International Fiscal Association, Tax Academy of Singapore

Transcription

1 International Fiscal Association, Tax Academy of Singapore Asia Pacific Regional Tax Singapore Page 1 of 6

2 Day 1 l Morning Session 8.00 am 8.45 am Registration 8.45 am 9.10 am Opening: Minister 9.10 am 9.30am An Introduction to IFA 9.30 am 10.45am Plenary: Developments and Trends in Asia-Pacific Tax Policy and Administration This session will focus on the trends in tax policy and administration in Asia-Pacific taxation as well as the tax policy outlook for 2013 and beyond. There will be an overview of developments in Singapore tax policy and administration, including co-operation between the Singapore tax authorities and taxpayers. A panel of experts from a number of countries will then discuss the key current tax policy issues and developments in their jurisdictions. From there, the key trends in Asia-Pacific tax policy will be distilled am am Refreshment Break am pm Keynote Speech: Global Developments and Trends in International Anti-Avoidance The Keynote speech will address recent developments and trends in international antiavoidance including enforcement and international cooperation. The speech will highlight key recent tax cases in the area of international anti-avoidance. Specific aspects of this topic will be explored in the Day 1 workshop seminars pm 1.300pm 1.30pm 2.00pm Lunch Q&A: Reflections on Singapore Tax A Q&A with a panel of eminent Singapore tax practitioners that will discuss their personal recollections and experiences of Singapore tax over the past 40 years. Page 2 of 6

3 Day 1 l Afternoon Session 2.00 pm 5.00 pm Workshop Seminars 1 Choose 2 [1 hour 15mins each]: IFA/Tax Academy Asia Pacific Regional Tax Workshop A: Meaning of Beneficial Ownership This workshop will focus on the meaning of beneficial ownership and include a review of recent case law and OECD work on this topic, as well as developments in locations such China, Indonesia, Japan and Korea. The workshop will feature a panel discussion and include case studies. Workshop B: India GAAR: The Journey Thus Far The focus of this workshop will be the India GAAR. The workshop will discuss on tax policy considerations that underpin the India GAAR, as well as well as the India GAAR journey to date. Key GAAR concepts such as the meaning of commercial substance will be discussed as will the likely judicial approach to the interpretation of the GAAR. A panel will consider the application of the GAAR in an international tax planning context, as well as strategies that might be considered including those to seek certainty as to the application of the GAAR. Finally, the lessons of the GAAR experience for India tax policy development will be discussed. Workshop C: Developments in International Anti-Avoidance in Asia-Pacific This workshop will consider recent developments in international anti-avoidance in Asia- Pacific. Topics covered will include an update on Australia s Part IVA and its application in an international context, the local Singapore tax case law on section 33 as well as the China GAAR. The workshop will also consider recent developments in jurisdictions such as China, Indonesia and India related to the taxation of indirect transfers including the underlying legal basis for taxing such transfers. Strategies to address this issue in the context of international M&A transactions and reorganizations will be discussed, as well as possible future reforms/developments in this area and suggested tax planning. The workshop will feature a panel of experts and include case study discussions. 5.00pm 6.00pm Plenary: International Tax Planning Strategies This session will address the current tax planning opportunities and strategies for MNC investment and business development in the Asia Pacific region, including investment holding and financing for the region. The session will also focus on outbound tax planning strategies for Asia MNC investment in Europe and the US pm Day 1 Close 6.00pm 8.00pm 8pm Cocktail Party Speakers Dinner 1 Each workshop will be repeated and run concurrently. There will be a 30 minutes refreshment break between each workshop cycle. Page 3 of 6

4 Day 2 l Morning Session 8.45 am 9.45 am Plenary: Permanent Establishments This session will examine the current issues related to permanent establishments. An overview of the topic including recent OECD work will be followed by a consideration of the practical issues that can arise in a number of the tax jurisdictions in Asia Pacific, including the strategies that can be considered to mitigate permanent establishment risks am am Plenary: Taxation of royalties with special reference to payments for the use of software This session will examine recent international and regional developments related to the taxation of royalties and payments for the use of software am am Refreshment Break am pm Cross Border Business Restructuring pm 1.30 pm Lunch This session will look at cross border business restructuring. The session will begin with an overview of the topic including the work undertaken by the OECD. From there, a number of tax authorities in the Asia Pacific region will provide their perspectives on the topic. 1.30pm 2.00pm Singapore as a Business Location The session will examine Singapore as a business location as well as the opportunities for investment in Singapore. Page 4 of 6

5 Day 2 l Afternoon Session 2.00 pm 3.30 pm Workshop Seminars Choose 1: 3.30 pm 4.00pm Refreshment Break Workshop A: Taxation of Cross Border Service Fees This workshop will consider the taxation of cross border services fees and the related direct and indirect tax issues and challenges, including relevant transfer pricing considerations. There will be a focus on outsourcing arrangements such as contract manufacturing, as well as service and R&D centres. The workshop will feature a panel discussion and include case studies. Workshop B: Plenary: APAs in Asia-Pacific: Developments, Trends and Current Experience This workshop will discuss recent developments and trends related to APAs in the Asia Pacific region. The discussion will focus on the current experience of obtaining APAs and seek to draw out the key practical considerations in seeking an APA. APA selection evaluation criteria will be compared pm 5.00 pm Plenary: Resolution of Tax Disputes This session will look at the approaches to addressing tax disputes in Asia - Pacific tax jurisdictions, including cross border tax disputes. In relation to cross border tax disputes the use of MAP will be considered as will the ability to obtain advance tax rulings. A specific topic for consideration will be the relationship between tax rulings, APAs and MAP. A panel of experts will provide a country perspective on a number of Asia - Pacific tax jurisdictions pm 6.00pm Plenary: Managing Tax in Asia: Practical Strategies This session will consider the key current practical issues and challenges in managing tax in Asia as well as practical strategies that can be considered. A panel of Asia tax directors will share their experiences and perspectives pm Close Page 5 of 6

6 Day 3 l Post Workshops [Sponsored] 9.00 am pm Workshops Choose 2 [1.5 hour each]: A. Perspectives on Foreign Investment and Taxes in China B. Regulatory and Tax Developments Impacting Funds C. Wealth Management in Asia D. Transfer Pricing Trends, Developments and Strategies Page 6 of 6