Structuring Cross Border Investments
• Developing a regional/global tax structure to lower the group’s effective tax rate
• The use of holding companies in Asia
• Achieving tax arbitrage in funding cross border investments
• Withholding tax mitigation strategies
• Updates on key tax incentives in Asia
Offshore International Tax Planning
• General features of several offshore jurisdictions – an update
• Investment holding, financing, licensing & trading
• Strategies & common typologies
• Case study - case of offshore structure in a large multinational operation
Tax Incentives for Companies Venturing Abroad
• Financial and tax incentive schemes in Singapore to support internationalization
• What are their key criteria?
• Types and taxability of different business entities in ASEAN
• Cross border tax related issues
Interpretation & Application of Double Taxation Agreements
• Principles of double taxation and tax treaties
• Tax mechanisms for relief under DTAs
• Tax exemption on foreign sourced income
• Singapore tax treaty partners and the main features of Singapore DTAs
• Use of DTAs on withholding taxes
• Tax treaty planning possibilities
Managing Transfer Pricing in Asia
• Regional update of transfer pricing practices
• Issues and challenges of using Advance Pricing Agreements (APA) in Asia
• Structuring an appropriate transfer pricing policy in Asia
Mr Chester WeePartner, Asean International Corporate TaxAdvisory Leader, International Tax andTransaction Services
Ernst & Young Solutions LLP
Accredited Tax Advisor (Income Tax)
Chester has over 20 years of experience in providing cross-border incometax advisory, managing tax controversy and tax compliance andreporting.Chester focuses on cross-border direct tax advisory and planningmatters. He has extensive experience in areas such as intellectualproperty (IP) planning, legal entity rationalisation (LER), permanentestablishment (PE) issues.Chester has a diversified portfolio of clients covering a wide spectrum ofindustries including consumer products & retail, technology,transportation and logistics (including shipping).Over the years, Chester has been assisting businesses in reviewing holdingstructures and operating models; managing tax residence issues;identifying and managing withholding tax issues and PE risks; and advisingon IP strategies and migration, and tax efficient repatriation of profitsand cross-border financing. He has also advised US, European and Asianmultinational companies regarding the establishment of regional as wellas global supply chain management structures in Singapore.Chester regularly participates in EY’s Global Think Tanks. He speaksregularly at conferences and seminars, both in Singapore and overseas.He facilitates various international tax training modules for the TaxAcademy of Singapore.
Mr Stephen LamPartner, Transfer Pricing
Ernst & Young Solutions LLP
Stephen has worked in Asia since 2010, with over 20 years of advisory experience in transfer pricing. His experience includes designing, recommending and supporting tax and transfer pricing models in a variety of industries including apparel, e-commerce, fast-moving consumer goods, commodities, hi-tech, logistics, pharmaceutical and shipping. Prior to his time in Asia, Stephen spent over nine years in London advising European multinational corporations based in Belgium, France, Germany, the Netherlands, Republic of Ireland, Sweden and the UK. In addition, he spent three years in Taiwan, where he co-managed the transfer pricing team. Stephen has advised on projects including the restructuring of global supply chains for multinational corporations, global transfer pricing documentation projects, transfer pricing controversy (including APAs), cash pooling structures as well as IP structuring. Stephen is a frequent speaker at seminars and events on transfer pricing and operating model effectiveness and has written numerous articles on these topics as well. Stephen has a Double-Bachelor’s degree in Finance and Accountancy from the University of Adelaide (Australia). Stephen is also a member of the Singapore Chartered Professionals. Stephen is a facilitator for the Advanced Tax Programme (International Tax Module) conducted by the Tax Academy of Singapore.
Mr Mark AbbyDirector, International Tax Advisory
KPMG in Singapore
Mark is a director in the International Tax team at KPMG Singapore with 11 years of international tax experience, split between the UK and Singapore. He worked in KPMG UK's international tax and value chain management group until 2014, where he spent his time advising a number of high profile clients on the design and implementation of tax optimal cross-border holding, financing and transaction structures. Since moving to KPMG Singapore's international tax team, Mark has advised European, US and Asian MNCs on a variety of tax issues, including, among others, permanent establishment, withholding taxes, treaty application and tax residence. His clients span a wide range of industry sectors, including energy and natural resources, technology, FMCG and life sciences. Mark has also been teaching the Advanced International Tax Planning Programme at the Tax Academy since 2015.