Transfer Pricing Masterclass on Intra-Group Services

Transcription

1 Transfer Pricing Masterclass on Intra-Group Services 27 August 2018 Junior Ballroom One World Hotel Petaling Jaya kpmg.com/my kpmg.com/my

2 Transfer Pricing Masterclass on Intra-Group Services Malaysians are now living in a new era since the Pakatan Harapan Coalition won GE14 on 9th May We have a new Government which, amongst others, emphasizes on the rule of law. In line with this, it is our understanding that tax audits will continue to be a major strategy of the Inland Revenue Board ( IRB ) as they strive to ensure that taxpayers comply with the relevant tax rules. Specifically on transfer pricing, a major focus area in almost all tax audits carried out by the IRB is in relation to intra-group services. Based on our experience, businesses are still unfamiliar with the requirements involved to ensure transfer pricing compliance and meeting the IRB s expectations. To help businesses, we have put together a Masterclass workshop to help you grapple with the associated complexities. Bonus session with our experts on the implications of Service Tax on Intra-Group Services. Workshop Objective In this specially designed masterclass workshop, we will cover the following: What are the different types of intra-group services? How do you characterize intra-group services? How do you describe the nature of services rendered and benefits received? What is the typical basis of charge? We will focus the discussion on cost plus methodology. What costs are chargeable? What are the different types of allocation keys? How to select an appropriate allocation key? Is a mark-up required? If yes, how do I determine the appropriate rate? Should a mark-up be imposed on pass through or third party costs? What source documents should be kept for tax audit purposes? Sharing of practical experiences from our handling of transfer pricing audits.

3 Speaker s Profile Chang Mei Seen Executive Director of Global Transfer Pricing Services, Malaysia Mei Seen joined KPMG in 1997 and is currently an Executive Director in KPMG Malaysia. She began her career by joining KPMG Malaysia s Audit Division where she worked on assignments involving both private and public listed companies. Thereafter, she was transferred to the Corporate Tax Division and was involved in transfer pricing engagements. Professional and Industry Experience Mei Seen advises multinational companies on transfer pricing issues, including preparation of transfer pricing documentation in compliance to the Malaysian transfer pricing guidelines, transfer pricing advisory and planning for risk mitigation as well as involvement in defending clients during transfer pricing audits by the Inland Revenue Board ( IRB ). In addition, she has also been involved in restructuring exercises in various industries. Mei Seen was actively involved in informal discussions to submit the first Bilateral Advance Pricing Agreement ( APA ) applications to the IRB and Mei Seen also provides feedback to the IRB on the typical area of concern which taxpayers may have on APA applications. Mei Seen has project management experience, especially in coordinating and managing a large transfer pricing engagements involving large multinational companies, involving several members of the Global Transfer Pricing Services ( GTPS ) network. Mei Seen s prior experience include corporate tax compliance engagements where she managed a portfolio of clients from a diversified range of industries. Her experience as an auditor has allowed her to better understand the client s business conditions and devise appropriate transfer pricing solutions.

4 Speaker s Profile Ng Sue Lynn Executive Director of Indirect Tax Practice, Malaysia Sue joined KPMG in Malaysia in 2005 and has experience in both corporate income tax and Goods and Services Tax (GST). She advises on Malaysian tax issues and has assisted numerous leading overseas and locally headquartered multinationals. Professional and Industry Experience She is a member of KPMG in Malaysia s GST Strategic team. She has also undertaken a secondment in KPMG ASPAC in Singapore from 2011 to For corporate income tax, her experience includes Malaysian tax advisory and tax planning work in mergers and acquisitions and cross-border transactions (inbound and outbound). She has been involved in numerous engagements on structured financing transactions, which include the review of financial projections and tax assumptions. For GST, Sue has been assisting her clients on GST implementation, advisory, compliance as well as health checks. Her clients come from a diverse range of industries such as plantation, retail, financial services, manufacturing, property and construction. Sue has advised overseas clients intending to invest in Malaysia on the GST implications. Sue has also advised clients on the Price Control and Anti-Profiteering Mechanism as a result of the introduction of GST. Sue is a regular speaker at GST seminars and workshops (locally and internationally), and has authored several GST articles. Who Should Attend Chief Financial Officer or equivalent Finance Managers Tax Managers/Advisors Accountants Workshop Details 27 August 2018 (Monday) 8:00am to 1:00pm Junior Ballroom, One World Hotel, Petaling Jaya Accounts/Finance/Tax personnel

5 Agenda 8:00am - 9:00am 9:00am - 10:30 am Breakfast and Registration Masterclass on Intra-group services 10:30am - 10:45am Tea break 10:45am - 12:15pm Masterclass on Intra-group services (cont d) 12:15pm 12:45pm Service tax implications on Intra-group services 12:45pm 1:00pm Q&A 1:00pm Lunch Registration Form Transfer Pricing Masterclass on Intra-Group Services (27 August 2018) Please mail your completed form and cheque to: KPMG Tax Services Sdn Bhd, 10th Floor, KPMG Tower, No. 8, First Avenue, Bandar Utama, Petaling Jaya, Selangor or fax it to /7388. For online registration, please visit (Please photocopy the registration form for more delegates) Name: Salulation: Organisation: Tel: Postal Address: Designation: Fax: Please indicate appropiately. Alumni member Vegetarian meal For Enquiry Ms. Sharon Leong Peck Sim pecksimleong@kpmg.com.my

6 CPE Certificate of attendance will be issued for 4 CPE hours. Fee & Payment RM500 per participant. 10% discount for registration of two or more participants under the same company or group of companies/kpmg alumni members. Cheques should be crossed and made payable to KPMG Tax Services Sdn Bhd. Amount: Bank: Cheque no.: Registration fee is inclusive of seminar materials, breakfast and tea break. Human Resource Development Fund HRDF application may be made under the Skim Bantuan Latihan, subject to approval by Pembangunan Sumber Manusia Berhad. Cancellation A substitute delegate is welcomed at no extra charge if the registered participant is unable to attend. No refund will be given for cancellations received less than 14 working days before the workshop date. Please note that limited seating is available for this workshop to encourage interactive discussion. Registration is on a first-come-first-served basis. KPMG reserves the right to change the speaker, facilitator, venue, date and to vary/cancel the programme should circumstances beyond its control arise. KPMG also reserves the right to make alternative arrangements without prior notice should it be necessary to do so. You are deemed to have read and understood the terms and conditions upon signing the registration form KPMG Tax Services Sdn. Bhd., a company incorporated under Malaysian law and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ( KPMG International ), a Swiss entity. All rights reserved. Printed in Malaysia. The KPMG name and logo are registered trademarks or trademarks of KPMG International.