Structuring Asian Acquisitions, Reorganizations and Investments

WorldTrade Executive In, January 2007, Pages: 352

Structuring Asian Acquisitions, Reorganizations and Investments, second edition, provides business executives, legal and tax advisors, and strategic planners at leading international firms a map of the tax and regulatory rules of Asia affecting corporate structuring and mergers and acquisitions in a convenient single-volume format. This special report discusses the tools and techniques needed to navigate regulatory obstacles for companies putting together deals in Asia.

Inside, you'll find country-by-country analysis for China, Japan, Korea, Taiwan, Singapore, India, Australia, the Philippines, and Vietnam. This country-specific coverage focuses on regulatory and tax planning that will help your business:

- Successfully acquire domestic companies as a foreign investor
- Establish the optimal holding company structure
- Capitalize on tax incentives and exemptions offered by regional governments
- Determine the tax implications of creating a permanent establishment
- Participate in the region’s growing securitization market

Coverage includes:
- Major Tax Issues for Asian Mergers and Acquisitions
- Utilizing Transfer Pricing as a Strategic Business Strategy
- Australian Corporate Tax Developments
- Building a Tax-Effective Supply Chain in China
- Investing in China
- Outsourcing to India
- New Japanese Limited Liability Partnership Law and its Relevant Tax Treatments
- New Opportunities for Distressed Debt in the Philippines
- Transfer Pricing in Singapore
- New Rules of Taiwanese on Foreign Stock Options
- How Proposed New Unified Company Law in Vietnam Significantly Impacts Merger & Acquisitions

TRANSFER PRICING
Transfer Pricing in the Asia Pacific Region: How do MNC’s perceive the issue?
Philip Anderson (Ernst & Young)
Globalization Increases Complexity of Transfer Pricing:
Tax Directors More Involved in Strategic Planning for Business Change
Ernst & Young

CORPORATE STRUCTURE
Successful Cross Border Transformation:
Balancing Between Tax and Commercial Opportunities is Critical
Helen Fazzino and Pete Calleja (PricewaterhouseCoopers)
Major Tax Issues for Asian Mergers and Acquisitions
An Interview with Guy Ellis (PricewaterhouseCoopers)

AUSTRALIA
Australia as an Investment Location: Reforms Offer New Opportunities for Inbound Investors
Anthony Klein & Norah Seddon (PricewaterhouseCoopers)
Large Businesses and Tax Risk in Australia: The ATO Attempts to Address Concern of Business
PricewaterhouseCoopers
Australia Federal Budget 2006:
Business Tax Measures Include Accelerated Depreciation and Improved R&D Provisions
PricewaterhouseCoopers
Foreign Investment into Australia: A Whole New Ball Game
Peter Collins & Liam Collins (PricwaterhouseCoopers, Melboune)
and Norah Seddon & Mark Hadassin (PricewaterhouseCoopers, Sydney)
Australian Corporate Tax Developments Include:
Foreign Exchange Determinations, Tax Consolidation and Sale/Leasebacks
David Ireland & Ronen Vexler (PricewaterhouseCoopers)
When Does a Non-Resident Consultant Providing Services at Your Premises
Have a Permanent Establishment in Australia: Withholding Tax Exposure Possible
Ken Fehily & Anthony Klein (PricewaterhouseCoopers, Australia)
The Draft Australian Same Business Test Ruling-Will Your Group Pass or Fail?
Paul Abbey (PricewaterhouseCoopers, Australia)

CHINA
Investing in China
Steve Monaghan (Competitive Capital Management Group)
New Tax Law Provides Relief to Investors in Chinese Companies Owned through
U.S. Holding Corporations
Daniel M. Berman and Gerald P. Towne (Thelen Reid & Priest, LLP)
China’s New Draft Contract Law Will Impact International Corporate
Concerns on Sarbanes-Oxley and IP
Meg Utterback (Thelen Reid & Priest, LLP)
China’s Long-Awaited Anti-Monopoly Law Takes Another Step Forward
Rouse & Co. International
Building a Tax-Effective Supply Chain in China with Bonded Logistics Centers
Ernst & Young
PRC Releases Implementation Guidelines on Mutual Agreement Procedures:
Resolution of Cross-Border Tax Disputes Targeted
Ernst & Young
China Tax & Business Update, Part I
Ernst & Young (China)
China Tax & Business Update, Part II
Ernst & Young (China)
China’s SAIC Issues Implementing Opinions On
Registration of Foreign Investment Enterprises
Stanley JIA, Bradley Herrold, Bo Jiang, Zhao Yang (Baker & McKenzie)
New Chinese Rules on Strategic Investments by Foreign
Investors in Listed Companies
Jean-Marc Deschandol and Charles Desmeules (Norton Rose)
New Regulations on the Administration of Foreign-Funded Banks
Baker and McKenzie (China)
Opening the Door to Freer Trade with China
Scott M. Flicker and Hamilton Loeb (Paul Hastings)
Structuring Investments and Operations: China and Hong Kong Update
Neal Stender, Qingsong (Kevin) Wang and Yan Zeng (Orrick, Herrington & Sutcliffe, Hong Kong)
PRC Tax Update 2006
Baker and McKenzie (China_
China’s Foreign Invested Companies Changing and Converging
with Domestically Owned Companies
Neal Stender and Yan Zeng (Orrick, Herrington & Sutcliffe, Hong Kong)
China Amends Foreign M&A Regulations
Baker and McKenzie (China)
2006 Rules Change Landscape For M&A, Offshore
Listings, and Restructurings in the PRC
Thomas M. Shoesmith (Thelen Reid Brown Raysman & Steiner, Shanghai)

INDIA
Business Process Outsourcing in India: When is Permanent
Establishment Created for Foreign Related Entities?
Jayesh Kariya (Deloitte Haskins & Sells, Mumbai)
Liberalized Foreign Investment Regulations in
the Indian Construction Industry
Sachin Kerur (Pinsent Masons)
Indian States are Imposing the Value Added Tax:
An Insight into the VAT in Maharashtra
Keshav Jetsey (K.F. Jetsey & Co., India)
Payment for Credit Rating Services: Controversial Ruling Requires
Tax Withholding in India
Jayesh Kariya (Deloitte Haskins & Sells, Mumbai)
India’s Finance Bill 2006: Major Changes Regarding Taxable Services
Practical Asian Tax Stategies
India Moves Forward with Data Security Proposals
Hunton & Williams
Recent Developments in India: Special Enterprise Zones Advantageous For
Outsourcing Operations-Transfer Pricing Adjustments Exceed USD 800 Million:
An Interview with Dharmesh Pandya
KPMG (New York)
Transfer Pricing in India
George H, Boerger, ESQ., (Practical Asian Tax Strategies)

JAPAN
Amendments Produce Significant Change to Japanese
Withholding Tax Exemption Certificate System
Yokoito (Shin Nihon Ernst & Young)
The New Japanese Limited Liability Partnership Law and its Relevant Tax Treatments
Yasuko Masaki (Shin Nihon Ernst & Young)
Japan’s New Corporation Law: Keys Feature and Potential Tax Implications
Yumiko Arai and Al Zencak (PricewaterhouseCoopers)
Japan Tax Update: Transfer Pricing Release from National Tax Agency
Focuses on Intangibles-Debate on Consumption Tax Increase Continues
Yumiko Arai and Al Zencak (PricewaterhouseCoopers)
The Battle Over Treatment of Intercompany Services
by Japan and U.S. Tax Authorities
Steven D. Harris, Makoto Nomoto and Barbara J. Mantegani (KPMG)
Japan Tax Update 2006
Baker and McKenzie (China)
KOREA
Korea Tax Update
Deloitte & Touche/Hana (Seoul)

THE PHILIPPINES
Invoicing Practices and the Ability to Obtain a VAT Refund in the Philippines:
Different Judicial Views on Invoicing Remain
Sylvia R. Bardelosa-Salvador and Paul Cooper (Isla Lipana & Co.)
(A Member Firm of PricewaterhouseCoopers)
New Opportunities for Distressed Debt in the Philippines: New Law Addresses
the Transfer of Non-Performing Assets to Special Purpose Vehicles
Paul Cooper and Cresencio Meneses (Isla Lipana & Co.)
(A Member Firm of PricewaterhouseCoopers)
The Software Taxation Saga in the Philippines: Is the End in Sight?
Paul Cooper (Isla Lipana & Co.)
(A Member Firm of PricewaterhouseCoopers)
Some Practical Issues for Tax Planning in the Philippines
Paul Cooper (Isla Lipana & Co.)
(A Member Firm of PricewaterhouseCoopers)

SINGAPORE
Singapore Expands/Updates Network of Income Tax Treaties:
Updated Malaysia Treaty Effective for 2007 While New Malta Agreement Reached
Practical Asian Tax Strategies
Singapore Formalizes the Advance Ruling Process: Legally Binding Rulings Available in 2006
George H. Boerger, Esq. (Practical Asian Tax Strategies)
Singapore Creates New Investment Vehicle: Limited Liability Partnership Act Comes into Force
AIAI Wong (Baker & McKenzie)
Transfer Pricing in Singapore: The Arm’s Length Principle
George H. Boerger, Esq. (Practical Asian Tax Strategies)
Transfer Pricing in Singapore: Documentation, Mutual Agreement Procedures
and Advance Pricing Agreements
George H. Boerger, Esq. (Practical Asian Tax Strategies)

TAIWAN
New Rules of Taiwanese on Foreign Stock Options
Peter Ni and Peter Su (Asia Business Group, Ernst & Young)
Taiwan Tax Update 2006
Baker and McKenzie (China)

VIETNAM
Proposed New Unified Company Law in Vietnam Significantly Impacts Merger & Acquisitions
Fred Burke, Dang Unh Chi & Mac Van Nam (Baker & McKenzie)

- K.F. Jetsey & Co., India
- Shin Nihon Ernst & Young
- Isla Lipana & Co.
- Asia Business Group
- Ernst & Young
- Baker & McKenzie

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