Speakers:
Wilson Cheng, Partner, Greater China Tax Controversy Co-Leader, Hong Kong Tax Controversy Leader, EY
Sangeeth Aiyappa, Director, Transfer Pricing, Greater China, EY
The concept of permanent establishment (“PE”) was first introduced in 1940s. This has not been mentioned frequently in Hong Kong as the taxability of profits has been to a great extent relied on the question of source of profits. After the launch of Base Erosion and Profit Shifting (BEPS) project by the Organization for Economic Co-operation and Development, the definition of PE has a new chapter internationally. The enactment of Inland Revenue (Amendment) (No.6) Ordinance 2018 has also brought the international standard to life in Hong Kong. Would this change of definition of PE bring more controversy or settlement of tax issues?
The purpose of this webinar is to provide insights on the change of meaning of PE in Hong Kong and its tax implication.
Details on how to join will be sent via email by 5pm the day before the webinar.
About the speakers
Wilson is a Tax Partner in Hong Kong, with more than 20 years of Hong Kong corporate tax and transaction tax experiences. He provides tax advisory and compliance services to conglomerates, listed companies as well as US and European-based multinational corporations.
His tax experiences include group structure rationalization, tax due diligence review, pre-acquisition tax structuring advice, cross-border transaction planning and compliance, IPO review and restructuring as well as tax accounting advice. He has extensive experience in dealing with Hong Kong tax authorities, for example assisting corporations in settling pro-longed tax disputes on contentious tax issues. More recently, he advised his clients on tax efficient procurement model and structure, withholding tax planning as well as the application of tax resident certificate for tax treaties between Hong Kong and overseas jurisdictions.
Wilson has diverse industry experience, including retail and consumer products, food and beverage, technology, real estate, entertainment, media and telecommunications sectors.
Wilson regularly contributes tax technical articles to newspapers and technical journals and is a frequent speaker at tax seminars organized by various professional bodies in Hong Kong. He also serves as the Committee Member of Association of Chartered Certified Accountants (ACCA) Hong Kong from 2018/19 onwards and is the co-chairman of the taxation sub-committee of ACCA Hong Kong. From 2012/13 to 2015/16, he was the Council Member of the Taxation Institute of Hong Kong and was the founding organizer of CTA Conference in Hong Kong.
Sangeeth has over 14 years of transfer pricing experience with Ernst & Young, with significant experience in Greater China, OECD and other Asian based transfer pricing documentation and planning.
Sangeeth has been involved in a wide range of transfer pricing projects covering tangible, intangible and service transactions. Her project experience includes the evaluation of inter-company pricing policies for planning and compliance purposes, defense documentation, documentation for advance pricing arrangements and setting up systems for accurate service cost allocations.
She has extensive experience with tax planning and cross-border tax structuring projects with respect to restructuring of principal structures, evaluating alternative operating models and redesigning transfer pricing policies/models.
Sangeeth also has experience in applying non-standard methods in the field of transfer pricing. Projects include trademark valuation with regression, intangibles valuation through real options, laffer curve analysis in the context of determining the optimal tax rate, and regression models to estimate arm’s length profits.
Sangeeth’s experience ranges over multiple industries including food, luxury goods, pharmaceutical, natural resources, chemicals, oil and gas, technology/software and consumer electronics companies.
Sangeeth was part of the core team that concluded the first ever APA in Hong Kong in June 2014, which was a bilateral agreement between Hong Kong and the Netherlands.
Pricing
- Member: HK$140
- Non-Member: HK$250
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