Morning Session 8.15am-8.55am 9.00am-9.10am Registration Conference Opening 9.10am-9.45am Keynote Address 1 Tax Competition in the New World - Opportunities and Challenges for Governments The economic realities of attracting investments, generating jobs and finding growth remain, particularly for many Asian emerging economies. However, fiscal costs in tax competition could be high. Will governments shun tax competition? 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 9.45am-10.15am 10.15am-10.45am 10.45am-11.45am Designing Effective Tax Incentives - Maximizing the Benefits and Minimising the Costs What are the elements in the design and implementation of a robust and effective tax incentive system? What are benchmarked practices that can be drawn from the experiences of countries like Singapore? Professor Eric M. Zolt Michael H. Schill, Distinguished Professor of Law UCLA School of Law Coffee Break Panel Discussion: Growth, Tax Competition and the Future of Tax Competition in post-beps World with particular focus on Asia How to design pro-growth tax systems in the region? How to reconcile the need for competitive tax systems with a fair distribution of the tax burden? Chairman: Prof Dr Jeffrey Owens Director, WU Global Tax Policy Center Institute for Austrian and International Tax Law, WU Chairman, SMU-TA CET Technical Advisory Panel Members: Professor Eric M. Zolt Michael H. Schill, Distinguished Professor of Law, UCLA School of Law Dr Yip Chun Seng Principal Economist (Fiscal Policy), Ministry of Finance, Singapore Tan Sri Datuk Wira Dr. Mohd Shukor Mahfar Chief Executive Officer / Director General Inland Revenue Board of Malaysia Ms Selena Ling Head of Treasury Research & Strategy, OCBC Bank
Morning Session 11.45am-12.15pm 12.15pm-2.00pm Analysing treaty policy trends in a post-beps world Action 6 in the OECD's BEPS Action Plan proposed a series of measures to control the abuse of treaties. It has not been easy to organise a consensus on what and how to do. Some countries have also taken unilateral measures. This paper examines the current state of developments in protecting against treaty abuse. Professor Graeme Cooper Professor of Taxation Law, University of Sydney Lunch Afternoon Session 2.00pm-2.30pm Keynote Address 2 Tax Disputes and the role of MAP and Arbitration? How can revenue authorities and taxpayers leverage on Mutual Agreement Procedures to resolve differences? Is there a bigger role for effective resolution of disputes through arbitration? What lessons are there for Asian authorities thinking about disputes resolution mechanisms? Professor David Rosenbloom Director, International Tax Program New York University School of Law 2.30pm-3.00pm 3.00pm-3.30pm Analysing the likely trends in limitation of benefits in Asian Tax Treaties post-beps Limitation of benefits is one of the two options in dealing with misuse of treaties. How could this option be adopted and adapted in Asian tax treaties? Mr Andy Baik Researcher of SMU-TA CET International Director, Asia Pacific Tax Centre US Tax Desk, Ernst & Young Solutions LLP Taxing and Pricing the Intangibles The BEPS work has resulted in significant modification of transfer pricing rules related to the development and exploitation of intangibles, the transfer pricing treatment of hard to value intangibles, the treatment of risks related to intangible development and the use of cost contribution arrangements. What are the complex issues and global debates surrounding the taxation, pricing and valuation of intangibles? What are the practical solutions that Asian tax communities could adopt and mitigate tax risks in the present global environment? Mr Alan Ross Researcher of SMU-TA CET
Afternoon Session (cont.) 3.30pm-4.00pm 4.00pm-4.30pm 4.30pm-5.00pm 5.00pm-6.00pm Tax Structures using Branches and Hybrid Entities Moving with the times Recent developments in international taxation has brought renewed focus on the use of tax efficient structures. Will the use of branches in a typical central entrepreneur/principal supply chain model still work in light of the international developments? Are hybrid entities being used to obtain Singapore tax benefits and what are the policy responses for Singapore in the light of the evolving international tax rules? Ms Yong Sing Yuan Group Tax Specialist International Tax Branch Inland Revenue Authority of Singapore Coffee Break Ms Cindy Wong Group Tax Specialist Corporate Tax - Large Corporations Branch Inland Revenue Authority of Singapore New Technologies and Information Requirements in post- BEPS world is Asia ready? The post-beps world will see more taxpayers reporting and information sharing amongst revenue authorities. What capabilities and transformation would be needed in data infrastructures to keep compliance costs in check and data secured? Mr Jeff Westphal Chief Executive Officer Vertex Panel Discussion: In pursuit of Tax Research for Growth, Tax Competition and Development Chairman: Prof Dr Jeffrey Owens Director, WU Global Tax Policy Center Institute for Austrian and International Tax Law, WU Chairman, SMU-TA CET Technical Advisory Panel Members: Mr Tay Hong Beng Partner, Head of Tax KPMG in Singapore Professor David Rosenbloom Director, International Tax Program New York University School of Law Mrs Eng-Tay Geok Lee Chief Executive Officer, Tax Academy of Singapore Deputy Commissioner (Business) / Chief Compliance Officer Inland Revenue Authority of Singapore 6.00pm End
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. Professor Eric M. Zolt Michael H. Schill, Distinguished Professor of Law UCLA School of Law Eric Zolt is the Michael H. Schill Distinguished Professor of Law at the UCLA School of Law. His recent scholarship has focused on taxation in developing countries and on the relationship of inequality and taxation. Working with the International Monetary Fund, the World Bank, the United Nations, US AID and the US Treasury Department, Eric has served as a consultant on tax policy matters in over 30 countries. Before coming to UCLA, he was a partner in the Chicago law firm of Kirkland & Ellis. Eric served in the US Department of Treasury, first as Deputy Tax Legislative Counsel and then as founder and director of Treasury s Tax Advisory Program in Eastern Europe and the Former Soviet Union. Dr Yip Chun Seng Principal Economist (Fiscal Policy) Ministry of Finance, Singapore Dr Yip is Principal Economist (Fiscal Policy) at the Ministry of Finance (MOF), and also heads up the Economics Unit at the Land Transport Authority (LTA). He has previously worked at MTI and the Department of Statistics. Dr Yip earned his Ph.D. in Economics from the University of Pennsylvania with a focus on empirical microeconomics and labour economics, and was on the Economics faculty at the Singapore Management University from 2004 to 2009. He has been a Singapore Government Economist since 2007.
Professor Graeme Cooper Professor of Taxation Law, University of Sydney Graeme Cooper is Professor of Taxation Law in the Faculty of Law, University of Sydney, where he specialises in corporate and international tax. He also teaches at the University of Virginia (USA). He has been a Visiting Professor at New York University Law School, Harvard Law School, Tilburg and KU Leuven. He also works as a consultant to Greenwoods & Herbert Smith Freehills, specialist tax advisers in Sydney. From 1995-98, he worked in the Fiscal Affairs Division of the OECD in Paris and has worked as a consultant for the UN, IMF, World Bank, several foreign governments and a number of international NGOs. In Australia, he has worked as a consultant for the Australian Treasury, the Board of Taxation, the Australian National Audit Office and the Australian Taxation Office. Professor David Rosenbloom Director, International Tax Program New York University School of Law Professor H. David Rosenbloom became director of the International Tax Program in 2002. 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 1981. 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. Mr Andy Baik Researcher of SMU-TA CET International Director, Asia Pacific Tax Centre US Tax Desk Ernst & Young Solutions LLP Andy has served in many strategic roles at EY and at another Big 4 firm. He led the International Tax practice in Asia Pacific at both firms, was the tax leader at EY s Korean member firm and headed up the global Sovereign Wealth Fund (SWF) tax practice in the Asia Pacific region. Andy currently heads up EY s global SWF tax practice and focuses on serving the cross border tax needs of private equity, SWF and pension fund clients. He is also involved in advising large US and other MNCs on pan-asian tax matters. Andy is a frequent author on international tax subjects and has written articles on topics such as the U.S. check-the-box regulations, passive foreign investment companies, tax risk management in Asia and tax planning in Asia. Andy speaks regularly at seminars dealing with crossborder transactions.
Mr Alan Ross Researcher of SMU-TA CET Alan has over 34 years experience in international tax and transfer pricing issues. During his career Alan specialized in leading large, strategic projects for multinationals engaged in realigning their global business structures with particular focus on intellectual property management. Alan has vast Asian experience having spent 15 years in the region focussing on issues across the Asia Pacific region. He was PwC Singapore s Tax Practice Leader for 4 years up to December 2014. Prior to that Alan held various leadership and functional roles in PwC in a number of countries, as well as with a major multinational with operations in over 90 countries. While Alan has now retired from PwC and full time consulting, he continues to undertake some international consulting work from his home office in Canada. Mr Jeff Westphal Chief Executive Officer Vertex Mr Westphal has led Vertex through three decades of growth and four generations of technology development. Vertex is the largest independent tax software company in the world, serving 80 percent of U.S. Multinationals and a rapidly growing list of EU and Asian companies. After acquiring the tax technology assets of Arthur Andersen in 2002, Vertex remains the only company with major technologies in VAT, Corporate Income, Sales, Telecomm and Payroll taxes. Mr. Westphal has served as CEO since 2001. He currently serves as Chair of the MidMarket CEO Council of The Conference Board and is a member of the World Presidents Organization (YPO/WPO) and the Institute for Professionals in Taxation (IPT). Ms Yong Sing Yuan Group Tax Specialist International Tax Branch 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.
Ms Cindy Wong Group Tax Specialist Corporate Tax Large Corporations Inland Revenue Authority of Singapore Ms Cindy Wong is currently a Group Tax Specialist with the Inland Revenue Authority of Singapore. She is involved in policy reviews on corporate tax issues and handles tax assessment matters for large corporations that have been awarded tax incentives by the Singapore Government. Since joining IRAS in 2001, Cindy has been engaged in a broad spectrum of tax work on individual and corporate income tax. Cindy holds a Bachelor of Accountancy with 1st Class Honours from the Nanyang Technological University and a Masters in Law and Accounting (with Distinction) from the London School of Economics and Political Science. She is also an Accredited Tax Practitioner with the Singapore Institute of Accredited Tax Practitioners. Tay Hong Beng Partner, Head of Tax KPMG in Singapore Hong Beng heads up the KPMG Tax practice in Singapore. He joined KPMG in 1990 and has more than 25 years of experience in international and local corporate taxation specialising in complex cross-border structuring and M&A transactions in the real estate and financial services sectors. He is an Accredited Tax Advisor (Income Tax) and also a Board Member with the Singapore Institute of Accredited Tax Professionals Limited and Tax Academy Singapore (TA). Hong Beng is also a Chartered Accountant (ISCA) and a Fellow Member (FCPA) of Certified Public Accountants of Australia. He is also a member of the SMU-TA CET Technical Advisory Panel. Hong Beng is also a regular speaker at tax seminars. Mrs Eng-Tay Geok Lee Chief Executive Officer, Tax Academy of Singapore Deputy Commissioner (Business) / Chief Compliance Officer Inland Revenue Authority of Singapore Mrs Eng-Tay Geok Lee is the CEO of Tax Academy, and also the Deputy Commissioner (Business) and Chief Compliance Officer of the Inland Revenue Authority of Singapore.
Tan Sri Datuk Wira Dr. Mohd Shukor Hj. Mahfar Chief Executive Officer, Inland Revenue Board of Malaysia (IRBM) Tan Sri Datuk Wira Dr. Mohd Shukor Hj. Mahfar is the current CEO of IRBM. Under his leadership, IRBM has undergone very notable transformations which have led to improved service delivery and increased in tax collection year after year. He has received many prestigious awards including the Visionary Leader of the Year Award - Mc Millan Woods Global Awards 2015 - Personality Class Category. He is Adjunct Professor of Universiti Utara Malaysia, Universiti Teknologi Mara, Universiti Tenaga Nasional, Universiti Malaysia Perlis, Universiti Tun Abdul Razak and University Technology College of Sarawak. Ms Selena Ling Head of Treasury Research & Strategy, OCBC Bank Ms Selena Ling, Head of Treasury Research & Strategy, OCBC Bank, has more than 20 years of research experience. She is the Chief Economist at OCBC Bank. She is responsible for treasury market research, forecasts and trading recommendations for the Bank, covering different asset classes, as well as providing macro-economic insights. Her team is ranked very highly for macroeconomic research, currency strategy, interest rate research, credit research and market coverage in Asia by various polls. Ms Ling focuses primarily on the Singapore economy and interest rates research.