C L A R I D E N August 2014

Transcription

1 C L A R I D E N August 2014 Knowledge for the world business leaders Shangri-La Hotel, Singapore Asia Strategic Tax and Finance Week: International Tax Planning and Structuring for MNCs Faculty Director Nico Derksen Owner International Tax Management Pte Ltd Associate Faculty, Masters of Taxation, UniSim School of Business Accredited in Singapore as a tax advisor by the SIATP Over 20 years of international experience with major tax advisory firms Advised some of the largest MNCs from around the globe and high net worth individuals, private equity funds, hedge funds, and government institutions Nico started his own consulting firm, International Tax Management, providing tax services to various companies across the globe. Over the years, Nico has worked with the largest multinationals in the world, helped entrepreneurs with their start ups, advised high net worth individuals, private equity funds, hedge funds, and government institutions. He is a renowned speaker at seminars, regularly publishes articles on tax topics, and has taught in many locations across the globe. Nico is currently an Associate Faculty at UniSim, lecturing for the Masters of Taxation course. He has also been accredited in Singapore as a tax advisor by the SIATP and is a highly sought after consultant and trainer. In 2000, Nico joined the international tax practice of Ernst & Young in Rotterdam. His focus was predominantly on US and UK multinationals, structuring their activities in Europe and the rest of the world. Nico took on various challenging roles within Ernst & Young for over 11 years. In his last role in Ernst & Young Singapore, he supported with the expansion of the international tax team. Here, Nico gained invaluable knowledge of the Singapore and Southeast Asian market.

2 International Tax Planning and Structuring for MNCs FACULTY DIRECTOR Nico Derksen Owner International Tax Management Pte Ltd Associate Faculty, Masters of Taxation, UniSim School of Business Accredited in Singapore as a tax advisor by the SIATP Over 20 years of international experience with major tax advisory firms Advised some of the largest MNCs from around the globe and high net worth individuals, private equity funds, hedge funds, and government institutions Nico is currently an Associate Faculty at UniSim, lecturing for the Masters of Taxation course. He has also been accredited in Singapore as a tax advisor by the SIATP and is a highly sought after consultant and trainer. He has worked with the largest multinationals in the world, helped entrepreneurs with their start ups, advised high net worth individuals, private equity funds, hedge funds, and government institutions. Nico founded International Tax Management Pte Ltd (ITM) to fill significant gaps that continue to exist in the tax consultancy market. Today, Nico is a renowned speaker at seminars, regularly publishes articles on tax topics, and has taught in many locations across the globe. Nico is also a regular trainer with the Singapore Tax Academy. Nico took on various roles in Ernst and Young for over 11 years. He first joined the international tax practice in Rotterdam in 2000, and his primary focus was on the US and UK Multinationals. He was later appointed to be the Dutch Ernst & Young representative in Chicago. After which, he went on to perform tax accounting and risk advisory duties in Netherlands and as he excelled in his role, he headed the Ernst & Young tax department in Slovenia. With an extensive experience in grooming various teams of people, Nico was then put in charge of building the outbound tax team for Ernst & Young in India, providing service to the Indian multinationals who were looking to invest abroad. Eventually, he was offered a position at Ernst & Young Singapore to support the expansion of the international tax team. This role has helped Nico gain invaluable knowledge of the Singapore and southeast asian tax industry market. Nico studied Dutch tax law and accounting at the Controleur Opleiding of the Dutch revenue service from 1987 till Upon graduation, he started his tax career in the Netherlands. As a member of the supervisory board of a large social housing trust in Rotterdam, Nico managed over 2 billion Euro worth of assets. He was frequently consulted by the ministry of finance to deliver his expert inputs and opinions on legislative proposals. Nico continued his studies at the University of Brabant to receive his masters in tax law in Nico is also an executive committee member of the Singapore chapter of the International Fiscal Association, and a board member of the Association of Dutch Business People. 2

3 International Tax Planning and Structuring for MNCs EXECUTIVE SUMMARY Program: Dates: Location: International Tax Planning and Structuring for MNCs August 2014 (2 days program) Shangri-La Hotel, Singapore Early Bird 1 (Register & pay by 26 June 2014): Early Bird 2 (Register & pay by 24 July 2014): Regular Tuition Fee: S$2,950 S$3,150 S$3,250 For limited period only: Registration for 2 participants, 10% on 2nd participant For limited time only by 24 July 2014, registration for 3 participants, the 4th participant will receive a complimentary seat (one discount scheme will apply) Note: GST is applicable only to participants from Singapore registered companies. Check your eligibility for 60% Cash Back at IRAS website. Program Essence: This intensive and highly interactive International Tax Planning and Structuring for MNCs executive education program is designed for senior to middle-level finance and tax professionals to provide you with a practical understanding of international tax planning and structuring for MNCs. In this two-day program, you will learn how to optimize your tax strategy for cross-border expansion and transactions with tax-efficient planning and structuring. You will discover how to plan and structure your acquisition activities, holding and financing activities, dividend and post-acquisition structuring across a wide spectrum of business models. Additionally, you will learn how to establish these activities along with the increasingly important concepts of Permanent Establishments (PE) and tax treaties. Throughout the two-day program, you will be engaged in concepts and group discussions on real-world successful and failed international tax planning case studies. PROGRAM INTRODUCTION Multinational companies (MNC) have and still consider Singapore as a jurisdiction of choice for setting up a company. Besides her unique position in the global economy and pivotal role as the epicentre of businesses, Singapore offers one of the most attractive corporate tax structures in the world. MNCs set up offices in Singapore for its vast network of free trade, reliable tax treaties and its economic stability. Likewise, Singapore companies are increasingly looking to grow their presence globally. Therefore, it is essential for Singapore companies to understand the intricacies involved during international tax planning and how to perform cross-border transactions smoothly. This intensive and highly interactive International Tax Planning and Structuring for MNCs executive education program is designed for senior to mid-level finance and tax professionals to provide you with a practical understanding of international tax planning and structuring for MNCs. In this two-day program, you will learn how to optimize your tax strategy for cross-border expansion and transactions with tax-efficient planning and structuring. You will discover how to plan and structure your acquisition activities, holding and financing activities, dividend and postacquisition structuring across a wide spectrum of business models. Additionally, you will learn how to plan and structure these activities along with the increasingly important concepts of Permanent Establishments (PE) and tax treaties. This program is designed for MNCs who are looking to increase their business exposure through cross border expansion or have existing cross border operations but are looking to design and plan for more tax efficient strategy. Hear Nico Derksen, an expert in tax matters; share his in-depth knowledge on how to achieve tax efficiency and to be tax savvy. 3

4 Program Details LEARNING OBJECTIVES Understand international tax planning in the current challenging tax environment Learn how to structure your international business operations, cross border expansion and acquisitions in a tax efficient manner Understand how the principles of hybrid instruments play a crucial role in international tax planning Explore the latest concepts and updates on Permanent Establishments, tax treaties, anti-avoidance rules and other major tax issues Understand current tax authorities thinking to plan and protect your organization from onerous processes Learn from successful and failed international tax planning case studies Network with tax professionals from around the region WHO WILL BENEFIT THE MOST Risk and Strategic Planning. This program is also applicable to Tax Lawyers, Tax Authorities, Accountants, Corporate Treasurers, Chief Operating Officer, Chief Compliance Officers, Financial Controller, Internal and External Auditors, and Project Managers across all industries. PROGRAM OUTLINE DAY ONE Fundamental Concepts of International Tax Introduction to international tax law Systems of taxation The role of tax treaties The role of tax in the decision making process International Tax Planning in the Current Environment The blurring line between tax planning, avoidance, and evasion Anti-avoidance rules; general and specific Controlled foreign company rules and their impact The impact of BEPS on tax planning Holding activities Structure an acquisition How to optimize dividend streams How to deal with reorganizations How to structure a disposal Financing Activities Typical leverage structures Withholding tax planning Interest deduction limitation rules Learn how to deal with them Hybrid entity and instrument planning 4

5 Program Outline & Agenda DAY TWO Permanent Establishment (PE) Why is this concept so important? How to identify PE exposures? How to mitigate the impact? How to use the PE concept to your benefit? Structuring International Business Operations Business models and key concepts Analyze key manufacturing structure Various ways to structure distribution operations Best methods to structuring R&D activities Intangible planning - where to hold the ownership Structuring proper royalty streams International Tax Planning: Key Concepts and Boundaries Recent developments Look at successful strategies that work Tax authorities approach to tax planning Protect your organisation from onerous processes 5

6 INTERNATIONAL TAX PLANNING AND STRUCTURING FOR MNCS August 2014 Shangri-La Hotel, Singapore C L A R I D E N Knowledge for the world business leaders REGISTRATION PAGE Booking Contact (Approving Manager) Mr/Mrs/Ms: Job Title: Department: Telephone: Fax: Organization: Address: Postal Code: I would like to receive more information on hotel accommodation using Clariden Global coporate rate. Please Register the following participant(s) for this Program: 1st Participant Name (Mr/Mrs/Ms): 2nd Participant Name (Mr/Mrs/Ms): 3rd Participant Name (Mr/Mrs/Ms): 4th Participant Name (Mr/Mrs/Ms): PROGRAM FEES 1 ST EARLY BIRD FEE: S$2,950 (Registration and payment must be received by 26 June 2014) 2 ND EARLY BIRD FEE: S$3,150 (Registration and payment must be received by 24 July 2014) REGULAR FEE: S$3,250 GROUP DISCOUNT: For 2 registrations from the same company and billing source, the 2nd participant enjoys a 10% discount. For registrations before 24 July 2014 and for 3 or more participants, the 4th participant will receive a complimentary seat Note: GST is applicable only to participants from Singapore registered companies. Important Notice: Payments are required with registration and must be received prior to the Course to guarantee your place. PAYMENT METHODS BY CHEQUE / BANK DRAFT : Made payable to CLARIDEN GLOBAL PTE LTD and mail to: 3 International Business Park, #04-29, Nordic European Centre, Singapore BY TELEGRAPHIC TRANSFER TO: Bank Name: DBS BANK Bank Branch code: 027 Bank Address: 6 Shenton Way, DBS Building, Singapore Bank Account No: Bank Account name: Clariden Global Pte Ltd SWIFT Code: DBSSSGSG Please note that all bank charges are to be borne by participants. Please ensure Clariden Global Pte Ltd receives the full invoiced amount. Note: Please include invoice number on all payment types and your company s name in your payment instructions for our reference. CREDIT CARD: To make payment by credit card, please call our client services hotline at WAYS TO REGISTER admissions@claridenglobal.com Fax: Call: Website: DATE AND LOCATION This executive program will be held at: Shangri-La Hotel, Singapore August Orange Grove Road, Singapore Tel : Fax : Website : The fee for this two-day executive program includes all written materials, lunch and refreshments. HOW TO REGISTER AND PAY An invoice and registration confirmation will be sent within 7 days, please contact us if you have not heard from us within 7 days. Payment can be made by credit card, by bank transfer or by cheque made payable to Clariden Global Pte Ltd. ALL PAYMENTS MUST BE RECEIVED IN ADVANCE OF THE EVENT. ACCOMMODATION Accommodation is not included in the program fee but you will be entitled to use our corporate rate for your accommodation. Information will be sent along with your registration confirmation. ENJOY 60% CASHBACK Productivity and innovation Credit (PIC) scheme allows registered Singaporean businesses to claim 60% cash back or enjoy 40% tax deduction for training. For more information, please visit CANCELLATIONS AND SUBSTITUTIONS Once we have received your booking, the place(s) are confirmed. No refunds will be made for any cancellations, however, program credits of equivalent value only applicable for Clariden Global events will be provided. Credits can only be redeemed for 1 program and is valid for only one (1) year from date of issue. Substitution with a qualified candidate is allowed by providing at least 5 working days of advance notice to Clariden Global. One time substitution is allowed with no charges. Subsequent substitutions will be charged 10% admin fee. ALL CANCELLATIONS MUST BE RECEIVED IN WRITTEN FORM PLEASE NOTE: Clariden Global Pte Ltd reserves the right to change the content and timing of the programme, the speakers and the date and venue due to reasons beyond their control. If in the unlikely event that the course is cancelled, Clariden Global Pte Ltd will refund the full amount and disclaim any further liability. ENQUIRIES: If you have any queries about registration or payment please do not hesitate to contact our client services department on PRIVATE DISCLOSURE STATEMENT: Any information provided by you in relation to this event is being collected by Clariden Global Pte Ltd and will be held in the strictest confidence. It will be added to our database for the primary purpose of providing you with information about future events and services. Visit us at for upcoming events FOR OFFICIAL USE FEE RECEIVED REFERENCE L4086/TK/AS/SJ