The Singapore Withholding Tax Masterclass

Transcription

1 The Singapore Withholding Tax Masterclass Exploring Concepts, Compliance & Planning 21 & 22 January am 5.00 pm Singapore Partner

2 The Singapore Income Tax Act places obligations on taxpayers to withhold tax when making certain payments to non-residents. Failure to do so in a timely manner could attract late payment penalties an additional maximum 20% on top of the withholding tax amount to be paid. As transactions are becoming more cross border in nature, understanding the practical issues related to withholding tax will be essential to avoid penalties being imposed for non-compliance. Wolters Kluwer presents a practical workshop designed to provide a complete and comprehensive analysis of withholding tax (WHT) for corporations. Also, this highly interactive workshop will offer technical insights into the withholding tax implications of transactions relating to secondment arrangements, construction, installation and assembly projects, consulting assignments and a selection of key income streams. This definitive workshop will equip you with best practice strategies to address key challenges related to concepts, compliance and planning of withholding tax. Target Audience For MNCs with voluminous foreign transactions Finance Directors Finance Managers Regional Tax Managers/Professionals 14 CPE Accountants Compliance Officers HOURS Top 6 Must-Attend Reasons 1.Be Updated on critical information and tools you need to: Analyse a transaction for withholding tax obligations Reduce foreign withholding tax or double taxation Mitigate this tax risk through double tax agreements 2. Learn how to identify and apply provisions in the tax treaties to ensure that your intra- group transactions are not incurring more withholding tax than necessary 3. Discover how to use relevant Articles of tax treaties to minimise your foreign withholding tax 4. Planning Tips on how to minimise withholding tax 5. Develop the analytical skills needed to determine if a transaction has withholding tax obligations 6. Find out the critical considerations when entering into agreements with non-residents Sivakumar Saravan Director, Tax and Corporate Advisory Crowe Horwath Singapore Siva has more than 19 years of experience in tax compliance and tax consultancy work for individuals as well as local corporations, multinationals and financial institutions. Siva has extensive experience in advising clients on international corporate and personal tax implications of cross-border transactions involving the various countries in the region. He has also advised on appropriate holding company structures for several multinational companies based in Singapore for their outbound investments into Europe and the Asia Pacific region. Siva is a member of Crowe Horwath s International Tax Committee and he has conducted several seminars on international tax to Crowe Horwath tax specialists in the Asia Pacific region as well as to members of the public. He is the author of CCH s Singapore Withholding Tax and Treaties Online, Crowe Horwath s Quick Guide to Business Tax in Singapore and Tax Essentials for HR Professionals. He is the consultant editor of CCH s Singapore Master Tax Guide manual. Siva is an accredited tax advisor of the Singapore Institute of Accredited Tax Professionals. He is also a member of The Institute of Singapore Chartered Accountants and the Singapore Institute of Arbitrators.

3 *Subject to conditions stipulated in the PIC scheme. Please refer to IRAS website for more details. Hear Excellent Reviews from Past Attendees Qualifies for Productivity and Innovation Credit (PIC) 60% Cash Grant* The most helpful is that Mr Siva not only explains the mechanism of the tax system but also the reasoning of the tax system, the objective of the tax policy. Also, Mr Siva interprets everything in a very easily understandable manner! ONE Basics Concept of Withholding Taxation of non-residents Applicable sections in the Income Tax Act Interpreting and understanding the law Applicable IRAS e-tax guides Importance of understanding withholding tax rules Transactions that are subject to withholding tax The Concept of Permanent Establishment Definition of PE under domestic law PE and implications to withholding tax Clarifications from IRAS Some practical issues and how to overcome them Tax Residency INTRODUCTION Relationship between tax residency and withholding tax Definition of tax resident Waiver of withholding for certain non-residents Framework for Complying With Withholding Tax Rules The key questions model to determining withholding tax Pointers on analysing transactions Examples and cases shared by the speaker had help me understand better on the application of WHT and if WHT issue is triggered. Practical tips on WHT treatments by IRAS. Siva provided me better interpretation on WHT. TWO ANALYSING WITHHOLDING TAX Payments Subject to Withholding Interest What is interest? Types of interest payments subject to withholding tax Royalty What is royalty?

4 Rental Rental defined Royalty versus rental Issues with mixed contracts Services IRAS Concessions and exemptions Applicability of withholding tax to certain payments: Commission Installation Cloud computing and other IT services Training Royalty versus services versus rental Flow chart for analysing withholding on services Management fee IRAS Concessions and exemptions Services versus management fee Flow chart for analysing withholding on management fee Directors fee Professional fee Definition of professional Entertainers, athletes, artistes Other payments SRS withdrawals Unit trust and REIT distributions Property transactions Junket promoter Review questions Withholding Tax Compliance When to withhold and pay IRAS? Withholding tax forms Certificate of residence Penalties Voluntary disclosure THREE USE OF TAX TREATIES IN INTERNATIONAL WITHHOLDING TAX PLANNING Understanding Tax Treaties Purpose of tax treaties Model Conventions: OECD Model, UN Model Structure of tax treaties Income allocation rules Step-by-step guide to applying the tax treaty provisions Conditions for Claiming Reduced Withholding Tax Rates Income characterisation Residency of recipient Beneficial ownership rules Other considerations Permanent Establishment Definition of PE PE and income allocation rules Types of PE Role of PE in relation to withholding tax planning Tax Treaties and Withholding Tax Planning Business profits article and PE mitigation Independent Services Article Planning for specific activities Consulting Training Management and technical services Construction project Secondment Claiming Tax Credit Tax credit mechanism Conditions for claiming foreign tax credits Tax residency issues Tax credit pooling Each participant will receive a complimentary copy of Crowe Horwath s Quick Guide to Business Tax in Singapore 2014 (4th Edition).

5 ENQUIRIES : / Fax: : events@cch.com.sg Website: Address: 8 Chang Charn Road, #03-00 Link (THM) Building Singapore Registration Form WORKSHOP DETAILS DELEGATE 1 DELEGATE 2 Salutation Mr Mrs Ms Dr The Singapore Withholding Tax Masterclass (0616STEB) Date: 21 & 22 January 2016 Time: 9.00am 5.00pm Venue: Hotel to be advised, Singapore Salutation Mr Mrs Ms Dr Seats are limited! Registrations are capped at 30 participants to maximise the effectiveness of this Masterclass. Name Name Job Title Job Title Special Dietary Requests (if any) Special Dietary Requests (if any) Company Address Fax Nature of Business Company Size Contact Person ENROLMENT STATUS WK Executive Events Corporate Member WK Subscriber Non-Subscriber SIATP Member FEE** (includes 7% GST) WK Executive Events Corporate Member WK Subscriber / SIATP Member Non-Subscriber Early Bird Fee (S$) (by 22 Dec 2015) $1, $1, $1, * Fee includes event materials, certificate of attendance, refreshments & lunch. PAYMENT OPTIONS Regular Fee (S$) (after 22 Dec 2015) $1, $1, $1, By Cheque (Bank Cheque No. ) Crossed cheque made payable to: CCH Asia Pte Limited Please send us an invoice By Credit Card MasterCard Visa TERMS & CONDITIONS Registration & Confirmation Registration will only be confirmed upon receipt of completed registration form. A confirmation will be sent to you from Wolters Kluwer to confirm your registration for the event. Payment Payment must be received prior the event. Please refer to Payment Options for payment details. Cancellation Full payment will be imposed if cancellation is made after 14 January This also applies to no show on the day of event. In such cases, a complete set of course materials will be sent to you at no additional charge. Notice of cancellation must be made in writing via / fax and acknowledged by Wolters Kluwer. Substitution A substitute delegate is allowed at no extra charge if you are unable to attend. Please inform Wolters Kluwer of the replacement in writing at least one week before the event. Programme Changes Wolters Kluwer reserves the right to cancel or make changes to the programme without any notification. Cardholder s Name Card No. I have read the Terms & Conditions and agree to abide by them. Expiry Date Amount Cardholder s Signature Signature & Company Stamp Date