SMU-TA Centre for Excellence in Taxation Inaugural Conference: A New Equilibrium in Tax Competition and Global Tax Co-operation?

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1 Date: 17 September 2015 Time: 9.00am to 6.15pm Venue: Marina Mandarin Singapore Leo & Taurus Ballrooms 6 Raffles Boulevard, Marina Square, Singapore Seminar Fees: $535 (includes GST) Businesses can claim 400% Tax Deduction or 60% Cash Payout of the course fee (net of government grant or subsidy) under Productivity and Innovation Credit scheme for training of their employees. For details, please refer to: edit.aspx This seminar is designed for: business and tax community, tax / finance / accounting / legal Professionals, academics, Government policy makers and tax administrators Closing date for registration: 28 August 2015 Registration: Please /fax the completed form to reserve a place at the seminar and request for invoice. For enquiries, please contact: Jocelyn Chong DID: (65) Amuna Manyuni DID: (65) seminars@taxacademy.sg Fax: The SMU-TA CET reserves the right to cancel the event, or make changes to the schedule, venue and speakers. SMU-TA Centre for Excellence in Taxation Inaugural Conference: The SMU-TA Centre for Excellence in Taxation is pleased to present its inaugural conference on and Global Tax Co-operation? This conference represents a unique forum for tax practitioners, policymakers and academics to discuss key issues on international tax policies and trends with particular focus on Asia. You will hear leading thoughts on the directions of tax competition and how governments will find the opportunities and challenges in use of tax tools for growth and development. Can tax incentives tools be designed to be more effective and meet the new international tax standards? You will garner the views of government and revenue officials and experts on the way forward for tax competition. CET researchers will present their findings on how many of the BEPS recommendations will operate for Asian economies. You will hear about the new rules in taxing of intangibles, in limiting access to treaties and preventing of treaty abuses and how these could possibly be implemented for Asia economies. The tax community has to brace itself for more tax reporting requirements and the transparency arising from more information sharing amongst governments. And in the evolving international tax world, tax disputes seem to an emerging inevitable. How can tax practitioners and governments in the region work together to resolve such disputes. Hear from a distinguished line-up of speakers and panelists amongst them - Prof Dr Jeffrey Owens, Professor Eric M. Zolt, Prof David Rosenbloom, Joseph Andrus, Andy Baik and Jeff Westphal. About SMU-TA Centre for Excellence in Taxation SMU-TA Centre for Excellence in Taxation (SMU-TA CET) is set up by Tax Academy and the Singapore Management University, with a mission to produce robust research in international and regional tax issues for policydevelopment and engagement of the international tax community. The SMU- TA CET is the first centre in Singapore that is dedicated to the research on taxation.

2 Morning Session 8.15am-8.55am 9.00am-9.10am Registration Conference Opening 9.10am-9.45am Keynote Address 1 Tax Competition in the New World - Opportunities and Challenges for Governments The economic realities of attracting investments, generating jobs and finding growth remain, particularly for many Asian emerging economies. However, fiscal costs in tax competition could be high. Will governments shun tax competition? 9.45am-10.15am 10.15am-10.45am 10.45am-11.45am 11.45am-12.15pm 12.15pm-1.45pm Designing Effective Tax Incentives - Maximizing the Benefits and Minimising the Costs What are the elements in the design and implementation of a robust and effective tax incentive system? What are benchmarked practices that can be drawn from the experiences of countries like Singapore? Coffee Break Panel Discussion: Growth, Tax Competition and the Future of Tax Competition in post-beps World with particular focus on Asia How to design pro-growth tax systems in the region? How to reconcile the need for competitive tax systems with a fair distribution of the tax burden? Analysing treaty policy trends in a post-beps world Action 6 in the OECD's BEPS Action Plan proposed a series of measures to control the abuse of treaties. It has been easy to organise a consensus on what and how to do. Some countries have also taken unilateral measures. This paper examines the current state of developments in protecting against treaty abuse. Lunch Afternoon Session 1.45pm-2.15pm Keynote Address 2 Tax Disputes and the role of MAP and Arbitration? How can revenue authorities and taxpayers leverage on Mutual Agreement Procedures to resolve differences? Is there a bigger role for effective resolution of disputes through arbitration? What lessons are there for Asian authorities thinking about disputes resolution mechanisms?

3 Afternoon Session (cont.) 2.15pm-2.45pm 2.45pm-3.15pm 3.15pm-3.45pm 3.45pm-4.15pm 4.15pm-4.45pm 4.45pm-5.15pm 5.15pm-6.15pm 6.15pm Analysing the likely trends in limitation of benefits in Asian Tax Treaties post-beps Limitation of benefits is one of the two options in dealing with misuse of treaties. How could this option be adopted and adapted in Asian tax treaties? Implications of BEPS on Intangibles The BEPS work has resulted in significant modification of transfer pricing rules related to the development and exploitation of intangibles, the transfer pricing treatment of hard to value intangibles, the treatment of risks related to intangible development and the use of cost contribution arrangements. The BEPS work has also considered the appropriate scope of country patent box regimes designed to attract intangible development activity. What would be the impact of these BEPS developments on corporate activities relating to the development and exploitation of intangible assets? Taxing and Pricing the Intangibles What are the complex issues and global debates surrounding the taxation, pricing and valuation of intangibles? What are the practical solutions that Asian tax communities could adopt and mitigate tax risks in the present global environment? Coffee Break Tax Structures using Branches and Hybrid Entities Moving with the times Recent developments in international taxation has brought renewed focus on the use of tax efficient structures. Will the use of branches in a typical central entrepreneur/principal supply chain model still work in light of the international developments? Are hybrid entities being used to obtain Singapore tax benefits and what are the policy responses for Singapore in the light of the evolving international tax rules? New Technologies and Information Requirements in post- BEPS world is Asia ready? The post-beps world will see more taxpayers reporting and information sharing amongst revenue authorities. What capabilities and transformation would be needed in data infrastructures to keep compliance costs in check and data secured? Panel Discussion: In pursuit of Tax Research for Growth, Tax Competition and Development End

4 Prof Dr Jeffrey Owens Director, WU Global Tax Policy Center Institute for Austrian and International Tax Law WU (Vienna University of Economics and Business) Chairman, SMU-TA CET Technical Advisory Panel Jeffrey Owens chairs the SMU-TA Centre for Excellence in Taxation Research Committee. He is the Director of the WU Global Tax Policy Center at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). He is also the Senior Policy Advisor to the Global Vice Chair of Tax at EY, advisor to the World Bank and UNCTAD and a number of regional tax administration organizations. For over 20 years, Jeffrey led the OECD Tax Work, establishing a major taxation program at the OECD and extensively developed the OECD contacts with non-member countries. He initiated the dialogue with the G20 on taxation and oversaw the G20/OECD initiatives to improve tax transparency, laying the foundation for the Base Erosion Profit Shifting work. Jeffrey is also involved in activities with a number of other NGOs. Professor Eric M. Zolt Michael H. Schill, Distinguished Professor of Law UCLA School of Law Eric Zolt is the Michael H. Schill Distinguished Professor of Law at the UCLA School of Law. His recent scholarship has focused on taxation in developing countries and on the relationship of inequality and taxation. Working with the International Monetary Fund, the World Bank, the United Nations, US AID and the US Treasury Department, Eric has served as a consultant on tax policy matters in over 30 countries. Before coming to UCLA, he was a partner in the Chicago law firm of Kirkland & Ellis. Eric served in the US Department of Treasury, first as Deputy Tax Legislative Counsel and then as founder and director of Treasury s Tax Advisory Program in Eastern Europe and the Former Soviet Union. Dr Yip Chun Seng Principal Economist (Fiscal Policy) Ministry of Finance, Singapore Dr Yip is Principal Economist (Fiscal Policy) at the Ministry of Finance (MOF), and also heads up the Economics Unit at the Land Transport Authority (LTA). He has previously worked at MTI and the Department of Statistics. Dr Yip earned his Ph.D. in Economics from the University of Pennsylvania with a focus on empirical microeconomics and labour economics, and was on the Economics faculty at the Singapore Management University from 2004 to He has been a Singapore Government Economist since 2007.

5 Professor Graeme Cooper Professor of Taxation Law, University of Sydney Graeme Cooper is Professor of Taxation Law in the Faculty of Law, University of Sydney, where he specialises in corporate and international tax. He also teaches at the University of Virginia (USA). He has been a Visiting Professor at New York University Law School, Harvard Law School, Tilburg and KU Leuven. He also works as a consultant to Greenwoods & Herbert Smith Freehills, specialist tax advisers in Sydney. From , he worked in the Fiscal Affairs Division of the OECD in Paris and has worked as a consultant for the UN, IMF, World Bank, several foreign governments and a number of international NGOs. In Australia, he has worked as a consultant for the Australian Treasury, the Board of Taxation, the Australian National Audit Office and the Australian Taxation Office. Professor David Rosenbloom Director, International Tax Program New York University School of Law Professor H. David Rosenbloom became director of the International Tax Program in He is a member of Caplin & Drysdale, a law firm he rejoined in 1981 after serving as international tax counsel and director of the Office of International Tax Affairs in the US Department of the Treasury from 1978 to A frequent speaker and author on tax subjects, Rosenbloom has taught international taxation and related subjects at numerous law schools including Stanford, Columbia, the University of Pennsylvania, and Harvard. He has also served as a tax policy adviser for the US Treasury, the OECD, USAID, and the World Bank in Eastern Europe, the former Soviet Union, Senegal, Malawi, and South Africa. Mr Andy Baik Researcher of SMU-TA CET International Director, Asia Pacific Tax Centre US Tax Desk Ernst & Young Solutions LLP Andy has served in many strategic roles at EY and at another Big 4 firm. He led the International Tax practice in Asia Pacific at both firms, was the tax leader at EY s Korean member firm and headed up the global Sovereign Wealth Fund (SWF) tax practice in the Asia Pacific region. Andy currently heads up EY s global SWF tax practice and focuses on serving the cross border tax needs of private equity, SWF and pension fund clients. He is also involved in advising large US and other MNCs on pan-asian tax matters. Andy is a frequent author on international tax subjects and has written articles on topics such as the U.S. check-the-box regulations, passive foreign investment companies, tax risk management in Asia and tax planning in Asia. Andy speaks regularly at seminars dealing with crossborder transactions.

6 Mr Alan Ross Researcher of SMU-TA CET Alan has over 34 years experience in international tax and transfer pricing issues. During his career Alan specialized in leading large, strategic projects for multinationals engaged in realigning their global business structures with particular focus on intellectual property management. Alan has vast Asian experience having spent 15 years in the region focussing on issues across the Asia Pacific region. He was PwC Singapore s Tax Practice Leader for 4 years up to December Prior to that Alan held various leadership and functional roles in PwC in a number of countries, as well as with a major multinational with operations in over 90 countries. While Alan has now retired from PwC and full time consulting, he continues to undertake some international consulting work from his home office in Canada. Mr Joseph L. Andrus Consultant Former Head of the Transfer Pricing Unit, OECD Joseph L. Andrus is a transfer pricing consultant working primarily with the OECD and the United Nations. Prior to his retirement in 2014 he was the Head of the Transfer Pricing Unit at the OECD, where he led all of the transfer pricing work in the G20 / OECD Base Erosion and Profit Shifting Project. He has nearly 40 years of experience in transfer pricing matters and has been a transfer pricing partner in a major US law firm and a large global accounting firm. In the mid-1980s he served as the Deputy International Tax Counsel at the US Treasury Department. Mr Jeff Westphal Chief Executive Officer Vertex Mr Westphal has led Vertex through three decades of growth and four generations of technology development. Vertex is the largest independent tax software company in the world, serving 80 percent of U.S. Multinationals and a rapidly growing list of EU and Asian companies. After acquiring the tax technology assets of Arthur Andersen in 2002, Vertex remains the only company with major technologies in VAT, Corporate Income, Sales, Telecomm and Payroll taxes. Mr. Westphal has served as CEO since He currently serves as Chair of the MidMarket CEO Council of The Conference Board and is a member of the World Presidents Organization (YPO/WPO) and the Institute for Professionals in Taxation (IPT).

7 Hong Beng heads up the KPMG Tax practice in Singapore. He joined KPMG in 1990 and has more than 25 years of experience in international and local corporate taxation specialising in complex cross-border structuring and M&A transactions in the real estate and financial services sectors. He is an Accredited Tax Advisor (Income Tax) and also a Board Member with the Singapore Institute of Accredited Tax Professionals Limited and Tax Academy Singapore (TA). Hong Beng is also a Chartered Accountant (ISCA) and a Fellow Member (FCPA) of Certified Public Accountants of Australia. He is also a member of the SMU-TA CET Technical Advisory Panel. Hong Beng is also a regular speaker at tax seminars. Ms Yong Sing Yuan Group Tax Specialist International Tax Branch Inland Revenue Authority of Singapore Ms Yong Sing Yuan is currently a Group Tax Specialist in the Inland Revenue Authority of Singapore dealing in advanced pricing arrangements and mutual agreement procedures relating to transfer pricing issues. She has experience in tax policy work and international taxation matters. Sing Yuan holds a Bachelor of Accountancy with Honours from the Nanyang Technological University and a Master of Advanced Studies in International Tax Law with Honours from Leiden University. She is also an Accredited Tax Advisor with the Singapore Institute of Accredited Tax Practitioners. Sing Yuan is the course advisor and one of the trainers for the International Tax Programme conducted by the Tax Academy. She has also contributed to external journals such as the Bulletin for International Taxation by IBFD. Ms Cindy Wong Group Tax Specialist Tax Policy & Rulings Branch Inland Revenue Authority of Singapore Ms Cindy Wong is currently a Group Tax Specialist with the Inland Revenue Authority of Singapore. She is involved in policy reviews on corporate tax issues and handles tax assessment matters for large corporations that have been awarded tax incentives by the Singapore Government. Since joining IRAS in 2001, Cindy has been engaged in a broad spectrum of tax work on individual and corporate income tax. Cindy holds a Bachelor of Accountancy with 1st Class Honours from the Nanyang Technological University and a Masters in Law and Accounting (with Distinction) from the London School of Economics and Political Science. She is also an Accredited Tax Practitioner with the Singapore Institute of Accredited Tax Practitioners. Tay Hong Beng Partner, Head of Tax KPMG in Singapore

8 REGISTRATION FORM Two easy ways to register Fax: (65) Venue: Marina Mandarin Singapore Leo & Taurus Ballrooms 6 Raffles Boulevard, Marina Square, Singapore Provide your details Dr / Mr / Ms / Mrs / Miss (please circle where applicable) Full Name (please underline family name) Name to appear on nametag Organization Designation Mailing address address Telephone number Fax number Name and address of co-ordinator: (continue next page) 17 Sep 2015 SMU

9 REGISTRATION FORM 2 Payment options I enclose a cheque of SGD / USD made payable to Tax Academy of Singapore. Cheques should be crossed and made payable to Tax Academy of Singapore indicating the event title at the back of the cheque. Please attach the registration form with your cheque and send to: Attn: Ms Faridah Omar Tax Academy of Singapore, #B1-01, 55 Newton Road, Revenue House, Singapore (307987) Telegraphic Transfers Information concerning telegraphic transfers : a) An invoice will be issued upon receipt of your registration form. Bank information will be stated in the invoice to facilitate the telegraphic transfer. b) Applicant will bear all local and overseas bank charges for telegraphic transfers. c) A copy of the remittance advice to be faxed to (65) or ed to seminars@taxacademy.sg. Other information 1. Registration and payment Registrations for events are on a first-come-first-served basis. Foreign participants, who in their business capacity belong overseas and sponsored by overseas employers, are excluded from paying 7% GST. 2. Cancellation/Substitution policy There will be no refund for cancellation. Substitute is welcome and must be submitted in writing with personal details. 3. Others CPE letter (issued by Tax Academy of Singapore) is only awarded to participants who have signed for and attended the event. Please send me a CPE letter. 4. Disclaimer The SMU-TA CET reserves the right to cancel the event, or make changes to the schedule, venue and speakers. 17 Sep 2015 SMU