This content is from: Direct Tax

Industry insights for Asian taxpayers

Tax directors from some of the largest multinational companies, including Siemens, Caterpillar, Noble, GE, Citi and Standard Chartered, will share their transfer pricing insights and experiences in Singapore later this month.

Speaking at International Tax Review and TPWeek’s second annual Global Transfer Pricing Forum in Singapore, these tax directors will cover issues relating to BEPS, permanent establishment, supply chain restructuring, financial services, dispute resolution and indirect tax. There will also be regional focuses on the Indian APA regime and how to negotiate with the authorities there, China’s input to transfer pricing policy and the developing regime of Indonesia.

Delegates will get a global perspective on transfer pricing including practical lessons from Europe, US insights and experiences from the Asian region.

To register, contact mfabri@euromoneyplc.com

Agenda

Day 1

08.30 Registration and breakfast

09.00Chairman’s opening remarks

09.30 BEPS and other policy developments
What the OECD’s Base Erosion and Profit Shifting project will mean for a company’s tax and transfer pricing arrangements is still unclear, but one thing most taxpayers will agree on is that its impact will be significant. This debate will look at:

§ Recent updates in the project’s development

§ Economic substance and planning

§ Permanent establishment issues

§ What the tax avoidance news headlines really mean

Amit Bhalla, Vice President, Tax & Customs APAC, Schneider Electric
Jitendra Jain, Vice President - Transfer Pricing CoE, GE
Paolo De Salvia, Group Head of Tax, Noble
Cheng Chi, Partner-in-Charge, China & Hong Kong, KPMG
Kari Pahlman, Principal, Asia Pacific Leader, KPMG

10.45 Coffee

11.15 India's APA programme
India’s new APA programme is welcome news for any taxpayer with operations in the country. But, as with many tax developments in India, the process is not necessarily straight forward. Taxpayers and experts will take taxpayers through the specifics of the programme and will provide tips and recommendations for negotiating with the relevant authorities.

§ The new programme

§ How to make the most of your application

§ How to negotiate with the authorities

§ Case studies

Kanupriya Prashar, Head of Transfer Pricing, Bharti Airtel
Nitin Gupta, Director - Tax & Trade, Alcatel Lucent
S.P. Singh, Transfer Pricing Partner, Deloitte
Tarun Arora, Transfer Pricing Partner, Deloitte

12.30 Lunch

2.00 Control transfer pricing volatility and drive financial performance
Inconsistencies in the implementation of transfer pricing policies pose a number of challenges for multinational corporations. Learn how the three key areas of process, people, and technology in operational transfer pricing can work in tandem for companies to ensure robust execution of transfer pricing policies.

§ Defining processes and controls governing the transfer pricing lifecycle

§ Maintaining data integrity and consistency

§ Transforming the standard reactive approach to transfer pricing into an efficient, intuitive process

Michael Velten, Partner, Deloitte
Vineet Rachh, Head of Tax, Jabil Circuit
David Jan, Client Service Consultant, Thomson Reuters

3.15 Coffee

3.45 China’s global TP impact
China represents a new global tax and transfer pricing powerhouse with its own approach to taxation to ensure it gets its fair share of companies’ profits. Included in its stance on transfer pricing are the China chapter of the UN’s Practical Manual on Transfer Pricing for Developing Countries. Multinational taxpayers and resident advisers will explain what the UN manual means for companies and how to negotiate contract R&D matters

§ The UN chapter for China: What does it mean?

§ Contract R&D

§ Working with autorities on a local and state level

§ Case studies with valuable lessons

Han Jin Ping, Senior Tax Manager, Siemens
Frank Xue, Tax Director - Special Projects, Honeywell International
Cheng Chi, Partner-in-Charge, China & Hong Kong, KPMG
Kari Pahlman, Principal, Asia Pacific Leader, KPMG

4.45 Why indirect tax has a significant impact on you TP department
Transfer pricing is closely linked to customs and other indirect taxes. However valuation, for indirect taxation purposes, can have a significant impact a company’s transfer pricing strategies and so it is increasingly important to coordinate the two.

§ Tax effective supply chain management: How to coordinate your indirect taxes and transfer pricing

§ Lessons from Europe: Impact of EU VAT Directive

Douglas Mackay, Indirect Tax & Customs Director Asia Pacific, Lear Corporation

Shubhendu Misra, Partner, EY

5.45 Chairman's closing remarks

6.00 Cocktail reception


Day 2

08.30 Registration and breakfast

09.00Chairman’s opening remarks

09.30 Supply chain restructuring
Without constant attention, it can be easy to let your supply chain become too complex and fall into disarray. Companies strive to implement simplified models but in reality it can be difficult to know where to start. This discussion will help taxpayers:

§ Determine best practices

§ Learn from audit experience in Europe

Gaetano Pizzitola, Partner, Cross-Border Tax, Crowe Horwath

10.45 Coffee

11.15 Financial services
Few industries are more international than financial services. New transfer pricing rules and reforms usually have as significant an impact on such taxpayers as any others. When you include requirements that are particular to the sector and which also affect transfer pricing, you have a demanding agenda that transfer pricing managers in financial services companies have to keep on top of. Among the topics this panel will cover are:

§ What capital and liquidity buffers mean for transfer pricing

§ Transfer pricing risk management for financial services companies

§ Latest practice on guarantee fees and its effect on intra-group loan pricing

§ Documentation requirements in the financial services industry

Sam Sim, Deputy Head, Global Transfer Pricing, Standard Chartered Bank
Jesse Kavanagh, Head of Tax, Asia Ex-Japan, Nomura Securities
Tobey Hill, Asia Regional Tax Director, Citi

12.30 Lunch

2.00 Dynamic developing countries: Indonesia focus
Aside from BRICS nations, dynamic developing countries are undergoing rapid developments in their transfer pricing regimes. Indonesia is a prime example of these countries and its changes to the legislation over the past year will have a big impact on the vast number of taxpayers with dealings in the jurisdiction.

§ Regulations update

§ What this can mean for your business

§ Implementation issues

§ What's coming up for Indonesian taxpayers

Herawan Yunendra Hardi, Section Chief of Tax Audit on Corporate Group Transactions, Indonesian Revenue Authority
Prasetyono Hendriarto, Transfer Pricing Specialist, PT Adargo Energy
Sri Wahyuni Sujono, Managing Partner, SF Consulting

3.15 Coffee

3.45 How to make the most of TP dispute resolution options
The culture for transfer pricing dispute is changing. While taxpayers can find themselves in increasingly uncertain positions, there are more and more options for resolution available to them. Taxpayers will hear from multinational taxpayers experiencing disputes, in particular in relation to intangible assets, and also from experienced advisers who can guide taxpayers through the various options available to them and provide key takeaways from global case studies.

§ Notable cases and what you can learn

§ Negotiation tips with the authorities

§ How to avoid a dispute; common mistakes

John Drewno, Transfer Pricing Manager, Caterpillar
Prasetyono Hendriarto, Transfer Pricing Specialist, PT Adargo Energy

4.45 Chairman's closing remarks

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