and cross-border securitization.

Ryann Thomas is a Partner in the Transfer Pricing Consulting Group of Zeirishi-Hojin PricewaterhouseCoopers. Since she joined the firm in mid 2001, Ryann has worked exclusively in the transfer pricing area, assisting both inbound and outbound multinational corporations with transfer pricing audit defense, advance pricing agreements, documentation and economic analyses, and risk assessments.