2015 FINANCIAL SERVICES TAXATION CONFERENCE · AMP Financial Services Session 3B: Update on Capital...

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2015 FINANCIAL SERVICES TAXATION

CONFERENCE

18–20 February 2015 Surfers Paradise Marriott Resort & Spa

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2 - THE TAX INSTITUTE - 2015 Financial Services Taxation Conference

WELCOME2015 Financial Services Taxation Conference

On behalf of The Tax Institute and the 2015 Financial Services Taxation Conference Organising Committee, it gives me great pleasure to invite you to Australia’s leading financial services taxation conference. In 2015, the conference will be held at the Surfers Paradise Marriott Resort & Spa on the Gold Coast from 18 to 20 February. As with the 2014 conference, the program includes optional sessions which will be held on the afternoon of Wednesday 18 February.

The recommendations of the Murray Inquiry may significantly impact the Australian financial services industry. The tax and non-tax impacts of the Murray Inquiry will be the focus of the Wednesday sessions. Additionally, the Australian tax landscape for financial services continues to evolve, influenced by the ongoing international developments of BEPS, FATCA and GATCA and by developments closer to home, including the ATO’s changing approach to the resolution of industry issues.

Our conference program is wide-ranging, covering numerous tax issues of relevance to our industry, including infrastructure, TOFA, nominees and custodians, Part IVA, transfer pricing and thin capitalisation, among others. The committee is confident that the first-rate technical program and speakers will be of value to all financial services tax practitioners.

I’m sure you will find the 2015 Financial Services Taxation Conference rewarding and enjoyable.

See you on the Gold Coast.

Monica Jordan, FTI, Chair, Conference Organising Committee

Thank you The Tax Institute gratefully acknowledges the generous assistance of members of the Conference Organising Committee:

Monica Jordan, FTI, ANZ Banking Group (Chair, Conference Organising Committee)Patrick Broughan, CTA, DeloitteJames Campbell, Australian Taxation OfficeJoanne Dunne, CTA, Minter EllisonIan Fullerton, CTA, AshurstPatrick Grob, CTA, SuncorpMatt Hartshorn, CTA, Macquarie Funds GroupJulian Humphrey, CTA, KPMGTim Kyle, CTA, Greenwoods & FreehillsJames Loughhead, CTA, WestpacGavin Marjoram, CTA, PwCGrant Peters, CTA, Ernst & Young

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THE TAX INSTITUTE - 2015 Financial Services Taxation Conference - 3

TECHNICAL PROGRAMEvent summary

Pre-conference sessions – Wednesday 18 February 2015

Time Session Presenter

12.00pm–12.45pm Registration and light lunch

12.45pm–2.15pm Session A: The Murray Review into Australia’s Financial SystemThis session covers Murray’s Financial System Inquiry, specifically the non-taxation issues, the policy options to be addressed and their impact on the industry.

The Murray inquiry is reviewing the Wallis framework for the financial system to see how well it is suited to current conditions, taking into account the lessons from the GFC.

This session will consider the implications and challenges for the Murray Inquiry in developing a framework that has a 10 to 15-year vision for financial services.

Rob Colquhoun, ATI, Australian Financial Markets Association

Dr Stephen Kirchner, Australian Financial Markets Association

2.15pm–3.15pm Session B: The Murray Review Through a Tax LensThis session covers Murray’s Financial System Inquiry, specifically the taxation issues identified and possible policy responses and their impact on the industry.

The Murray Inquiry made a series of observations on certain aspects of the current taxation system which could distort the efficient allocation of capital in the financial system.

This session will consider the taxation observations from both a short-term (such as withholding taxes) and long-term (such as imputation) perspective.

Rob McLeod, EY

3.15pm–3.45pm Afternoon tea

3.45pm–5.15pm Session C: The Financial Services Tax Function in a Changing WorldThe level of both internal and external pressures challenging Australian corporates is at an unprecedented high. Demands on most tax functions are increasing, stretching resources to the limit. These demands are amplified for a large financial services tax function that has third-party reporting responsibilities for policyholders, unitholders, members and other investors. Tax functions such as these must be proactive, improve efficiencies and evolve through innovation.

This session will include a discussion of ways of improving the strategy and operating model for the tax function.

Facilitator: Greg Fitzgerald, CTA, Macquarie Group

Panellists:Robert Gallo, ATI, PwC

Warren Dunn, EY

Patrick Grob, CTA, Suncorp

5.15pm–6.30pm Free time

6.30pm–8.00pm Welcome drinks reception

Day one – Thursday 19 February 2015


8.00am–9.00am Registration

9.00am–9.15am Conference Opening Address and Senior Tax Counsel Update Robert Jeremenko, CTA, The Tax Institute

9.15am–10.30am Session 1: The Politics of Taxation ReformThere are approximately 125 taxes in the current Australian state and federal system. Since the Asprey report was issued in 1975, there have been a number of reviews of the taxation system, culminating in the most recent Henry Review. The government is preparing another review, the White Paper on Taxation. This session considers the past reviews and where Australia is on taxation reform. This session will consider the politics of taxation reform, including a view on how governments should approach taxation reform in Australia.

Dr John Hewson, AM, Crawford School of Economics

10.30am–11.00am Morning tea



Day one – Thursday 19 February 2015 (cont.)


11.00am–12.00pm Session 2: The ATO’s Changing Approach to Resolution of Banking and Finance Industry Issues The session will focus on:

� The ATO’s compliance approach to banking and finance industry issues, comparing past and present approaches

� Identification of industry issues � Approaches to consulting with key industry stakeholders � Options for resolution of industry issues illustrated by some recent examples.

Judy Morris, CTA, Australian Taxation Office

James Campbell, Australian Taxation Office

12.00pm–1.00pm

OR

Session 3A: Managed Investment Trusts: Where Are We Now?Managed Investment Trusts (MITs) are affected by a mix of regimes relating to withholding tax, deemed capital treatment and the new system for attributing the income of MITs. Each regime has a different level of maturity and different definitions have applied to MITs.

This session will cover practical issues that MITs encounter from the perspectives of a fund manager, institutional investor and tax practitioner. It will provide::

� Recap on common MIT issues under the withholding and deemed capital provisions and the current position

� Overview of the new MIT regime, including: – Transitional issues moving into the new MIT regime – Implications for trust constitutions – Calculation of trust components, including expense allocation – Attribution of amounts to unitholders and shortfall taxation – The treatment of under/over amounts – Cost base adjustments for unitholders.

Peter Oliver, CTA, KPMG

Brendan O’Brien, CTA, AMP Capital

John Kirkness, AMP Financial Services

Session 3B: Update on Capital Management Issues This session will provide an overview of recent capital management transactions, ATO rulings and government announcements, with a particular focus on the financial services industry. Topics to be covered include:

� Raising capital, including hybrid instruments and rights issues � Paying and franking dividends in light of the Corporations Act changes � Returning capital, including buybacks � Practical aspects of the share capital tainting provisions.

Tim Kyle, CTA, Greenwoods & Freehills

1.00pm–2.00pm Lunch

2.00pm–3.00pm Session 4: How Will the BEPS Action Plan Impact on Financial Services?The OECD’s BEPS action plan has the potential to impact financial services. This session addresses those actions that will impact financial services entities such as multinational entities. Topics include:

� An update on the OECD action plan � Hybrid entities � Transfer pricing � Tax transparency.

Michael O’Neill, Australian Taxation Office

3.00pm–3.15pm Afternoon tea


Day one – Thursday 19 February 2015 (cont.)


3.15pm–4.15pm

OR

Session 5A: BEPS Topics of Specific Interest to Financial Services The focus of this session will be on the action items most likely to affect financial services including:

� Challenges of the digital economy � Base erosion through interest and other financial payments, including the use of hybrid techniques

� Artificial avoidance of PEs � Prevention of treaty abuse � The impact of overlap between various action items.

Peter Collins, FTI, PwC

Session 5B: FATCA, GATCA/CRS: What Will Be The Impact? This session focuses on GATCA and Common Reporting Standard (CRS) as well as FATCA. Topics include:

� Finalisation of FATCA implementation issues � Lessons from FATCA – what worked, what didn’t � What is Common Reporting Standard (CRS) aka GATCA? � Key deliverables and timeline for CRS � How is CRS different from FATCA? � Approaches to implementation of CRS, including tips and tricks.

William Brown, CTA, Westpac

4.15pm–5.15pm

OR

Session 6A: InfrastructureIf election promises are held, we are likely to see a wave of infrastructure transactions in the coming years, from nation – transforming greenfield developments to privatisation of existing large-scale assets across many asset classes. We are also likely to see considerable innovation in the manner in which federal and state governments will provide support to those projects, whether through funding support or risk sharing. This session will explore:

� The importance of tax certainty in these transactions, how various stakeholders seek to obtain certainty and the practical issues in obtaining certainty from the ATO

� Specific issues that can arise where there is federal or state funding support for a project

� Current tax issues that create uncertainty, and what legislative, administrative or practical approaches could be taken to minimise uncertainty.

Addison Younan, CTA, National Australia Bank

Richard Buchanan, CTA, Greenwoods & Freehills

Session 6B: Recent Developments in Thin CapitalisationThis session considers recent developments and complex issues that impact thin capitalisation including:

� The Board of Taxation’s views on the arm’s length debt test � Foreign equity distributions � Prudential requirements � What does attribution mean? � What constitutes CFE equity and debt?

Sarah Bernhardt, CTA, Allens

5.15pm–7.00pm Free time

7.00pm–11.00pm Conference dinner




Day two – Friday 20 February 2015


8.15am–8.45am Registration

8.45am–9.45am Session 7: Managing Disputes Post-Independent ReviewThis session will present an ATO and advise perspective on dispute resolution post the implementation of the ATO’s independent review approach. Topics include:

� Current ATO approach: brief overview of independent review, objection and ADR processes (delineation from the ATO’s compliance function)

� The experience since independent review: the ATO’s and advisor/industry experience so far and where it might move to in the near future

� Role of the review and dispute resolution unit � Developments in ADR: an industry/advisor view.

Debbie Hastings, Australian Taxation Office

Sue Williamson, CTA (Life), EY

9.45am–10.45am

OR

Session 8A: Thorny TOFA IssuesThis session will provide an analysis of current TOFA issues, focusing on practical examples. This will include:

� Continuing uncertainty in the application of the TOFA rules to commonplace transactions in the financial services sector

� Hedging (and especially NIFO hedging) � Interactions between the TOFA provisions and other parts of the law.

James Pettigrew, ATI, Deloitte

Session 8B: Topical Custody IssuesThere are a number of practical and complex technical issues arising for custodians when dealing with domestic and foreign tax matters.

This session will focus on the impact on custodians and their clients of topical issues affecting the funds management and superannuation industries, arising from the increased use of foreign investments, the greater sophistication of the industry, its participants and regulators, and the greater investment choices being made available to investors and members of superannuation funds. Technical matters, such as the status of proposed amendments, the 45-day rule (including the impact of the dividend washing rules), enhanced third-party reporting requirements, and foreign withholding and financial transaction taxes will be addressed.

Zaf Kardaras, Northern Trust

10.45am–11.15am Morning tea

11.15am–12.15pm Session 9: Transfer PricingThe reconstruction provisions in Subdivi 815-B require taxpayers to assess whether the substance of the commercial and financial arrangements they have entered into is in accordance with the form of the arrangements, and whether independent parties acting at arm’s length would have entered into those arrangements. If the answer to either of those questions is “no”, the arrangements are reconstructed, or alternatively are treated as not having been entered into, before the “arm’s length conditions” are identified. The provisions require a broader analysis than simply their effect on pricing, as the tax implications of a reconstructed arrangement can differ from the tax implications of the actual arrangement, before pricing is considered.

This session examines the circumstances in which the reconstruction rules may apply and how the ATO intends to apply the rules. It also considers the interaction of the reconstruction rules with the thin capitalisation rules.

Ian Fullerton, CTA, Ashurst

Michael Jenkins, CTA, Australian Taxation Office

12.15pm–1.15pm Session 10: Financial Services Acquisitions and DisposalsThe session will review key income tax considerations from the perspective of both a purchaser and a seller in respect of M&A transactions in the financial services sector, including:

� The key issues of acquiring and selling entities out of a tax consolidated group � The role of tax-sharing agreements, “clear exits” and impact on potential liabilities � Implications for tax due diligence – what should be the focus? � Topical tax issues from recent financial services M&A transactions.

Teresa Dyson, CTA, Board of Taxation


Day two – Friday 20 February 2015 (cont.)


1.15pm–2.00pm Lunch

2.00pm–3.00pm Session 11: Part IVA Case law developments and the statutory changes have resulted in the evolution of the ATO’s views on Part IVA? In this session the ATO’s Chief Tax Counsel will:

� Expand upon noteworthy aspects of the ATO’s published views � Outline the ATO’s perspective on other issues, raised by the session chair, which remain to be addressed from the ATO’s perspective

� Outline the ATO’s approach to evidentiary aspects of the purpose and tax benefit elements.

The session chair will present further questions to the ATO as well as facilitating discussion with the attendees.

Jeremy Hirschhorn, Australian Taxation Office

Facilitator: Tim Kyle, CTA, Greenwoods & Freehills

3.00pm–4.00pm Session 12: Recent CasesThis session will review important case law which has been determined in the Federal Court and High Court since the 2013 conference, including an analysis of overall win-loss percentage. It will also consider significant case law from other Commonwealth jurisdictions which is relevant to the industry and which will be potentially persuasive in Australia.

Joanne Dunne, CTA, Minter Ellison

4.00pm–4.10pm Conference close

4.10pm–4.40pm Conference close drinks



PRESENTER PROFILES An overview of our experts

Sarah Bernhardt, CTA, has been a Partner in the Tax Group at Allens since 1998 and in that time has advised clients on a wide range of complex income tax issues. Sarah is both a lawyer and a chartered accountant with over 25 years of tax experience.

William Brown, CTA, is currently the Head of Tax in Westpac’s Enterprise Project Office and has broad experience in corporate income tax and GST matters. His experience includes tax advice focusing on financial services on capital management, treasury, securitisation, retail and business banking, employee matters and encompassing a number of tax areas including FBT, franking, thin capitalisation, transfer pricing, withholding taxes and GST. William is currently both a legal practitioner and Chartered Accountant with over 16 years tax experience.

Richard Buchanan, CTA, is a Director of Greenwoods & Freehills who specialises in the tax aspects of major transactions, particularly mergers and acquisitions and infrastructure and property projects. In these transactions, Richard regularly provides advice through the life cycle of the transaction, including funding, structuring, due diligence, documentation negotiation and post-acquisition integration. Richard’s role in infrastructure transactions can vary from advising the bidding consortium, representing lending syndicates, advising vendors and representing equity investors into a consortium.

James Campbell, is a Director in Public Groups and International, managing the ATO’s Banking and Finance Strategy. James joined the ATO in 2001 as a graduate. He has extensive experience working in compliance in the large market with a focus on the banking and finance industry. James has a BEcon (Hons) from Macquarie University and MTax from the University of NSW.

Peter Collins, FTI, is a specialist in international tax, assisting foreign investors structuring their Australian investments and Australian corporates expanding offshore. He works within PwC’s global tax network team to develop solutions for clients and is the leader of the Australian firm’s International Tax Services group. Peter is a member of Australian Treasury’s BEPS Tax Advisory Group and participated in the G20 BEPS Tax Symposium and the BCA BEPS workshop in 2014.

Rob Colquhoun, ATI, is a Director of Policy at the Australian Financial Markets Association (AFMA). He has primary carriage of AFMA’s taxation and AML/CTF issues. Rob joined AFMA in December 2012 with more than 11 years experience in corporate taxation. He also served as the Chief Executive Officer of the NSW Trainers Association. Rob holds honours degrees in both Law and Commerce from the Australian National University.

Warren Dunn, is a Partner in EY’s Fraud Investigations and Dispute Services division and leads the firm’s Forensic Technology and Discovery Services (FTDS) practice across Australia and New Zealand. Warren has over 15 years experience providing comprehensive IT forensic, electronic discovery (eDiscovery) and forensic data analytic consulting services with particular expertise in managing complex, highly sensitive and very public multi-jurisdictional litigations and investigations.

Joanne Dunne, CTA, is a Tax Partner in the Melbourne office of Minter Ellison. She advises clients in the management of tax audits, disputes, objections, dispute resolution and tax litigation at a state

and federal level. Joanne has over 20 years experience in tax law in both Australia and New Zealand.

Teresa Dyson, CTA, is a Tax Partner at Deloitte and is recognised as a leading individual in tax in Chambers Global 2014, Best Lawyers 2014 and International Who’s Who of Corporate Tax Lawyers 2014. Teresa is Chair of the Board of Taxation. She provides income tax advice on financing, and corporate and structuring issues to domestic and international entities.

Greg Fitzgerald, CTA, leads Macquarie Group’s Tax Accounting and Tax Decision Support functions as part of Macquarie’s Financial Management Group. The Decision Support function has responsibility for tax management reporting, forecasting and tax analytics. Greg’s prior experience includes five years in Macquarie Capital, providing transaction structuring advice for M&A transactions, and five years in EY’s international tax team.

Ian Fullerton, CTA, is a Consultant in the Tax group of Ashurst in Sydney. He joined the firm in 2012 after 14 years in group tax and institutional banking roles at two major Australian banks. At Ashurst, Ian advises on the tax aspects of a range of banking and corporate activities and has been involved with industry submissions on various cross-border tax issues, including the operation of the new transfer pricing rules. He is an author of the Thomson Reuters Australian Tax Handbook with responsibility for chapters on debt and equity, financial transactions, asset financing, trusts and tax planning and he is the author of the Tax chapter in Ford & Lee: The Law of Trusts.

Robert Gallo, ATI, is a Director in PwC’s Tax Reporting & Strategy practice. He has over 15 years experience in advising clients on optimising their tax reporting and compliance processes as well as transforming their tax functions to best balance their use of strategy, people, processes and technology. Robert’s experience expands across tax functions in various geographies and industries including banking and finance, retail, manufacturing, energy and mining. This experience includes tax function design and assessment, application of tax corporate governance and risk management frameworks, process improvement, and tax software implementation combined with project assurance.

Patrick Grob, CTA, is Head of Tax at Suncorp and has 20 years of financial services tax and finance experience, both in Australia and the UK. He is responsible for Suncorp’s overall tax advisory and compliance function across Australia and New Zealand. Patrick has also been providing tax advice and support to Suncorp’s Life, Superannuation and Investment business for over 10 years. He is a member of Suncorp’s Finance and Advice Shared Service executive management team. Patrick is also a member of the FSC Tax Experts Group and the FSC Life Insurance Technical Tax Working Group.

Debbie Hastings, leads the ATO’s approach to dispute management and dispute resolution (including ADR) as well as litigation services and legal risk for the ATO. She is also responsible for independent review of large business audits, as well as managing large market objections. Debbie is a graduate of the University of Sydney with a Bachelor of Economics and Bachelor of Laws. She has led strategic litigation matters in the AAT, Federal Court and High Court and has also been a member of the General Anti-Avoidance Panel and Public Rulings Panel.


Dr John Hewson, AM, is an economic and financial expert with experience in academia, business, government, media and the financial system. He has worked as an economist for the Australian Treasury, the Reserve Bank, the IMF and as an adviser to two successive federal Treasurers and the Prime Minister. Since leaving politics in early 1995, Dr Hewson has run his own private investment banking business, including as director/advisor of a wide range of companies and was, until December 2004, a Member of the Advisory Council of ABN AMRO, having previously been Chairman of the bank. Dr Hewson has recently served as Special Advisor to the Secretary-General of the UN Economic and Social Commission for Asia and the Pacific, and he is a member of the Trilateral Commission.

Jeremy Hirschhorn, is the Chief Tax Counsel at the ATO. As Chief Tax Counsel he is one of the highest legal authorities within the ATO and is responsible for oversight of the Tax Counsel Network which has carriage for the most significant and high-risk matters. Prior to joining the ATO, Jeremy had been with KPMG for 20 years and was a senior partner in KPMG’s Tax Practice with a focus on the financial services industry.

Michael Jenkins, CTA, has worked in the area of transfer pricing and international tax for around 15 years, both in the ATO and in a professional services environment. Michael is an Assistant Commissioner in the Public Groups & Internationals business line of the ATO. He is involved in a number of the ATO’s major transfer pricing cases, and leads a team involved in the development of the ATO’s guidance products related to the transfer pricing provisions enacted in 2013. Michael is currently the Australian delegate to the OECD’s Working Party No. 6 on transfer pricing matters, and was the Australian competent authority for transfer pricing matters from 2010 to 2012.

Robert Jeremenko, CTA, is Senior Tax Counsel at The Tax Institute and heads the Tax Policy and Advocacy team, leading the Institute’s advocacy activities. Robert joined The Tax Institute after five years at one of Australia’s largest banks, where he held roles including Head of International Government Affairs. Prior to this, Robert was taxation adviser on the personal staff of the Australian Federal Treasurer, where he worked on the implementation of a broad range of taxation policy over a four-year period. Robert holds degrees in Law and Science from the Australian National University and is admitted as a Barrister and Solicitor of the High Court of Australia.

Zaf Kardaras, joined Northern Trust in May 2012. Prior to joining Northern Trust, he was a Tax Director at PwC specialising in the taxation of superannuation funds and the managed funds industry. Previous roles have included Head of Taxation at IOOF Holdings Limited. Zaf has over 19 years of experience as an Australian taxation adviser in the financial services industry.

Dr Stephen Kirchner, joined Australian Financial Markets Association (AFMA) in September 2014 and provides economic research and analysis on issues affecting financial markets for incorporation into AFMA’s policy and advocacy work, including regulation, competition and taxation policy. Previously, Stephen has worked in think-tanks, academia, federal politics and financial markets. He was Director of economic research with Standard & Poor’s Institutional Market Services based in Sydney and Singapore.

Stephen has published in leading academic journals, including Public Choice and the Australian Economic Review. He has a PhD in economics from the University of New South Wales.

John Kirkness, is the Head of Tax for AMP Financial Services and has over 25 years experience in the taxation of financial services entities. John is responsible for the life insurance, superannuation, advisory and distribution areas of AMP’s business, including tax compliance, mergers and acquisitions, investment, transfer pricing, product development and unit pricing. John is a member of the Tax Experts Group of the Financial Services Council (FSC) and the Life Insurance Tax Working Group of the FSC, and is active in lobbying government and federal Treasury in relation to income tax developments and policy.

Tim Kyle, CTA, is a Director of Greenwoods & Freehills, based in the Sydney office. He has a focus on the financial services and resources industries, advising clients on a wide range of income tax matters, including mergers and acquisitions, capital raisings, innovative financial products, cross-border dealings, audits and tax litigation. Tim has worked on a range of matters involving Part IVA advice, rulings and disputes.

Rob McLeod, is the Chief Executive Officer and Managing Partner for EY’s Oceania region with responsibility for the firms in Australia, New Zealand, Fiji and Papua New Guinea. He was appointed to this role in July 2010. He was previously Managing Partner of EY New Zealand. Rob has been a tax specialist for over 30 years with experience in all facets of taxation. Rob previously chaired the New Zealand Business Roundtable for eight years. He also chaired the NZ Institute of Chartered Accountants Tax Committee and was Chairman of the New Zealand Government’s Tax Review in 2001.

Judy Morris, CTA, is an Assistant Commissioner in Public Groups and International and leads the Sydney Operations group and the Banking & Finance strategy. Judy joined the ATO in 2009. Prior to joining the ATO, Judy was a Corporate Tax Partner with a large advisory firm. Judy also has experience as Head of Tax for a large Australian listed group.

Brendan O’Brien, CTA, is the Head of Tax for AMP Capital, covering business and global fund structures. He is responsible for fund structures ’ housing assets in excess of $140 billion, including real estate, infrastructure, fixed income and equities asset classes. Brendan has more than 15 years tax experience, focusing on financial services and international tax. Brendan is an active member of the Financial Services Council Tax Expert Group.

Peter Oliver, CTA, is a Partner in the Financial Services Group at KPMG. Peter advises clients on corporate matters, mergers and acquisitions and cross-border transactions within the financial services sector, particularly insurance, life insurance and funds management. Peter has extensive experience advising on structuring international and domestic funds and advising both fund managers and institutional investors. Peter is also heavily involved in industry consultation with Treasury and the ATO on life insurance and wealth management tax issues, both through his membership of the Financial Services Council’s Life Insurance Tax Working Group and on behalf of clients.




Michael O’Neill, is a leader in the ATO’s Public Groups & International business line focusing on the International branch. International tax issues align with the G20/OECD agenda including addressing base erosion and profit shifting (BEPS), improving international transparency, and building capability and collaboration across tax agencies. The ATO’s focus is driving international approaches so that jurisdictions get their fair share of taxation. Michael is a lawyer who has worked in professional firms and other government agencies.

James Pettigrew, ATI, is a Partner in the Sydney office of Deloitte. He advises on a wide range of corporate tax matters for clients primarily in the finance, infrastructure, property and funds management sectors. James has presented for the Tax Institute and the Institute of Chartered Accountants in Australia, and he has lectured in the University of Sydney Master’s degree program in taxation.

Sue Williamson, CTA (Life), is a former President of The Tax Institute. She is the head of EY’s Melbourne tax controversy practice in Melbourne. Her focus is on the management of potentially complex and controversial issues to avoid disputes and, in relation to those that are in dispute, on the successful resolution of the disputes. In this capacity Sue has experience in the independent review, objection, ADR and litigation processes. Sue recently became accredited as a mediator to ensure a thorough understanding of the ADR processes.

Addison Younan, CTA, is the Head of Tax for NAB’s business advisory division and has over 10 years of corporate tax experience working in both a leading tax advisory firm and as an in-house tax adviser. He has recently returned from Hong Kong, where he managed the tax function of NAB Asia which operates in five jurisdictions. Addison has advised on numerous banking and wealth management transactions, including matters relating to superannuation, managed funds, life insurance, capital management, securitisation, debt syndication and infrastructure projects. He has advised extensively on a range of infrastructure projects for the NAB Group, especially around the tax issues arising for debt investors. Addison holds a Master of Laws from the University of Sydney. He is an Associate of the Institute of Chartered Accountants in Australia and a Chartered Tax Adviser with the Tax Institute.


FURTHER INFORMATION What, when and how to

Online registrationDelegates are encouraged to register online at taxinstitute.com.au/2015financialservices.

Registration inclusionsFull conference + WednesdayIncludes participation in the full technical program on Wednesday, Thursday and Friday, a folder containing all available conference materials, electronic access to all technical papers, attendance at the welcome drinks on Wednesday 18 February, attendance at the conference dinner on Thursday 19 February and all lunches and refreshments during conference hours. Registration fees do not include travel, accommodation, transfers, hotel breakfasts or hotel incidentals.

Full conferenceIncludes participation in the full technical program on Thursday and Friday, a folder containing all available conference materials, electronic access to all technical papers, attendance at the welcome drinks on Wednesday 18 February, attendance at the conference dinner on Thursday 19 February and all lunches and refreshments during conference hours. Registration fees do not include travel, accommodation, transfers, hotel breakfasts or hotel incidentals.

DiscountsEarly bird registrationAll full conference registrations received and paid on or before Friday 12 December 2014 will be entitled to an early bird discount.

Group discountsPurchase four full conference registrations and receive the fifth free. All attendees must be from the same firm and all must register at the same time. This offer cannot be redeemed in conjunction with any other offer, promotional code or discount.

Mates rateIntroduce and register a colleague who has not previously attended the Financial Services Taxation Conference and we will extend to you a special discount of $250 off the standard registration fee. This offer cannot be redeemed in conjunction with any other offer, promotional code or discount and both registrations must be received together.

Paperless optionTo assist in lowering your ecological footprint at this conference, you may elect to forgo the conference folder. This option is suitable for delegates wishing to use a laptop or tablet in session and not only saves on paper usage, but also reduces the registration price by $70. Technical papers and PowerPoint presentations will be available for participating delegates to download. An email informing delegates how to access these materials will be sent one week prior to the conference.

Delegate listA delegate list will be included in the conference folder to assist with networking. Please indicate on the registration form if you do not want your name included on the list.

Confirmation of registrationA confirmation letter and tax invoice will be sent via email.

CPD accreditationAttendance at the sessions on Wednesday afternoon counts for 4 hours, on Thursday counts for 6.5 hours and on Friday counts for 6.25 hours of Continuing Professional Development Accreditation with The Tax Institute. Therefore, attendance on Wednesday, Thursday and Friday combined counts for 16.75 hours.

Venue and accommodationSurfers Paradise Marriott Resort & Spa Reconnect with nature at the Marriott where verdant tropical gardens, a stunning waterfall and the area’s only private saltwater lagoon await.

Accommodation has been reserved for delegates at the Marriott. Favourable room rates have been negotiated and secured. All accommodation bookings can be made through the Ozaccom website: conferences.ozaccom.com.au/2015/fin15/index.html or by following the link on the Financial Services website: taxinstitute.com.au/2015financialservices.

Please note that as per venue booking conditions, all accommodation booked is non-refundable. All additional hotel incidentals, including breakfast, remain the responsibility of delegates, and individuals will be responsible for payment of the balance of their account when checking out of the hotel. Please note that extra charges may be incurred for additional guests, and will be charged to individual room accounts to be settled on check-out.

Welcome drinks – WednesdayFor delegates arriving on Wednesday, a welcome drinks reception will be held from 6.30pm at the Poolside. The welcome drinks reception is included in the conference registration fee for full conference delegates, and additional tickets are available to purchase for accompanying persons at a cost of $55. Please indicate your requirements, including dietary requirements, on the registration form.

Conference dinner – Thursday The conference dinner will be held in the Waianbah Room on Thursday evening from 7pm. Additional conference dinner tickets are available to purchase for accompanying persons at a cost of $160. Please indicate your requirements, including any dietary requirements, on the registration form.


FURTHER INFORMATION What, when and how to

Dress codeSmart casual attire is suitable for the duration of the conference program, including the conference dinner.

Getting thereSurfers Paradise Marriott Resort & Spa is situated approximately 30 minutes drive north of Gold Coast Airport and approximately a one-hour drive from Brisbane’s domestic airport.

ParkingSurfers Paradise Marriott Resort & Spa offers guest parking for $10 per day or a professional valet parking service is available for $20 per day.

Transfers from Gold Coast and Brisbane airportsFor delegates wishing to fly into Gold Coast or Brisbane airports, The Tax Institute has negotiated a favourable rate with transport provider Con-x-ion. A 20% discount will be offered to conference delegates for transfers between the airports and the resort. Should your flight be delayed, you will be placed on the next available shuttle service. Simply go to www.con-x-ion.com/Bookings/Airport-Transfers and enter the conference code FSTC2015. The discount is applied once your service has been selected.

Alteration and cancellation policy The Tax Institute reserves the right to alter, amend or cancel all or any of the arrangements contained in the program. It is a condition of acceptance of registration that an administration fee of 20% of the registration fee will be charged for cancellation. No refund will be given for cancellations received within five working days of the event. A replacement may be nominated; however, the replacement is only valid for the 2015 Financial Services Taxation Conference. If the replacement is not a member, the non-member registration fee will apply. CPD hours will be allocated to the designated attendee. The Tax Institute cannot accept responsibility for delegates’ late transport arrivals or non-arrivals due to delays.

Become a memberThere is no time like the present to join Australia’s leading educator and professional association in tax and take advantage of the special new member introductory offer. For an additional $100 on the member registration fee you can become a member and gain access to “the mark of expertise” (membership is extended until 30 June 2015) and a two-week trial to the Tax Knowledge eXchange.

Member benefits include: � Taxation in Australia journal � TaxVine e-newsletter � TaxLine research service – free to members � CPD event discounts � Publications and tax product discounts � Business Alliance Partner discounts.

The Chartered Tax Adviser ProgramDeveloped to enhance the performance of all tax professionals, the Chartered Tax Adviser Program is the industry’s choice for innovative tax education and training. The Institute offers three formal education courses to support tax professionals throughout their career – CTA1 Foundations, CTA2 Advanced and CTA3 Advisory. Visit taxinstitute.com.au/education for more information or call us to discuss your firm’s training needs on 02 8223 0032.

EnquiriesFor further information regarding this event, please contact the National Events Team on 1300 733 842 or [email protected].

For registration enquiries, please contact [email protected].

mailto:[email protected]

mailto:[email protected]

Full conference + Wednesday Please register me for the full conference including the Wednesday sessions. The registration fee includes catering, conference dinner and materials.

Early bird registration price (register on or before 12 December 2014)

The Tax Institute member $2,095 New member* $2,195 Non-member $2,395

Standard registration price (register after 12 December 2014)


Registration

Delegate contact details

Title: (Dr/Mr/Miss/Ms/Mrs/Other)

First name:

Last name:

Member no.:

Postal address:

Suburb:

State: Postcode:

Company:

Position:

Tel:

Mobile:

Email:

Fax:

Please tick this box if you do not wish your name to be included on the delegate list provided to all attendees for networking purposes.

2015 Financial Services Taxation Conference 1150202M1/HTML

REGISTRATION FORMPlease retain the original copy for your records and photocopy for additional delegates. All prices quoted include GST. ABN 45 008 392 372

PLEASE PRINT IN BLOCK LETTERS.

Register

OnlineSave time, register online at taxinstitute.com.au

[email protected]

MailGPO Box 1694 Sydney, NSW 2001

Fax02 8223 0077

Paperless option – deduct $70 from registration fee (see page 11 for further information)

Mates rates – I am bringing a new attendee – deduct $250 from registration fee (see page 11 for further information)

Name of new attendee:

Dietary requirements: Promotional code: Date of issue: 15 October 2014

Full conferencePlease register me for the full conference. The registration fee includes catering, conference dinner and materials.

Early bird registration price (register on or before 12 December 2014)


Standard registration price (register after 12 December 2014)


Please see page 11 for registration inclusions.

*SPECIAL NEW MEMBER OFFERThe new member registration fee includes fees for Affiliate level membership of The Tax Institute so that you can take advantage of the many benefits membership affords. Membership is extended until 30 June 2015. Please read and sign below to take up membership.

DeclarationI hereby apply for membership of The Tax Institute. I declare I am a person of good fame, integrity and character and agree to be bound by the Constitution of the Tax Institute. For more information on membership visit taxinstitute.com.au.

*Signature: Date:

Payment details summary

Registration fee $

Paperless option (deduct $70 – see page 11 for details) $

Mates rates (deduct $250 – see page 11 for details) $

Additional conference welcome drinks tickets ($55) $

Additional conference dinner tickets ($160) $

Total payable $

Payment method

Note: All registration payments must be made prior to the event, unless other arrangements have been made with The Tax Institute.

Membership and education program promotion I am interested in becoming a member of The Tax Institute. Please send me further details. I am interested in learning more about The Tax Institute’s education program. Please contact me.

Marketing and business alliance partner exclusions I no longer wish to provide my contact details to The Tax Institute’s contracted business partners. I no longer wish to receive marketing correspondence from The Tax Institute.

We take your privacy seriously. Our policy can be viewed at taxinstitute.com.au/go/footer/privacy.

ReplacementsPlease note: Registrations for the event are not interchangeable but replacements are acceptable. Please notify us at least two days prior if you intend on sending a replacement. CPD hours will be allocated to the designated attendee. If the replacement is not a member, the non-member registration fee will apply.

CancellationsThe Tax Institute must receive cancellations in writing five working days prior to the conference. It is a condition of acceptance of registration that an administration fee of 20% will be charged for cancellation. No refund will be given for cancellations received within five working days of the event. A replacement may be nominated. Further details on The Tax Institute’s cancellation policy can be found at taxinstitute.com.au.

I enclose a cheque* for $ *Please make cheque payable to The Tax Institute.

Please charge my credit card $

Card type:

AMEX Visa MasterCard Diners

Card no. / / /

Expiry date:

Cardholder’s signature:

Cardholder’s name:

For event enquiries, please contact the National Events Team on 1300 733 842 or [email protected]. For registration enquiries, please contact [email protected].

Conference dinner

The conference dinner is INCLUDED in the registration fee for delegates attending the full conference. Thursday 19 February: Waianbah Room

Yes, I WILL be attending the conference dinner OR No, I WILL NOT be attending the conference dinner Yes, I require additional tickets for the conference dinner at $160 per person

No. x tickets at $160 each: $ Name(s):

Dietary requirements:

Welcome drinks

The welcome drinks reception is INCLUDED in the registration fee for delegates attending the full conference.

Wednesday 18 February: Poolside

Yes, I WILL be attending the welcome drinks reception OR No, I WILL NOT be attending the welcome drinks reception Yes, I require additional tickets for the welcome drinks reception at $55 per person

No. x tickets at $55 each: $ Name(s):

Dietary requirements:

Breakout session selection

Please tick the breakout sessions you would like to attend during the conference:Thursday 19 February12.00pm–1.00pm Session 3A: Managed Investment Trusts: Where Are We Now? Session 3B: Update on Capital Management Issues

3.15pm–4.15pm Session 5A: BEPS Topics of Specific Interest to Financial Services Session 5B: FATCA, GATCA/CRS: What Will Be the Impact?

4.15pm–5.15pm Session 6A: Infrastructure Session 6B: Recent Developments in Thin Capitalisation

Friday 20 February9.45am-10.45am Session 8A: Thorny TOFA Issues Session 8B: Topical Custody Issues

EMBRACE YOUR DIGITAL TAX WORLD

Accessing the conference online

Join us on LinkedInJoin The Tax Institute group on LinkedIn to network and contribute to the group discussions and tax news.

Follow us on Twitter Follow us @TaxInstituteOz for daily tax news, updates and tweets. Use #nextgentax to share your posts about the convention.

FacebookLike us on Facebook for news, careers information and networking.

Register and purchase onlineSave time – register online for CPD or purchase dedicated publications, DVDs and more at taxinstitute.com.au.

Visit our blogGet the latest industry news from the team at The Tax Institute by visiting our blog at taxinstitute.blogspot.com.au.

Tax Knowledge eXchangeSubscribe and get access to Australia’s leading online database containing over 65,000 records including papers, presentations, podcasts and videos through the Tax Knowledge eXchange. Visit our website for details. Now includes up to 17 structured CPD hours.

iCPD – online and interactiveNo matter where you are in Australia or the world, you can access seminars by The Tax Institute. These online and interactive seminars come complete with presenter, chairperson and discussion forum. Visit taxinstitute.com.au/icpd to find out more.

Convention Mobile Web AppInstantly access conference details, scheduling, speaker biographies as well as available technical papers and presentations with the 2015 Financial Services Taxation Conference mobile web application, suitable for your web-enabled smartphone or device. Visit the website taxinstitute.com.au/2015financialservices for the download link. Available from February 2015.

TAX KNOWLEDGE EXCHANGENow includes up to 20 CPD hoursAustralia’s leading tax knowledge base continues to grow in 2014, now giving you up to 20 CPD hours and updated coverage of:

� BEPS � Finance & Investment � Litigation � Part IVA � Property � Succession planning and estates � Superannuation � Trusts, and much more.

FIND OUT MORE and take a trial at taxinstitute.com.au/tkeFIND OUT MORE and take a trial at taxinstitute.com.au/tke

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2015 FINANCIAL SERVICES TAXATION CONFERENCE · AMP Financial Services Session 3B: Update on Capital...

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