This programme is designed to help participants achieve a higher appreciation of tax planning techniques and how it can be applied to business decisions both locally and internationally. It will cover both local tax planning as well as international tax planning. As this is an advanced tax programme, the assumption is that participants are already conversant with basic tax laws and practice in Singapore. Other advanced tax topics such as tax incentives, transfer pricing and tax issues in mergers and acquisitions will also feature in this programme. Where applicable, practical examples, illustrations and case studies (including recent court cases) will be used to enable participants to relate and apply to real life tax situations.
Day 1
Introduction to tax planning and application of common tax planning techniques in the following areas:
- Full/partial tax exemption and residence status
- Taxability of trade income
- Deductibility of trade expenses
- Claims for capital allowances
- Utilisation of tax losses
- Managing withholding tax burden and obligations
- Claiming reliefs from double taxation
Overview of tax incentives and coverage on selected tax incentives, including:
- Headquarters tax incentives
- Development and expansion incentive
- Global trader programme
- Pioneer incentives for products and services
- Investment Allowance
Transfer Pricing and Anti-Tax Avoidance, including:
- Transfer pricing guidelines and consultation
- Advanced Pricing Arrangements and Mutual Agreement Procedures
- Intercompany loans and services
- Tax Evasion v Tax Avoidance v Tax Planning
Tax Issues in corporate mergers and acquisitions, including:
- Overview of corporate M&As
- Normal tax implications
- New tax framework for statutory voluntary amalgamations
- New M&A tax allowance and stamp duty remission for qualifying M&As
Day 2
Introduction to international tax planning including objectives of international tax planning and common techniques, including;
- Use of international holding company
- Use of international finance company
- Use of international purchase and sales company
Tax issues to consider when a company ventures overseas, including:
- Choice of investment vehicle
- Designing a tax efficient holding structure
- Planning the financing structure
- Profit repatriation
- Common pitfalls to avoid
- Taxation of foreign income in Singapore
Understanding the role of tax treaties in international tax planning, including:
- Overview of Double Tax Agreements (DTAs)
- Singapore’s DTAs
- OECD Model Tax Convention and Commentaries on various treaty articles
- Base Erosion and Profit Shifting (BEPS)