Chapter News 

US - Singapore tax treaty Survey

As part of the Treasury Liaison meetings, TEI met with the US Treasury (Tax Policy) and one of the items on the agenda was a discussion on a possible US/Singapore income tax treaty.  As such, please consider the following questions and provide your feedbacks with any facts or ideas that could help to build the case on the benefits of a treaty:

1)      Provide actual examples of double-tax (from a US perspective) that a US/Singapore income-tax treaty would eliminate;

2)      What is the effective tax rate from your company’s Singapore operations? (there is a view in Washington that many/most companies pay no or very little tax to Singapore); and

3)      What from your perspective are the benefits to the United States that a US/Singapore income tax treaty would provide?  

Thanks in advance for your help and please reply to Aaron Lam at Aaron.Lam@morganstanley.com and Dan Goff at dan.goff@xilinx.com.

 

TEI Asia Employment Committee

A career opportunity is available:

Philips - Corporate - China Tax Manager  - Shanghai

For the job description, please click here:

www.tei.org/chapters/asia/Chapter%20Documents/Forms/AllItems.aspx

To apply directly, please click here:    

http://careers.peopleclick.com/careerscp/client_philips/external/en/jobDetails.do?functionName=getJobDetail&jobPostId=207493&localeCode=en-us

   

TEI and Baker & McKenzie - Holding structure seminar

The event was held on April 13, 2010 in Hong Kong.  The presentations are now available at this web link:

www.tei.org/chapters/asia/Chapter%20Documents/Forms/AllItems.aspx

 

For news and activities on TEI EMEA chapters, click here:

www.tei.org/chapters/asia/Chapter%20Documents/Forms/AllItems.aspx

 

 Upcoming Meetings
 

(1) China's Tax Treaties: Qualifying for Benefits

Friday, August 20, 11:45am - 2:30pm

Offices of Baker & McKenzie, Unit 1601, Jin Mao Tower,
88 Century Avenue, Pudong, Shanghai

TEI and Baker & McKenzie invite you to a roundtable discussion on Friday, August 20, 2010.  China tax experts from Baker & McKenzie will host a discussion on "China's Tax Treaties:  Qualifying for Benefits".  China has entered into over 90 Double Tax Arrangements with other countries and regions.  Many of these offer treaty beneficiaries preferential withholding tax rates, far below China's standard withholding tax rates, which can reduce your China tax cost when repatriating profits.  However, the path to qualifying for treaty benefits in China is less than clear and inconsistently applied by local tax authorities.  We will discuss China's latest notices in this area, what are the grey areas, and how you can maximize your chances of prevailing. 

This event is intended to facilitate a smaller group discussion so space is limited.  If you wish to attend, please reply by July 30 to Jasson.tian@bakermckenzie.com with the following information:

Name:
Company:
Title:
Contact Information:

We will send you an email to confirm your attendance. This event is free of charge and will be conducted in English. Lunch will be served.
 
We look forward to seeing you on August 20.

 

(2) Korean Tax Roundtable Event

TEI and Kim & Chang

August 31 and September 1, 2010 - Hong Kong

TEI and Kim & Chang are very happy to extend our invitation for the two tax seminars in Hong Kong respectively on Tuesday, August 31 and Wednesday, September 1, 2010. This may be highly valuable as a number of Korean NTS officials will be also attending the both events.

The first seminar will be held at Morgan Stanley office at ICC, 46th floor, Kowloon on Tuesday, August 31 from 12:30pm to 3:30pm. We will start off with technical Korean tax updates, including changes in tax rules concerning M&As, tax rate reduction and consolidation rules, partnership regulations, etc. It will be followed by a transfer pricing session detailing the impact of the new contemporaneous documentation rules, proposed improvement on the transfer pricing regulations, etc. The last segment of the event on Tuesday will feature an interactive panel among the industry representatives and Kim & Chang advisors, focused on the topic of tax audit disputes in Korea related to transfer pricing and permanent establishment.

On Wednesday, September 1, the second seminar will be held in Central, Hong Kong from 12:30pm to 2pm. In the first half hour, Kim & Chang advisors will share current tax issues specifically related to financial services industry, such as thin-cap rules, withholding tax on bonds, pass-through private equity funds regime, etc. The remaining hour will feature an open-forum format session where the financial services industry professionals can share their concerns with the NTS tax officials in relation to certain tax policies, rules and administration impacting foreign financial services institutions operating in Korea.

For the both events, delicious lunch and refreshments will be provided to the attendees. If you have any dietary remarks, please also let us know so that we can accommodate. There will be more details (e.g., the venue for the second seminar) sent to you in August. These events will be free of charge. We sincerely hope you can make for these interesting and valuable seminars in Hong Kong.

Please send your RSVP for both or either of the events to Ms. Seung Yeon Lee via email at
zsylee5@kimchang.com or call at 822-3703-8020. Please provide your name, company and email contact so that we can confirm your attendance. 


 

(3) 2010 TEI US Tax Conference

Wed 1 to Fri 3 September 2010

Singapore

The Tax Executives Institute (TEI) and the Tax Academy of Singapore (TAS) are pleased to present the 3rd annual TEI US Tax Conference in Singapore on 1 to 3 September 2010. This 3-day program will step participants through the key features of the US tax system, beginning from the introductory level to more advanced concepts and features in US taxation. It is a unique training program not to be missed!! 

This event brings together top experts in US taxation from the tax and legal accounting profession. The program will feature experienced speakers from international accounting and law firms including: 

Baker & McKenzie Thomas R. May

Deloitte & Touche Vijay K. Dhingra, Aaron Grundman, Gyung Ho Kim, Jing Nealis and Steve Towers

Ernst & Young Andy Baik and Chris J. Finnerty

PricewaterhouseCoopers Michael Brevetta, David Friedel, Jennifer Kim and Junko Yamato

White & Case Eric N. Roose and Michael H. Shikuma

This is an event for both non-TEI and TEI members, please invite your colleagues.  Please click here for the flyer and registration form:  www.tei.org/chapters/asia/Chapter%20Documents/Forms/AllItems.aspx

 

(4) Permanent Establishments - Detecting and Minimizing Unintended Tax Liabilities

20 Sep 2010  |  9:00am – 6.00pm  |  Singapore (Venue to be advised)

TEI and Deloitte are very happy to extend an invitation to members only for a full day event in Singapore.

 Program Outline

The Concept of PE

Determining If You Have a PE

Tax Planning Tips On How To Avoid Or Quarantine PE Risks

1.   Introduction to PE

1.      Work through real-life case studies

 

1.    Work through real-life case studies

2.   Article 5

2.      Develop the analytical skills needed to determine if you have created a PE in your overseas operations

2.    Discover planning tips on how to limit your PE risks while achieving your commercial objectives

3.   OECD and UN Model Treaties

 

3.    Learn how to avoid or quarantine PE risks through the use of separate legal entities

 Benefits of attending

Understand

:

The concepts related to PEs 

Business Impact

:

Develop the analytical skills needed to determine if your organization has created a PE in your overseas operations

Practical Knowledge

:

By working through numerous “Live” case studies to consolidate your knowledge

Planning Tips

:

On how to limit your PE risks

Highlights

·     Interactive Discussions

·     Case Studies

·     Practical Know-How

Speaker

By Steve Towers,  International Tax Partner, Deloitte & Touche LLP Steve is the leader of Deloitte’s international tax practice in Asia Pacific.  He has 29 years of experience in international tax planning for multinational corporations.  During that time, Steve has worked in Deloitte’s offices in Sydney, Melbourne, London, New York and Singapore.   Steve has been listed (since 1997) in “The World’s Leading Tax Advisers” (Euromoney).  Currently, he is listed therein as one of Singapore’s leading tax advisers.

Lunch and refreshments will be provided to the attendees.  If you have any dietary remarks, please also let us know so that we can accommodate.  Further details (e.g., the venue) will be sent to you later.

To register

Please send your RSVP to Ms. Rachel Tan on or before Aug 20, 2010 via email at rachel.tan@ap.sony.com.  As we have limited seating capacity, registration will be on a first come first served basis.  Kindly provide the following so that we can confirm your attendance:

1)      Name

2)      Company

3)      Email address

 

(5) India Tax Forum

TEI and International Tax Review

Nov 12 and 13, 2010 - New Delhi, India 

We are please to announce that ITR and TEI have teamed up for another great event.   

Please refer to the flyer for registration details here: www.tei.org/chapters/asia/Chapter%20Documents/Forms/AllItems.aspx

Or visit www.internationaltaxreview.com/IndiaTaxForum

***Discounted rate for TEI members***

Benefits of attending:

* Understand the implications of the Direct Tax Code

* Gain practical solutions on how to adjust your tax strategy for 2011

* Find out how you can put together a more effective tax planning strategy

* Learn how to avoid the pitfalls of litigation

* Discover how international tax trends will affect your tax department

* Listen to the leading tax professionals discussing India corporate, international and indirect tax

* Assess the trends in dispute resolution

* Talk to your peers to learn how to streamline your tax department

* Prepare for the introduction of GST

 

(6) Mark your calendar - other upcoming TEI Asia events: 

TEI International Tax Conference (Region IX - EMEA & Asia) 

·  Organizers : Tax Executives Institute (TEI) and Ernst & Young
 

·  Dates : 26th - 27th January 2011

·  Venue : Dubai, Middle East

More details to follow on pricing, topics, and speakers. 

 

China International Tax Conference - postponed

BeijingChina International Tax Conference.  With presentations by and discussions panels featuring senior members of the SAT and IRS, this promises to be the leading high – powered China tax conference.  Sponsored by Skadden, Arps and other leading professional firms, this two day conference will bring together senior tax officials, outside experts and seasoned in – house professionals for a close-up look at China tax and how it compares to international norms. 

This event is postponed to a later date.

  

 

 

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