CCH Learning SEA


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In our ever changing world, we have seen the business operational models of MNCs evolve. In the last decades, more and more transactions are conducted across borders in managing the business globally.

With the increased number of cross border transactions and the increasing complexity of the business structures, coupled with the increasing complexity of tax rules in different jurisdictions, we are seeing also an increasingly complex set of the tax considerations.

Today, when we look at intercompany cross-border transactions, we need to consider the potential challenges from the respective tax authorities trying to ensure the appropriate amount of tax to be charged in their respective jurisdiction. Oftentimes this may lead to double taxation.

This topical programme is designed specifically to give participants a practical understanding of how to classify cross-border-transactions in an international perspective, so as to gauge the international corporate tax implications and understand how the network of Double Tax Treaty Agreements concluded may be a tool to avoid double taxation to occur.

Programme Outline

Different Types of Income and Taxation from a Singapore Domestic Law Perspective

  • International tax perspectives and taxability of the different classifications of Income:
    • Business profits
    • Real estate
    • Dividend
    • Interest
    • Royalty
    • Capital Gains, including those arising from related party cross-border transactions
  • Global Business Structures of MNCs; covering relevant sections from a transfer pricing perspective
  • Relevant reporting requirements and obligations

Double Tax Treaty Agreements / International Tax Considerations from Cross-Border Transactions

  • How the Double Tax Treaty Agreements are typically structured
  • What are the mechanics of the Double Tax Treaty Agreements
  • How to allocate taxing rights and the way(s) how double taxation is to be avoided
  • Sharing of some scenarios covering different types of income and how double tax treaties can be avoided

Managing Practical International Tax Considerations in Related Party Cross-Border Transactions

  • A focus on application of transfer pricing and managing the permanent establishment risks

International Tax Structures

Today policy makers in the international tax arena have drafted policies as to address the undesired outcome of corporate tax avoidance and/or aggressive tax planning strategies with a rationale that taxation should take place where economic value is generated and economic activity is carried out. The objective of the earlier mentioned strategies was typically achieving the best possible tax outcome for MNCs by getting tax on income to be deferred or for income to be taxed in no/low tax jurisdictions and claiming the tax deductions in high tax jurisdictions. We will highlight some examples by looking at some structures:

  • IP structure
  • Financing structure
  • Hybrid structure

Brief overview of BEPS 2.0 considerations

  • Addressing the current stage of the progress of implementation of the two pillars of BEPS 2.0


What you will learn

At the end of this workshop, you will:

  • Get an understanding of how cross-border transactions should be structured from a corporate tax perspective so as to avoid or reduce the risk of double taxation
  • Get practical pointers on managing direct tax exposures arising from cross-border transactions
  • Get an understanding on how to mitigate tax risks in the current and future international tax environment

Target Audience

  • Finance and Tax Professionals

Expert Speaker

Gene Kwee
Partner, Head of Tax APAC, Mazars Singapore

Gene Kwee is the partner leading the tax practice of Mazars Singapore. Additionally, he is also appointed as the Regional tax leader for Mazars in Asia Pacific.

His area of specialization is in cross-border tax planning, advising on private equity and venture capital structures, merger and acquisitions, transfer pricing and international tax advisory services. He has more than 22 years of experience as a tax advisor, including 12 years as an international tax lawyer for one of the big four accounting firms in Amsterdam and Singapore. Thereafter, he successfully set up and sold his own tax advisory and legal firm. After which, he successfully built the multidisciplinary tax practice of Mazars in Singapore.

Gene is a trained Civil and Tax Lawyer and has practiced in The Netherlands and in Singapore.

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