SMU-TA Centre for Excellence in Taxation Annual Conference: The Future of Tax Reforms for Growth and Protection of Revenue Base 9 Sep 2016, Singapore

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1 Date: 9 September 2016 Time: 9:00am to 5:00pm Venue: Marina Bay Sands Sands Expo and Convention Centre, Level 4 Orchid Ballroom 10 Bayfront Avenue Singapore Seminar Fees: $535 (includes GST) Businesses can claim 400% Tax Deduction or 40% Cash Payout on the course fee (net of government grant or subsidy) incurred on or after 1 Aug 2016 under Productivity and Innovation Credit scheme for training of their employees! For details, please refer to: dit.aspx This seminar is designed for: business and tax community, tax / finance / accounting / legal Professionals, academics, Government policy makers and tax administrators Closing date for registration: 26 August 2016 For enquiries, please contact: Jocelyn Chong DID: (65) Amuna Manyuni DID: (65) tax_academy@iras.gov.sg Fax: The SMU-TA CET reserves the right to cancel the event, or make changes to the schedule, venue and speakers. All information stated in the brochure is correct at time of publication and subject to change. Visit cet/ SMU-TA Centre for Excellence in Taxation Annual Conference: The Future of Tax Reforms for Growth and Protection of Revenue Base 9 Sep 2016, Singapore The SMU-TA Centre for Excellence in Taxation is pleased to present its annual conference on The Future of Tax Reforms for Growth and Protection of Revenue Base. This conference represents a unique forum for tax practitioners, policymakers and academics to discuss key issues on international tax policies and trends with a particular focus on Asia. With the slowing of the global economy, competition for investments will continue as governments look for ways to stimulate their respective economies. There are also challenges posed by global change in international tax rules, public concerns about tax evasion and avoidance, and potential aggressive posturing by tax authorities and governments in need of revenues. You will hear thoughts and ideas on the directions of tax policies and tax systems from renown speakers and thought leaders. CET researchers will present their findings on their research future of tax for global and Asian economies. Distinguished panellists will discuss on the latest developments in treaties and transfer pricing. The speakers and panellists include - Prof Dr Jeffrey Owens, Prof David Rosenbloom, Prof Philip Baker QC, Prof Sum Yee Loong, Dr Christiana HJI Panayi, Dr Jing Xing, Senior Lecturer Jow Lee Ying and many more. About SMU-TA Centre for Excellence in Taxation SMU-TA Centre for Excellence in Taxation (SMU-TA CET) is set up by Tax Academy and the Singapore Management University, with a mission to produce robust research in international and regional tax issues for policydevelopment and engagement of the international tax community. The SMU- TA CET is the first centre in Singapore that is dedicated to the research on taxation. CPD Accreditation 5.5 Public CPD Points Practice area: Tax Training Level: General

2 Morning Session 8.15am-8.55am 9.00am-9.15am 9.15am-10.30am 10.30am-10.45am 10.45am-11.30am 11.30am-12.15pm 12.15pm-12.30pm 12.30pm-2.00pm Registration Conference Opening Panel Discussion: The Future of Tax Singapore is charting its next phase of economic developments through the works of Future of Economy committee. There is intense competition for investments and governments are looking for ways to grow their respective economies. There are also challenges posed by global changes in international tax rules, public concerns about tax evasion and avoidance, and potential aggressive posturing by tax authorities and governments in need of revenues. How could tax policies and tax systems evolve to meet these challenges and find the balance between growth and avoidance? How could Singapore s tax policies and systems meet these challenges? What would be the new balance and order in international tax policies and rules? Coffee Break UK s Future of Tax - Reforms for a Post-BEPS World? A critical evaluation of UK s tax changes that seem to address tax avoidance and yet maintain a probusiness environment. How fine has the balance been? Future of tax reforms Where are US tax reforms now? An evaluation on how far US will go in support of the post BEPS changes with the new US tax treaty model. Territorial Tax Systems Reform is this still the way to go? An evaluation of the continued relevance of territorial tax systems reforms. Lunch

3 Afternoon Session Future Of Tax Treaties And International Tax Law 2.00pm-2.15pm 2.15pm-3.15pm 3.15pm-3.45pm Multilateral Instrument - A More Harmonised Global Treaty Network? A critical evaluation of the BEPS proposal to implement swiftly tax treaty changes. Panel Discussion: Future of Tax Treaties and International Tax Law Coffee Break Future Of Transfer Pricing In A World Of More Information Sharing And Exchange 3.45pm-4.00pm 4.00pm-4.15pm 4.15pm-4.45pm 4.45pm-5.00pm 5.00pm Transfer Pricing validating value and substance in the future With implementation of CBCR and more information exchange, how will transfer pricing be adopted as a strategy to substantiate value and substance in the digital world? Related parties and the definition of control in transfer pricing Panel Discussion: Future Of Transfer Pricing In A World Of More Information Sharing and Exchange The foreseeable future of international tax reforms summing it up! End

4 Ms Indranee Rajah Senior Minister of State Ministry of Finance & Ministry of Law Ms Indranee Rajah is Singapore s Senior Minister of State for Law and Finance. She was educated at Raffles Institution, and read law at the National University of Singapore. She was admitted to the Singapore Bar in 1987 and appointed Senior Counsel in 2003, was the Deputy Head of Drew & Napier s Dispute Resolution Department until October 2012, when she left to join the Government. Ms Indranee also co-chairs the Working Group on Legal and Accounting Services under the Committee on the Future Economy (CFE). Prof Dr Jeffrey Owens Director, WU Global Tax Policy Center Institute for Austrian and International Tax Law WU (Vienna University of Economics and Business) Chairman, SMU-TA CET Technical Advisory Panel Jeffrey Owens chairs the SMU-TA Centre for Excellence in Taxation Research Committee. He is the Director of the WU Global Tax Policy Center at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). He is also the Senior Policy Advisor to the Global Vice Chair of Tax at EY, advisor to the World Bank and UNCTAD and a number of regional tax administration organizations. For over 20 years, Jeffrey led the OECD Tax Work, establishing a major taxation program at the OECD and extensively developed the OECD contacts with non-member countries. He initiated the dialogue with the G20 on taxation and oversaw the G20/OECD initiatives to improve tax transparency, laying the foundation for the Base Erosion Profit Shifting work. Jeffrey is also involved in activities with a number of other NGOs.

5 Prof Philip Baker QC Visiting Professor, Tax Law, Oxford University Barrister and Queen s Counsel Field Court Tax Chambers Philip Baker QC is a barrister and Queen s Counsel, practising from Field Court Tax Chambers in London, and also Visiting Professor in Tax Law at Oxford University. He began practice in 1987, having been a full-time lecturer in law at London University from 1979 until then. He is also a Senior Visiting Fellow at the Institute of Advanced Legal Studies, University of London. He specialises primarily in international aspects of taxation, which covers both corporate and private client matters. He also advises governments on a range of tax matters, including state aid and tax investigations by the European Commission. He has a particular interest in taxation and the European Convention on Human Rights, and is the author of a book on Double Taxation Conventions. He has appeared in cases before courts and tribunals at virtually every level from the Special Commissioners (now the Tax Tribunal) to the House of Lords, Privy Council and European Court of Justice. He is a former member of the Council of the Chartered Institute of Taxation, and remains a member of several committees of the CIOT and of the International Tax Sub- Committee of the Law Society. He is a member of the UK Committee of the International Fiscal Association and a member of the Permanent Scientific Committee of IFA. He is also a government-appointed member of the UK s Tax Professional Forum. In 1997 he was awarded an OBE for work with Chinese political refugees in the UK. Prof Sum Yee Loong Professor of Accounting Singapore Management University Professor Sum Yee Loong has more than 30 years of experience in Singapore and international taxation. Yee Loong is currently Professor of Accounting in the School of Accountancy, Singapore Management University, honorary technical advisor (tax) of the Institute of Singapore Chartered Accountants, chairman of the examinations and curriculum committee of the Singapore Tax Academy, Board Member of Singapore Institute of Accredited Tax Practitioners, member of the Learning and Assessment Committee of the Singapore Qualification Programme of the Singapore Accounting Commission and Council Member of National Arts Council. He is the author of the Singapore Tax Workbook published by CCH.

6 Prof David Rosenbloom Director, International Tax Program New York University School of Law Professor H. David Rosenbloom became director of the International Tax Program in He is a member of Caplin & Drysdale, a law firm he rejoined in 1981 after serving as international tax counsel and director of the Office of International Tax Affairs in the US Department of the Treasury from 1978 to A frequent speaker and author on tax subjects, Rosenbloom has taught international taxation and related subjects at numerous law schools including Stanford, Columbia, the University of Pennsylvania, and Harvard. He has also served as a tax policy adviser for the US Treasury, the OECD, USAID, and the World Bank in Eastern Europe, the former Soviet Union, Senegal, Malawi, and South Africa. Dr Jing Xing Assistant Professor Antai College of Economics and Management Shanghai Jiao Tong University Dr. Jing Xing joined the Antai College of Economics and Management at the Shanghai Jiao Tong University in 2014 as an Assistant Professor of Finance. Prior to joining Antai, she was a Research Fellow at the Oxford University Centre for Business Taxation, and an Associate Member of Nuffield College, University of Oxford between 2011 and Dr. Xing obtained her D.Phil in Economics from the University of Oxford in Her research interests include public economics, taxation, and corporate finance. Dr. Jing Xing is an International Research Fellow at the Oxford University Centre for Business Taxation, and a Research Associate at the Centre for European Economic Research (ZEW) in Germany. Mr Jerome van Staden Researcher of SMU-TA CET International Director, International Tax Services Ernst & Young Solutions LLP Jerome has worked 22 years as international tax advisor of which 5 years in the Netherlands and 16 years in Brazil and is based in Singapore. He advises companies on cross border transactions, establishment of entities in various foreign jurisdictions, acquisition of assets and group restructurings. He is knowledgeable about Dutch tax law as well as international tax law with an emphasis on reorganization of multinational companies, M&A and the use and interpretation of double tax treaties. He has extensive experience in international reorganizations, transactions involving European multinationals with investments in Brazil as well as Brazilian multinationals with operations overseas.

7 Mr Mukesh Butani Managing Partner BMR Legal Mukesh is a specialist in corporate international tax and transfer pricing and has significant experience in advising Fortune 500 multinationals and large Indian business houses on a wide range of matters relating to FDI policy, business re-organizations, cross-border tax structuring, tax controversy across a range of sectors. He has been consistently featured among leading international tax and transfer pricing advisors in independent surveys, most notably Euromoney s International Tax Review, Legal Review expert guides (2002 to 2016), Asia Law Leading Lawyers, Chambers & Partners and Who's Who Legal of Corporate Tax Lawyers. Mukesh has been ranked as the top Tax Controversy Leader in India by International Tax Review (2013, 2014, 2015). Mr Tang Siau Yan Tax Director (International Tax) / Director (Law 1) Inland Revenue Authority of Singapore Siau Yan is the Tax Director of the International Tax Branch of the Inland Revenue Authority of Singapore (IRAS). He is also Director of Law 1 Branch of IRAS. Siau Yan read law at the London School of Economics and Political Science and at Cambridge University. He started his career with IRAS in From 2008 to 2014, he was a tax partner at a leading Singapore law firm. He rejoined IRAS in his current appointments in Siau Yan has represented both IRAS and taxpayers in various tax cases and has authored several works on Singapore income taxation. Ms Moira Khaw Principal TAX Ed Moira holds a LL.B and LL.M from the National University of Singapore. She has more than 30 years of tax experience that includes practice in international accounting firms and as Tax Partner in a leading Singapore law firm. Moira has consulted for clients from business sectors that include finance, international manufacturing and trading, aircraft manufacturing and aviation, telecommunications, and oil and gas. Her transactional work experience ranges from structuring outbound investments, advising on complicated cross-border project financing arrangements, corporate restructuring, mergers and acquisitions, setting up of multinational business operations and global operating subsidiaries, centralizing ownership of investments and intellectual property, and has dealt extensively with tax treaty issues. She has also successfully represented many clients at negotiations with the Inland Revenue Authority of Singapore in contentious tax matters and disputes. Moira is now Principal of her own tax training firm.

8 Mr Allen Tan Principal Baker & McKenzie.Wong & Leow Allen has extensive experience working on both international and local tax issues, with a special focus on the regional tax aspects of the transactions that he is involved in. His practice includes advising clients on tax issues arising from mergers and acquisitions, transfer pricing, tax controversies, foreign direct investment, cross-border tax issues, indirect and transfer taxes and private equity fund. Allen has been recognised as a leading tax lawyer by leading industry and legal publications including International Tax Review, Asia Pacific Legal 500 and Chambers Asia Pacific. Mr Yuki Araki Deputy Director International Operations Division National Tax Agency, Japan Mr Yuki Araki is Deputy Director of the International Operations Division, National Tax Agency of Japan. In this division, he is responsible for OECD issues including the BEPS project. Mr. Araki started his career in From , he studied in SAIS (School of Advanced International Studies) of Johns Hopkins University, majoring in international law. After coming back to Japan, he was assigned to the tax treaty division of Ministry of Finance, where he was in charge of the negotiation of bilateral tax treaty. In that position, he participated in the negotiations with more than 10 countries such as Germany, Belgium and Taiwan. Dr Raffaele Petruzzi Managing Director WU Transfer Pricing Center at the Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Transfer Pricing Advisor, Deloitte (Vienna, Austria) Raffaele Petruzzi is Managing Director of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at Vienna University of Economics and Business (WU) and a transfer pricing advisor at Deloitte (Vienna, Austria). Since 2007, Raffaele has gained relevant experience in international tax and transfer pricing, by working in different countries within Big4 companies and in the tax department of a multinational. Raffaele holds a Master of Science degree in Business Administration and Law (major: Corporate Taxation) at Bocconi University (Italy), a Master of Laws degree (LL.M.) in International Tax Law at WU, and a Ph.D. in International Business Taxation at WU (thesis title: Transfer Pricing Aspects of Intra-Group Financing ).

9 Ms Yong Sing Yuan Researcher of SMU-TA CET Group Tax Specialist International Tax Branch, Tax Policy & International Tax Division Inland Revenue Authority of Singapore Ms Yong Sing Yuan is currently a Group Tax Specialist in the Inland Revenue Authority of Singapore dealing in advanced pricing arrangements and mutual agreement procedures relating to transfer pricing issues. She has experience in tax policy work and international taxation matters. Sing Yuan holds a Bachelor of Accountancy with Honours from the Nanyang Technological University and a Master of Advanced Studies in International Tax Law with Honours from Leiden University. She is also an Accredited Tax Advisor with the Singapore Institute of Accredited Tax Practitioners. Sing Yuan is the course advisor and one of the trainers for the International Tax Programme conducted by the Tax Academy. She has also contributed to external journals such as the Bulletin for International Taxation by IBFD. Prof Dr Alfred Storck Managing Director WU Transfer Pricing Center at the Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Alfred Storck is Managing Director of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at Vienna University of Economics and Business (WU)and, since April 2009, a Visiting Professor at the same Institute. The focus of his research and teaching activities is International Business Taxation and Transfer Pricing. From 2009 till January 2015, Alfred Storck has been working as Honorary Professor for Company Taxation and Managerial Finance at the University of St. Gallen, Switzerland. Additionally, Alfred Storck is teaching in various LL.M./MBA programs at WU Vienna and Universities of Zurich and Lausanne. Alfred also held various functions in a large multinational company as Group Tax director and Head of Group Function Finance and Treasury; for the last 5 years, he was also the acting Deputy CFO. Miss Jow Lee Ying Researcher of SMU-TA CET Senior Lecturer Nanyang Business School Nanyang Technological University Lee Ying is a senior lecturer and faculty member of the Nanyang Technological University and Associate Director of Ernst & Young Solutions LLP's tax practice based in Singapore. She has extensive experience in a wide spectrum of international tax work, such as transfer pricing consultations/audits, Advance Pricing Arrangements (APAs), Mutual Agreement Procedure (MAPs) and tax treaties. Prior to this, Lee Ying was with the Inland Revenue Authority of Singapore (IRAS) and the Ministry of Finance. She is well regarded for her international tax expertise and is a regular speaker at public tax seminars.

10 Prof Dr John Hutagaol Director of International Taxes Directorate General of Taxes Ministry of Finance, the Republic of Indonesia Prof DR Poltak Maruli John Liberty Hutagaol, M.Acc., M.Ec.(Hons.), S.E., Ak., C.A. is currently serving as Director of International Taxation of the Directorate-General of Taxes and Competent Authority of the Republic of Indonesia. Previously, he was Director of Tax Regulations II and Head of the Foreign Direct Investment One Tax Office. He has experience in various taxation areas, such as being delegate in many tax treaty negotiations and conceptor of taxpayers mapping, profiling, and benchmarking. He also had important role in drafting current Indonesian Income Tax Act. He graduated with Bachelor of Economics from Brawijaya University at Malang. He finished his graduate studies in University of Macquarie at Sidney and doctoral program in the University of Padjadjaran at Bandung. He received his title of professor from ABFI Institute Perbanas at Jakarta. Dr Lee Kyung Geun Senior Tax Attorney Yulchon LLC Dr Kyung Geun LEE has been leading the international tax team of Yulchon LLC since 2007 and was ranked in Band 1 Group of Tax Consultants in 2014 and 2015 by Chambers Asia-Pacific. Mr Lee, who used to be a director in Korean Ministry of Strategy & Finance, played a leading role in formulating in international tax policies in Korea. He was appointed as a Member of the Tax Expert Committee by the Secretary General of the United Nation in He also participated in the activities of the Transfer Pricing Subcommittee of this Committee, which issued UN Transfer Pricing Manual in During , Mr Lee worked for the OECD CTPA as an Administrator seconded by Korean Government. Mr Leon Kwong Wing Head, Tax & Private Client Withers KhattarWong Kwong Wing advises on tax, immigration, trusts and inheritance. He represents taxpayers in objections against assessments and valuations. He acts as counsel in appeals before the Review Boards and the Courts, and he represents taxpayers under audit or investigation. He is ranked in Who s Who Legal, The Legal 500 Asia Pacific and the Tax Directors Handbook. Kwong Wing is a tutor for the Bar Course. He is the General Editor of Income Tax and co-author of Stamp Duties for Halsbury s Laws of Singapore; and a contributor to The Law and Practice of Singapore Income Tax and the World Trust Survey.

11 REGISTRATION FORM Two easy ways to register Fax: (65) Venue: Marina Bay Sands Sands Expo and Convention Centre 10 Bayfront Avenue, Singapore Provide your details Dr / Mr / Ms / Mrs / Miss (please circle where applicable) Full Name (please underline family name) Name to appear on nametag Organization Designation Mailing address address Telephone number Fax number AAS No. (eg. 888/2008): Name and address of co-ordinator: SMU-TA Centre for Excellence in Taxation Annual Conference (continue next page)

12 REGISTRATION FORM 2 Payment options I enclose a cheque of SGD made payable to Tax Academy of Singapore. Cheques should be crossed and made payable to Tax Academy of Singapore indicating the event title at the back of the cheque. Please attach the registration form with your cheque and send to: Attn: Ms Faridah Omar Tax Academy of Singapore, #B1-01, 55 Newton Road, Revenue House, Singapore (307987) Telegraphic Transfers Information concerning telegraphic transfers : a) Bank: UOB / Bank number: 7375 / Branch number: 016 / Account number: / Swift Code: UOVBSGSG b) Applicant will bear all local and overseas bank charges for telegraphic transfers c) A copy of the remittance advice to be faxed to (65) or ed to tax_academy@iras.gov.sg Other information 1. Registration and payment Registrations for events are on a first-come-first-served basis. Foreign participants, who in their business capacity belong overseas and sponsored by overseas employers, are excluded from paying 7% GST. 2. Cancellation/Substitution policy There will be no refund for cancellation. Substitute is welcome and must be submitted in writing with personal details. 3. Others CPE letter (issued by Tax Academy of Singapore) is only awarded to participants who have signed for and attended the event. Please send me a CPE letter. 4. SILE Attendance Policy Participants who wish to claim CPD Points are reminded that they must comply strictly with the Attendance Policy set out in the CPD Guidelines. This includes signing in on arrival and signing out at the conclusion of the activity in the manner required by the organiser, and not being absent from the entire activity for more than 15 minutes. Participants who do not comply with the Attendance Policy will not be able to obtain CPD Points for attending the activity. Please refer to for more information. Please tick if claiming CPD points.