2019 Asia Pacific Financial Services Tax Conference Confidence through disruption. Agenda 25 February 2019, Singapore

Transcription

1 2019 Asia Pacific Financial Services Tax Conference Confidence through disruption Agenda 25 February 2019, Singapore

2 2019 Asia Pacific Financial Services Tax Conference Welcome to the 2019 Asia Pacific Financial Services Tax Conference. This year s conference includes a series of breakfast workshops to kick-start the day; before we officially start with the Welcome and introduction at 0900hrs. Topic 0745 Breakfast workshops 0900 Welcome and introduction 0915 Plenary: The changing International and Financial Services Tax Landscape 1045 Coffee break 1100 Breakout A 1215 Lunch 1315 Breakout B 1415 Breakout C 1515 Coffee break 1530 Plenary: Controversy: Tax and transfer pricing audit developments across key jurisdictions 1630 Plenary: The tax function: Building a tax operating model for the future 1715 Closing remarks 1730 Cocktail reception Map Level 4, Raffles City Convention Centre `

3 The breakfast workshops are a precursor to the main programme, and are intended to provide participants with a deeper understanding of key topics impacting Financial Services Breakfast workshops Global Information Exchange Efficient compliance This workshop will take stock of current developments in the legislative environment (e.g., OECD Mandatory Disclosure Rules), the expected ramp up in enforcement action and key components for good governance and risk management, including customer experience. Tom Toryanik Tax Director Deloitte Singapore Roy Phan Tax Director Deloitte Singapore Introduction of GST Reverse Charge in Singapore This workshop will involve an examination of the practical and business considerations for financial institutions in making the transition to the reverse charge in Singapore. This will include discussing the different approaches and strategies to implementation, the areas requiring immediate focus and the possible road blocks that can occur. There will also be a wider discussion on input tax efficiencies and cost mitigation strategies that can be considered as a consequence of the change. Tax considerations for M&A in the Middle East This workshop will survey the current tax landscape in the Middle East including: tax reform, impact of BEPS, the introduction of VAT and tax authority attitudes. The discussion will then cover wider M&A trends and the key micro and macro considerations from a tax perspective in the M&A deal process. Richard Mackender, Southeast Asia Indirect Tax Leader Deloitte Southeast Asia Senthuran Elalingam Indirect, Asia Pacific Financial Services Indirect Alex Law International and M&A Tax Partner Deloitte UAE Hamish Sandison International & M&A Tax Manager Deloitte UAE

4 Main Programme 0900 Welcome and introduction Tim Pagett Partner, Asia Pacific Financial Services Leader Stamford Ballroom 0915 Plenary: The changing international and financial services tax landscape This plenary will begin with the Dean of the National University of Singapore Business School, Professor Bernard Yeung, presenting an Asia Pacific economic outlook to provide a broader context for the overall conference. This will be followed by a Q&A with representatives of Inland Revenue Authority of Singapore and the Monetary Authority of Singapore on current financial services tax developments in Singapore. Finally, there will be a Tax Directors panel discussion on the key tax issues impacting financial services, issues as well as priorities for the industry as we progress further into Michael Velten, Asia Pacific Financial Services Tax & Legal Leader 1045 Coffee break 1100 Breakout A Current issues in financial services tax This session will examine a number of current issues for financial services. The topics that will be discussed include: digital business related tax developments (e.g., OECD Public Consultation on the tax challenges of digitisation), including a review of blockchain applications in the financial services sector and the emergence of security token offerings. The session will also address: recent tax reform in Asia, intangibles in financial services, the tax treatment of regulatory capital securities, accounting changes that impact tax, China regulatory reform and Interbank Offered Rate (IBOR) reform. Real estate tax developments This session will address international and domestic tax developments impacting real estate investment in the region, as well as an update on structuring for investments in the UK, Europe and the United States. Key issues related to branch capital attribution and funds transfer pricing This session will survey regional AOA developments, including Hong Kong s recent adoption of the AOA into domestic law, Japan approach to AOA since it came in effect in 2016, and the broader views of AOA within APAC. This session will also provide an update on funds transfer pricing and intercompany funding in light of the recent OECD BEPS discussion draft on financial transactions. Michael Velten, Asia Pacific Financial Services Tax & Legal Leader Siew-Kee Chen Deloitte Australia Samuel Gordon Transfer Pricing Partner Deloitte Japan

5 1215 Lunch 1315 Breakout B Mergers & Acquisitions (M&A): Current strategic and tax considerations The M&A breakout will consider the environment for M&A transactions in the Asia Pacific region; including the drivers for strategic M&A. The session will also include a round-up of key regional issues. Outsourcing arrangements: Managing tax costs Outsourcing to shared service centres and BPOs remains common in the region; relevant locations include India, Malaysia and the Philippines. The session will focus on common pitfalls, practical considerations and planning opportunities. Cost mitigation strategies will also be highlighted. Business models and transfer pricing methods in the asset management sector This session will consider transfer pricing methods for the asset management sector (both traditional, hedge and alternative) in view of applicable business models. Current practical issues in transfer pricing for asset management will also be considered; including strategies to mitigate transfer pricing risk in the Asia Pacific region. Michael Velten, Asia Pacific Financial Services Industry Tax & Legal Leader Senthuran Elalingam Indirect, Asia Pacific Financial Services Indirect Samuel Gordon Transfer Partner Deloitte Japan

6 1415 Breakout C Tax developments in the Investment Management Sector This breakout session will focus on a range of topics relevant to investment managers in the Asia Pacific region. Topics to be covered include: the impact of Brexit on investment management business models; new fund vehicle update (especially the Singapore Variable Capital Company regime and the proposed Corporate Collective Investment Vehicle in Australia); the Hong Kong Unified Profits Tax exemption; fund manager remuneration incentive plans, the carried interest regimes now in place in key jurisdictions, and the practical implications of the transparency agendas of tax authorities. Key transfer pricing considerations for insurers and brokers with respect to new operating models This session will discuss current industry trends in profit attribution to branch structures, managing general agent (MGA) arrangements and split-kert business models. The session will also consider how to apply transfer pricing principles to new operating models. Practical strategies to support cost allocations will also be discussed. US tax reform: Additional guidance and practical issues for inbound and outbound This session will discuss some of the additional guidance (e.g., related to interest deductibility, BEAT, GILTI, and partnership dispositions) received since the tax reform was enacted a year ago and provide some practical insights and potential opportunities for dealing with some of the new provisions that may be applicable to taxpayers in the financial services industry. Siew-Kee Chen Deloitte Australia Sebastian Ma ilei Deloitte UK David Allgaier Deloitte China 1515 Coffee break

7 1530 Plenary: Controversy Tax audit developments across key jurisdictions This plenary will consider the current and emerging areas of tax audit focus and controversy. Strategies to manage disputes will also be considered. The session will focus across all sectors Plenary: The tax function Building a tax operating model for the future In the final session, we will explore the drivers of change within tax functions and how organisations might want to respond. Tax departments are being asked to do more with less, to embrace technology and partner with the business and yet compliance obligations are growing not shrinking. Added to this there is an increased focus on tax from multiple stakeholders. We will discuss what this means for the structure of your tax function, the skills you may need in future and where you might start in tackling the challenges. Jun Takahara Deloitte Singapore Piyus Vallabh, Asia Pacific Tax Management Consulting Leader Sarah Watts Deloitte UK Stamford Ballroom 1715 Closing remarks Nigel McCrea, Global Financial Services Industry Tax & Legal Leader Deloitte UK 1730 Cocktail reception Stamford Foyer Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited ( DTTL ), its global network of member firms, and their related entities. DTTL (also referred to as Deloitte Global ) and each of its member firms and their affiliated entities are legally separate and independent entities. DTTL does not provide services to clients. Please see to learn more. Deloitte is a leading global provider of audit and assurance, consulting, financial advisory, risk advisory, tax and related services. Our network of member firms in more than 150 countries and territories serves four out of five Fortune Global 500 companies. Learn how Deloitte s approximately 286,000 people make an impact that matters at Limited is a company limited by guarantee and a member firm of DTTL. Members of Limited and their related entities provide services in Australia, Brunei Darussalam, Cambodia, East Timor, Federated States of Micronesia, Guam, Indonesia, Japan, Laos, Malaysia, Mongolia, Myanmar, New Zealand, Palau, Papua New Guinea, Singapore, Thailand, The Marshall Islands, The Northern Mariana Islands, The People s Republic of China (incl. Hong Kong SAR and Macau SAR), The Philippines and Vietnam. In each of these, operations are conducted by separate and independent legal entities. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the Deloitte Network ) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte Network shall be responsible for any loss whatsoever sustained by any person who relies on this communication For information, contact Deloitte Touche Tohmatsu Limited.