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Description
This is a one-day workshop covering two topical and timely tax topics: Transfer Pricing (TP) Compliance Rules in the morning (AM) and BEPS 2.0 in the afternoon (PM).
For Tax, TP and Finance managers with responsibility for Asia-Pacific, the challenge is to remain abreast of TP rule changes and to assess their relevance and impact for their compliance obligations. In this way, practitioners can pre-empt and monitor potential TP risks, their impact and mitigation.
In this course, we baseline the existing TP rules for a number of jurisdictions in S/E Asia. With reference to the more recent TP updates, we review the updates and use practical examples to illustrate the impact of the updates on compliance requirements, to assist practitioners in their risk management decisions. We additionally, overview recent OECD TP changes or guidance (not including the BEPS 2.0 guidance).
Also, the latest update on BEPS 2.0 will be covered, with a focus primarily on Pillar 2.
For most practitioners, Pillar Two is complex – especially:
- The scope, rule application and country GloBE rules implementation (noting differences in rules and effective dates apply in jurisdictions);
- The data and calculation requirements for taxpayers in respect of their in-scope jurisdictions – in addition to filing obligations; and
- Importantly, what taxpayers need to do now to be properly prepare for the execution of the Pillar Two rules in their jurisdictions.
The training will feature calculations to illustrate the determination of ETR and Top-up tax – as well as deciding where Top-up tax is collected.
This unique workshop format offers you the choice to attend either the AM, PM or one-day session.
AM Session: Latest Update: Transfer Pricing Compliance Rules A PRACTICAL Guide using Financial Illustrations click HERE
PM Session: Latest Update: BEPS 2.0, A Focus on Pillar 2 – A PRACTICAL Guide using Financial Illustrations click HERE
By attending the one-day session, you get to enjoy greater savings and buffet lunch. Register NOW!
Programme Outline
With reference to certain Asia country implementation and using practical examples, we will cover the following:
AM Session: 9am-12.30pm
- An Overview of TP rule Changes and Impacts:
- A high-level overview of TP rules, with a focus on recent TP changes and identification of common themes;
- A review of the impacts of recent TP updates on compliance through practical examples; and
- A review of compliance, audit and penalty updates.
- An Overview of Recent OECD TP Changes and Country Responses
Q&A
PM Session: 1.30pm-5.00pm
- Pillar One Overview:
- High-level overview of the current rules and status
- Pillar Two Overview and Implementation (primary focus):
- Underlying Pillar Two structure;
- GloBE model rules and rule ordering – featuring calculations at each step to determine jurisdictional ETR and Top-up Tax*;
- Asia country implementation and expected impacts (practical implementation and challenges); and
- How best to prepare now
- Expected Next Steps
* We will aim to feature a number of jurisdictions in the practical examples, but may be limited by the extent of GloBE rule implementation by jurisdictions at the scheduled date of this course.
Q&A
What you will learn
- Remain abreast of the evolving and complex TP compliance landscape in a number of jurisdictions in S/E Asia, to aid in TP risk management
- A baseline overview of existing TP legislation in a number of S/E Asia jurisdictions
- Gain a good understanding of the recent TP changes, TP audit themes and penalties in Singapore, Malaysia, Vietnam, Thailand, Indonesia and Cambodia
- Through practical examples, understand the impact of recent relevant TP updates on your TP compliance obligations
- Learn how to manage TP compliance risks and penalties
- Gain an update on the current progress of Pillar One implementation – and expected next steps
- Gain an understanding of the Pillar Two (GloBE) Rules, their application and key country implementations
- Understand the impact of the Pillar Two implementation on taxpayers in S/E Asia countries (through a review of examples)
- Taxpayers will learn what to do now to prepare for the execution of the BEPS 2.0 rules in their jurisdictions
Target Audience
- Business owners
- In-house tax professionals
- Finance professionals
- Middle management and above
Expert Speaker
Christine Schwarzl
Christine is specialised in providing Transfer Pricing advisory covering the Asia region, for over 10 years, from planning to transfer pricing defence support. Christine’s has worked with ‘big four’ firms and she has provided transfer pricing advisory to companies across a wide range of industries. She has a Masters in Tax from Sydney University, and advanced tax Diplomas from CIOT (UK) and Singapore Tax Academy. She has authored various papers and regularly provides transfer pricing training and presentations to tax and transfer pricing practitioners in Asia.