2021 Southeast Asia Financial Services Tax Conference

sg-tax-2021-sea-financial-services-tax-conference-12-october-2021Headline Verdana Bold 2021 Southeast Asia Financial Services Tax Conference Trusted. Transformational. Together 12 October 2021
2021 Southeast Asia Financial Services Tax Conference© 2021 Deloitte Southeast Asia Ltd. 2
1. Infrastructure and renewables investment in Southeast Asia 3
2. Wealth planning for Southeast Asian families 25
3. Structuring Southeast Asia focused funds 72
Contents
Infrastructure and renewables investment in Southeast Asia
Spotlight on Indonesia, Philippines, Thailand, and Vietnam
Moderator
Panellist
Speakers
An Vo Hiep Van Partner Deloitte Vietnam
Korneeka Koonachoak Partner Deloitte Thailand
Elaine De Guzman Partner Deloitte Philippines
Michael Velten Partner | Financial Services Tax Leader Investment Management and Real Estate Sector Leader Deloitte Southeast Asia
Erlangga Atmadja Director Deloitte Indonesia
Economic impacts on clean energy investments particularly on developing its infrastructure, helps drive green economic recovery from pandemic. • Demand-drivers: SEA electricity demand is one of the world’s fastest at
6% per year, but renewables constitute 15%. Aspirations to double this by 2025 (ASEAN Plan of Action for Energy Cooperation phase ii 2021-2025).
• More jobs created directly and indirectly—per US$1 million in spending, RE technologies create 7.49 jobs, compared to 2.65 jobs for fossil fuels.
• Strengthens Energy Security by reducing fossil fuel imports (Philippines, Thailand, and Vietnam are top 15 importers of coal).
• Counters fossil-fuel shortages: renewables coupled with battery storage technology can buffer volatility in fossil fuel supply.
• Avoids future public health crises. Without investments in clean energy, continued growth in electricity demand will increase carbon emissions and air pollution with detrimental effects on public health, estimated 650,000 premature deaths by 2040.
• Averting global climate change induced crises in the future by helping global efforts in achieving Paris Agreement goals via achievements of NDCs.
• Large scale RE projects developed needed to meet demand and to ensure economies of scale.
• Private sector development by incentivizing IPP and FDI.
A green recovery from the pandemic is crucial—especially in Southeast Asia (SEA)—to ensure an economically and environmentally resilient future
Macro view
Source: ADB, 2021; ACE, 2020; IEA, 2019; IEA, 2021; CNBC, 2021
• Quick-win from hydropower, based on continued historical trends, project pipeline availability, and natural endowment. • Waste-to-energy (including biomass), especially when large cities are supported by smart grid and current waste management infrastructure is overcapacity. • Solar energy (Photovoltaics) and wind, especially if government policies create favourable market conditions. Shorter construction time. Wind power potentials may be developed in the longer-run but are area
specific. • Levelling the playing field reduced fossil fuel subsidies and improved RE incentives (particularly to attract FDI); supplementary infrastructure such as smart grids and battery-enabled tech needs to also be in place. • Mechanisms in place to de-risk RE investments and improve access to infrastructure finance a good track record in government support through PPP, Feed-in-Tariffs, and supportive investment climate.
Where and what to look for
Sector view
Country Commitments for growth (revised plans to 2030 issued during pandemic)
Flagship projects to 2025 Constraints identified and measures taken
Indonesia The Energy Supply Business Plan (RUPTL) updated in 2021 for 2021-2030 is a game-changer as for the first-time renewables at 51.6% in the energy mix is expected to beat fossil fuels at 48%.
• Waste-to-energy projects in cities such as Jakarta, Tangerang, Bandung, Surakarta, Semarang, Surabaya, Makassar, and Denpasar, as priority projects to be developed in the PPP mode and though state-owned enterprises (SOEs). The estimated project cost is Rp19.74 trillion (approximately US$1.4 billion).
• Off-grid mini and micro-hydro power plants to be offered via PPP mode. • Rooftop Solar PV mainstreaming mandated to state electric company (PLN) in
RUPTL 2021-20230. Flagship solar pv project: Floating solar energy plant in Cirata Dam with UAE investment.
• Doubling Geothermal energy generation capacity from 1.2 GW to 2.4GW by 2026 by creating a holding company to coordinate geo-thermal investments.
Reducing reliance on coal and general decarbonization of the economy • A ban on new coal-fired power projects from 2023,
along with plans to retire ageing coal-fired plants. New tax legislation with a provision for carbon taxation helps level playing field.
Philippines RE targets to be achieved through Philippine Energy Plan 2021-2030, currently being drafted. RE generation target proposed at 35%; previous target at 10%. Plan focuses on hydropower, solar, and geothermal.
405 pipeline commercial projects identified for hydropower and 273 solar pv power under RE Act of 2008, as of June 2021; These constitutes more than 75 % of RE capacity in the RE pipeline. Geothermal potentials are also being expanded.
Direct access to capital and broaden base for RE investments • Green Energy Option Program, lists the renewable
energy suppliers accredited to sell RE energy directly to customers.
Where and what to look for (cont.)
Sector view
Country Commitments for growth (revised plans to 2030 issued during pandemic)
Flagship projects to 2025 Constraints identified and measures taken
Thailand Energy Efficiency Plan 2015–2036; to be updated by the new integrated National Energy Plan (NEP) scheduled for 2022, with focus on going green with a US$4.2 billion investment. NEP syncs 5 action plans with target of 35% of installed capacity by 2037.
• Thailand is creating the largest floating hydro-solar power plants at Ubon Ratchatani province covering 121 Ha and would be replicated in 8 other reservoirs nationwide.
• "Energy For All" programme to focus biomass and waste—Thailand has developed waste-to-energy technology that can use agricultural waste as biomass feedstock, and this will support.
• develop community-owned power generation projects using waste-to-energy resources in more remote areas. It will encourage local communities to sell crop waste to be used for biomass and biogas generation in order to earn additional income.
• Hydropower is historically the strongest contributor in RE energy mix.
Reducing reliance on LNG • 60% of electric power in Thailand currently
generated from local natural gas, diversification of the energy supply is seen as a necessary step towards enhanced national energy security. Advanced Grid being developed to integrate RE to help reduce dependence on LNG in the long-run.
Vietnam National Energy Efficiency Programme (VNEEP) for the period of 2019-2030 (Decision280/QD). Updated by Power Development Plan (PDP 8) for 2021-2030. The draft PDP 8 expands wind and solar capacity and increases their shares of the country’s generation mix. The draft PDP 8 also prioritizes enhancing grid infrastructure to ensure stable operation with a higher share of renewables.
• Rooftop solar energy champion in the region. In 2020, successfully created an 8-fold increase in rooftop solar installation. Now is the highest installed solar energy capacity in ASEAN and is a world top 10.
• Vietnam also has strong potential in wind energy generation. There are over 17 wind farm projects being developed as of 2017 in 8 provinces.
• Hydropower, however, is historically the strongest contributor in RE energy mix. Mini- Hydro projects developed in more remote areas can help reduce local reliance on coal-fired energy.
Successful RE Policies need to be bolstered by smart grid—eight-fold increase of rooftop solar in 2020 compared to the previous year, driven by the attractive policies. Market rush needs to be supported by smart grid. supplementary infrastructure, such as storage and ample grid, should be planned and developed along with the deployment. This is acknowledged by PDP 8.
© 2021 Deloitte Southeast Asia Ltd. 82021 Southeast Asia Financial Services Tax Conference
Indonesia
Tax features and facilities
Key tax aspect Features
Income Tax (IT) 22% Financial Year (FY) 2021 or 20% from FY2022 (now proposed to 22% from FY2022).
Value Added Tax (VAT) 10%, or exempt for certain products or services (electricity, water, toll road fare). Now proposed to increase to 11% from 1 April 2022 and 12% from 1 January 2025 at the latest.
Withholding Tax (WHT) dividend and interest
20%, or between 5% to 15% under a Tax Treaty (generally 10%).
Investment exit 5% final tax on sale of shares by non-residents, or 0.5% founder tax and 0.1% transaction tax if exit through the Indonesia Stock Exchange/IDX. A tax treaty may provide exemption.
Tax facilities Features
Tax holiday Provides 50% or 100% reduction of CIT payable, for 5 to 20 years.
Tax allowance Provides additional (hypothetical) depreciation 30% of capex, accelerated depreciation, 10% WHT on dividend to non-resident shareholder, and extended tax loss carry forward period.
Import facilities • Masterlist facility: exemption from import duty. • Import taxes (VAT and IT) exemption facility.
Selected key tax considerations/issues • Thin capitalisation rule (DER) 4:1. Sponsor
loans vs third party financing. • Fiscal depreciation/amortisation may not
necessarily match the actual project life. • Tax facilities: devils is in the details:
timeline, document submission, limitation of facility.
• VAT may represent additional investment cost: if product is VAT-exempt (e.g., Independent Power Producer/IPP project) or if pre-production period extend to certain pre-determined period.
• VAT refund process and timeline: cash flow issue.
• Accounting versus tax treatment (e.g., lease accounting vs fixed assets accounting).
• New draft tax bill (e.g., Carbon Tax).
Tax considerations and issues in infrastructure and renewable Investments
Indonesia
Indonesia
PT Project 1
PT Project 2
PT Project 3
Dividend (IT exempt)
Dividend Lenders
Exit (22%/20% tax on gain)
Exit (5%/0.1% final tax/exempt
Exit (long-arm rule)
EPC contract
Philippines
Macroeconomic outlook
Philippines
48%
22%
24%
6%
Infrastructure investment forecast 2016-2040, sector breakdown in terms of Gross Domestic Product (GDP)
Philippine energy mix (2020)
Philippine taxation—At a glance
Infrastructure and renewables investment in the Philippines
Philippines
Tax type Tax rate
IT In general, effective 1 July 2020, domestic corporations with total assets of PHP100 million below and net taxable income of P5 million and below will be subject to 20% tax, and 25% tax for other domestic corporations. Lower tax rates may apply under special laws.
VAT
• Levied on the supply of goods and the provision of services, and on importation. • VAT rate is 12% while a number of transactions are exempt. A 0% VAT rate applies to qualified export sales
transactions and activities covered by special laws. • VAT registration is mandatory for all taxpayers whose taxable transactions in the Philippines exceed
PHP3,000,000 gross sales/receipts.
Creditable WHT • Imposed on local income payments and creditable against the income tax due of the payee ranging from 1% to
15%.
Philippine taxation—At a glance
Infrastructure and renewables investment in the Philippines
Philippines
Tax type Tax rate
Final WHT on dividends
Dividends paid by a domestic corporation to its foreign parent are generally taxed at 25%. However, if the home country of the recipient allows an additional credit of 10% as tax deemed paid in the Philippines, the tax is reduced to 15%. The rate may be reduced under a tax treaty subject to conditions under Double Taxation Agreement (DTA) and tax treaty relief application with the Philippine tax office.
Final WHT on interest Interest paid to non-resident corporations is subject to a WHT of 20% on interest for foreign loans unless the rate is reduced under a tax treaty subject to conditions under DTA and tax treaty relief application with the Philippine tax office.
Capital gains tax
A final tax of 15% shall be imposed upon the net capital gains realised during the taxable year from the sale, barter, exchange, or other disposition of shares of stock in a domestic corporation not sold through a local stock exchange. Tax relief under the treaty is available subject to conditions under DTA and tax treaty relief application with the Philippine tax office.
Documentary stamp tax Transfer of shares of stocks are subject on the rate of PHP1.50 for each 200 pesos of the par value of the shares of stocks issued. In the case of stocks without par value, a DST at the rate equivalent to 50% of the DST paid on the original issuance of the said stocks shall be paid.
Tax incentives
Fiscal incentives available for renewable energy developers Rule 5 Section 13, Renewable Energy Act • Income tax holiday for the first seven years of
commercial operation. • Reduced corporate tax rate (10% after income
tax holiday). • 0% VAT rate. • Duty-free importation of renewable energy
machinery, equipment and materials. • Special realty tax rates on equipment and
machinery. • Net operating loss carry-over. • Accelerated depreciation. • Cash incentive for renewable energy developers
for missionary electrification. • Tax exemption of carbon credits. • Tax credit on domestic capital equipment and
services.
Philippines
Thailand
Strategic energy plan 1. Reduce carbon emission. 2. Renewable energy. 3. Disruptive technologies.
Infrastructure and energy industry
Thailand
The consumption of renewable energy in Q1 2021 • 2021 is targeted to be at 17.34%, whereas 2037 is expected to reach 30%.
25
Solar Energy Biomass Biogas (Wastewater/Waste) Wind Energy Municipal Solid Waste Hydro Power
65.5%
92
20.5%
44
56
Board of Investment (BOI) incentives • BOI is a governmental agency under the direct administration of the Prime Minister’s office to promote investment in Thailand offering activity-based
incentives and merit-based incentives. • In 2021, Energy, Utilities & Environmental Industry are eligible to tax incentives under section 7.1.1 “Production of electricity or electricity and steam” in
BOI schedule.
Eastern Economic Corridor (EEC) • Chachoengsao, Chonburi and Rayong Provinces have been designated for the development (EEC areas). • The government has identified four “core areas” essential in making the EEC a renowned economic zone
Increased and improved infrastructure; Business, industrial clusters, and innovation hubs; Tourism; and The creation of new cities through smart urban planning.
.
Thailand
BOI incentives
Eastern Economic Corridor (EEC) incentives
Common issues • The debate on VAT point for sale of electricity and water supply since it is intangible goods and could not clearly determine the timing of ownership
transferred. • The debate on Build Transfer Operate (BTO) on whether it should be considered as a sale of good or provision of service. • The debate on Permanent Establishment (PE) issue when hiring a foreign advisor to oversee a project in Thailand.
Tax incentives and common issues
Thailand
EEC package Incentives
Standard tax package for the infrastructure using advance technology to create value added
Tax holiday for 8 years would be granted.
• Investment projects which are engaged in human resource development programs.
• Additional tax holidays for 2 years; or • 50% reduction of CIT for 3 years depends on targeted activities.
• Investments located in EECi, EECd, EECa and EECmd. • Additional tax holidays for 1 year; or • 50% reduction of CIT for 2 Years depends on targeted activities.
• Investments located in industrial estates and promoted industrial parks. Additional tax holidays for 1 year depends on targeted activities.
BOI activities Incentives1
7.1.1.1 Production of electricity or electricity and steam from garbage or refuse derived fuel. 8 years CIT exemption (No Cap).
7.1.1.2 Production of electricity or electricity and steam from renewable energy (e.g., solar, wind, biomass or biogas).
8 years CIT exemption.
7.1.1.3 Production of electricity or electricity and steam from other energy sources. 3 years CIT exemption.
1Being subject to an approval by relevant government agencies and certain conditions to be fulfilled.
Cash repatriation
DTA between Thailand and respective countries WHT Other taxes
Interest 15% SD: 0.05% on loan principal but capped at THB 10,000.
Generally, a tax relief would be available for financial institution and insurance company.
Dividend 10% N/A. No Tax relief available (but can be exempt if the income is qualified for BOI/EEC tax incentive).
Capital gain 15% SD : 0.1% on shares transfer consideration or paid-up capital whichever is higher.
A tax relief would be available subjecting to conditions under DTA with respective countries.
Vietnam
FDI by Sector as of August 2021
Vietnam
Industrial Power Real Estate Others
Renewable Energy Sector in Vietnam is one of the most vibrant in SEA
6.5%
Challenges • Weak grid capacity. • Low tariffs. • Unbankable PPA terms.
Tax incentives • Tax holiday (4 years tax exemption, 9 years 50% tax reduction and 15 years tax concessional rates). • Import tax exemption and free of land use fee*.
Development cost The importance of arranging sufficient supporting documents to enhance the deductibility of the development costs after the project comes into operation phase.
Interest deduction 30% EBITDA cap on interest deduction.
CGT and Tax Treaty • Indirect share transfer would be subject to Vietnam CGT. • Structure attached to land such as wind turbine, solar farm, LNG terminal could be considered as immovable assets affecting the ability to obtain tax
treaty benefits at investment exit.
* Conditional application
Wealth planning for Southeast Asian families
Issues and considerations
Moderator
Panellist
Speakers
Tristan Lopez Director Deloitte Philippines
Dionisius Damijanto Partner Deloitte Indonesia
Wealth management trends
Competitiveness ranking • Switzerland, Singapore and Hong Kong are leading in a tight race, as in 2018. But
the competitive landscape is shifting, with factors such as ESG investments and political stability becoming more important.
Asset size ranking • Switzerland remains the largest centre, followed by the UK and US.
COVID-19 has boosted the offshore market—on average the centres grew their IMV by 10.6% in 2020, significantly above the annual average of 4.8% for the previous four years.
IWMC overview • All centres have been affected by erosion of structural fees and margins as well
as increasing costs driven by stricter regulation. Increasing wealth in Asian emerging markets is leading to further development of local offshore hubs, and Singapore and Hong Kong are well-positioned as Asian international finance centres.
Strategic implications for offshore wealth managers • Digitally enabled interaction with clients, deeper integration with local partners
as well as enhancement of the product offering are emerging priorities.
Key findings of the International Wealth Management Ranking 2021 report
Tight race at the top—Switzerland leading before Singapore and Hong Kong • Overall competitiveness ranking
Competitiveness ranking results
Tight race at the top—Switzerland leading before Singapore and Hong Kong • Detailed competitiveness ranking
Switzerland is strong almost across the board, with particular strength in ‘stability’ (monetary, financial, political) but a slight weakness due to limited market size and the lower profitability of Swiss wealth management providers.
Singapore shows few weaknesses, mostly related to the domestic capital market and taxation.
Hong Kong also ranks well for competitiveness. A weak point is political stability (whereas monetary and financial stability remains unproblematic).
UK is hampered by Brexit, loosing in Provider capability (talent) and only not loosing in stability due to the weakness of others (esp. Bahrain).
Competitiveness ranking results (cont.)
Switzerland remains the largest centre, followed by the UK and the US—except for Luxembourg and Panama & the Caribbean, all centres kept the same relative positions as in our 2018 report.
International Market Volume of leading wealth management centres (in US$ billion)
Asset sizing—results
2020
2019
2018
2017
Indonesia
• Indonesia has Controlled Foreign Companies (CFC) rules which are intended to prevent Indonesian tax taxpayers from circumventing Indonesia’s worldwide tax regime by placing their assets in a foreign (non-Indonesian tax resident) company.
• Where a CFC derives profits but does not distribute such profits as dividends to the Indonesian taxpayer, 100% of the profits would be attributed to the Indonesian taxpayer as a deemed dividend and be taxed. PMK 107 issued on July 2017—CFC rules applied to both directly held CFC, and indirectly held CFCs. PMK 93 issued on June 2019: CFC attribution rules were to be applied only to “passive” income of the CFC,
and not active income. • CFC attribution rules are based on accounting profit. This means that both realised and unrealised gains may be
attributed. This may be contrasted to an Indonesian individual taxpayer deriving the income directly—in such a case, tax would generally only apply on realised gains.
• If the CFC rules apply and no dividends are declared or derived from the foreign entities, the deemed dividend must be calculated and reported in the annual corporate income tax return.
Omnibus Tax Law—impact on Indonesia’s Controlled Foreign Companies rules
Indonesia
Omnibus Tax Law—example
Current year: PAT $100: • Dividend: $50
$30 is reinvested in Indonesia in prescribed instruments. $20 is not reinvested in Indonesia. Retained earnings: $50.
Tax treatment under the Omnibus tax law: • Dividend: $50
Reinvested $30: not income tax object—i.e., exempt from tax. Not reinvested $20: not subject to income tax.
• CFC attribution: $0: not subject to income tax.
Where corporates receive dividends from local companies, the dividend income would be automatically exempt without the need to satisfy further conditions.
Omnibus Tax Law—New tax exemption on dividends re-invested into Indonesia
Indonesia
Individuals may now enjoy a tax exemption on dividend income, if the dividends are “re-invested” into Indonesia. This is applicable to both local and foreign dividends. In order to qualify for the exemption, the dividends must be invested in Indonesia into specified categories of investments (see table on right), and be subject to a 3 year lock up period.
Corporates may similarly enjoy a tax exemption on dividends received from a foreign company, subject to the same re-investment and lock-up conditions.
Notable categories of investments include “investment in new/old companies in Indonesia”. Query whether an Indonesian taxpayer can re-invest dividends into his own company, and subsequently repatriate cash from the company.
Omnibus Tax Law—New tax exemption on dividends re-invested into Indonesia
Indonesia
Financial investments Non-financial investments
1. Bonds and Sharia RI’s bonds; 2. Bonds/sukuk BUMN (OJK); 3. Bonds/sukuk Government owned financing institution (OJK); 4. Investment in perception bank (including Sharia); 5. Bonds/private sukuk (OJK).
1. Government infrastructure investment cooperation; 2. Government priority real sector investment; 3. Investment in new companies in Indonesia; 4. Investment in old companies in Indonesia; 5. Collaboration with investment management institutions; 6. Lending for micro businesses; 7. Other valid investment.
Investment form Investment form
1. Debt securities (including MTN); 2. Sukuk; 3. Shares; 4. Mutual fund unit; 5. EBA; 6. DIRE; 7. Deposit; 8. Saving; 9. Giro; 10.Futures; 11.Other instruments including investment insurance products, finance
companies, pension funds, venture capital (OJK).
1. Infrastructure investment through government cooperation 2. Government priority real sector investment; 3. Land and/or building property (non subsidy) ; 4. Direct investment to companies in Indonesia; 5. Precious metals, gold bullion or bullion (99.99%); 6. Collaboration with investment management institutions; 7. Lending for micro businesses; 8. Other investment besides financial market.
Tax residency New criteria and procedures have been introduced for an Indonesian citizen to qualify as a non-resident taxpayer. The changes introduce more procedures to achieving tax non- residency, but also greater certainty.
Omnibus Tax Law—other changes
Indonesia
Insurance products Indonesia’s tax exemption on payments from insurance companies now only applies if such insurance payments arose due to death, sickness or an accident. This means, if a policy holder partially or full surrenders its policy, the cash value less the premium paid, will be taxable in the hand of policy holder.
Trusts No changes were made to Indonesian tax treatment of trusts. Our understanding remains that the DGT will disregard a trust and generally impose tax on trust income on the settlor. Where a CFC is settled into a trust, the settlor will continue to be subject to CFC attribution rules vis-à-vis the CFC during his/her lifetime. In the event that the settlor is deceased, CFC attribution rules will apply to the beneficiaries instead.
Due date • 30 September 2022, for taxpayers who declare to transfer net assets into Indonesia territory; • 30 September 2023, for taxpayers who declare to invest net assets in natural resources or renewable energy business sector and/or SBN/Government
Bonds in Indonesia. The investment must be carried out at least 5 years since initially invested.
Tax compliance programme
Not Repatriated
2%, 3%, 5% 2%, 3%, 5% 4%, 6%, 10% 6% 8% 6% 8% 11% 12% 14% 12% 14% 18%
Penalty Increase 4%, 6%, 10%
- If not invested:
Assessment Letter);
- 5% (Voluntary)
Lock-up Period 3 years 3 years 3 years 5 years 5 years 5 years 5 years 5 years 5 years 5 years 5 years 5 years 5 years
Compliance Program 2
Onshore Asset Offshore Asset
Compliance Program 1
Offshore Asset
Financial & non-
financial to
Financial & non-
financial to
Financial & non-
Offshore Asset
Singapore
Observation • The Monetary Authority of Singapore (MAS) estimates that the number
of family offices in Singapore increased fourfold between 2015 and 2017, and fivefold between 2017 to 2019.
• On 5 October 2020, Senior Minister Tharman Shanmugaratnam (who serves as the Chairman of the MAS) estimated that there are currently about 200 family offices in Singapore managing around US$20 billion in assets.
• The growth of family offices in Singapore corresponds with the broader global trend that family office growth has accelerated rapidly since 2000—see infographic on the right.
• Pull factors include strong, predictable and clear regulatory framework (e.g., MAS adopts a light touch regulatory regime for Single Family Offices (SFO)), attractive work and living environment, access to strong talent pool and service providers.
• Push factors include high taxes in home jurisdiction, developments in North Asia, etc.
Singapore family office—rapid growth
Singapore
• Singapore’s 13R/13X/13CA fund incentives allow for fund vehicle to enjoy Singapore tax exemption on “Specified Income” from “Designated Investments”.
• Fund vehicle typically able to obtain Certificate of Residence for treaty access.
• Potential non-Singapore tax benefits as well, e.g., re Indonesian CFC rules.
• No Singapore withholding tax on fund vehicle outbound distributions of dividends or interest.
Singapore family office—tax
Portfolio
assets
Singapore tax exemption on fund’s income if within “Specified Income” from “Designated Investments.
Fund management fee is taxable in the hands of the Singapore fund manager. The prevailing corporate tax rate in Singapore is 17%.
Employment salary is tax deductible by family office, and taxable in Singapore in the hands of employee at up to 22%.
Employees
• Singapore Permanent Residency (PR) under the Global Investor Programme (GIP): Under the GIP Option C, an investor who
places at least S$2.5 million in a Singapore-based SFO with an Assets under Management (AUM) of at least S$200 million may be granted PR status for himself and his family (spouse, unmarried children below 21). This is subject to satisfaction of milestones (employee headcount, business spending) based on a business plan.
• Singapore Employment Pass (EP) under SFO sponsorship route: An SFO that applies for the 13R/13X fund
incentive can expect MAS support for EP applications.
• Dependent Pass (DP)/Long Term Visit Pass (LTVP) Suitable for spouse, unmarried children
below 21, and/or parents that are not directly covered under GIP/EP.
Singapore family office—immigration
• One common structure is the combination of a Singapore family office structure under a Singapore trust.
• This is primarily driven by non-tax reasons, e.g., estate planning.
• Potential to mitigate exposure to future wealth/inheritance tax?
Singapore family officeuse of trust
Singapore
100%
Trustee
Trust
BeneficiariesSettlor
100%
100%
Tax residency
Breaking the nexus
Tax residency
Jurisdiction Is it sufficient to spend 183 days a year in Singapore?
Indonesia Post-omnibus tax law, the following must be satisfied to sever tax residency in Indonesia • Reside outside of Indonesia for more than 183 days within 12 months period; • Satisfy one of the tie-breaker rules (being permanent home, main activities, or habitual abode); • Become a tax resident of another country; • Settle all outstanding taxes payable in Indonesia; and • Obtain approval from the Indonesian tax office.
Malaysia There are four conditions to meet in order for a Malaysian citizen to qualify as a tax resident of Malaysia. Generally, he/she would need at least 5 years to break the tax residency rule. In order to qualify as non-tax resident, the Malaysian citizen must not satisfy any of the following: • Physical presence in Malaysia for ≥182 days or more in a calendar year; • Physical presence in Malaysia for <182 days but is linked to/by a consecutive period of 182 days or more with temporary absence allowed; • Physical presence in Malaysia >90 days and 3 out of 4 immediate basis year, he was either resident or in Malaysia for > 90days; • No physical presence in Malaysia in the year concerned and was resident in 3 immediate preceding years and will be resident in immediate following year.
Philippines For a Philippine citizen to qualify as a non-resident citizen, he/she should establish to the satisfaction of the Commissioner of internal revenue either of the following: • He/she left the Philippines during the year for permanent migration or permanent employment abroad. • He/she left the Philippines, for a foreign country, for employment thereat and outside of the Philippines most of the time (at least 183 days) for employment thereat.
Thailand Tax residency purely based on 180 day rule (increased to 183 days under applicable treaty).
Vietnam For an individual to qualify as non-resident, he/she has to be present in Vietnam for less than 183 days in a tax assessment year, not maintain any “regular residence” in Vietnam, and prove the residence in another country (by obtaining Tax Residency Certificate of other country).
Use of Singapore family office by Southeast Asian families
• From a Singapore tax perspective, where the Fund has applied for and obtained the 13R/13X fund incentive, it will enjoy a Singapore tax exemption on “Specified Income” from “Designated Investment”. However, fund management fees derived by the Family Office would be subject to Singapore income tax at 17%.
• In considering the tax issues that arise for the SEA family under a Singapore Family Office structure, the threshold consideration is the tax residence of the family members that invest in the Singapore Fund. Put simply, are the family members tax resident in
Singapore or in another SEA jurisdiction or both (in the case of the latter, the “tie break” rule under tax treaties is relevant).
If the family members are: Tax resident in Singapore (and not tax resident in any
other jurisdiction): Distributions from the Singapore fund are tax exempt in Singapore.
Tax resident in another jurisdiction: We will need to consider domestic tax rules in such jurisdiction, e.g., CFC.
100%
• Tax treatment in Indonesia if family members are Indonesian tax resident: Indonesia will look through the trust for tax purposes, such
that the Singapore fund and family office would be treated as CFCs. Undistributed profits may be attributed back to the Indonesian Settlor as a deemed dividend based on Indonesia’s CFC rules, and consequently be subject to tax in Indonesia.
When dividend distributions are made, such dividend income would be taxable in the hands of the Indonesian taxpayer, subject to the dividend income qualifying for the tax exemption on the basis of being re-invested into Indonesia.
Where profits have already been taxed in Indonesia under CFC rules, and are subsequently distributed as dividends, Indonesian tax would not apply on dividend income, i.e., no double taxation.
Gains on disposal of assets into structure may trigger Indonesian tax.
• If family members are not Indonesian tax resident: No adverse Indonesian tax risks.
Indonesia
100%
• Tax treatment in Malaysia if family members are Malaysian tax resident: — No CFC rules in Malaysia. — Transfer of assets (except for Malaysian real estate or “RPC
shares”) into a Singapore Trust structure will not be subject to Malaysian income taxes as the gains are regarded as capital in nature.
— The transfer of stock, shares or marketable securities will be subject to stamp duty at 0.3% of the higher of transfer consideration or market value. Stamp duty remission in excess of RM200 is remitted for all instruments of contract notes relating to the sale of any shares, stock or marketable securities listed on a stock market of an approved stock exchange or in companies in Malaysia or elsewhere between a local broker and an authorised nominee on behalf of a foreign broker.
— Trust distributions to Malaysian beneficiaries not subject to tax in Malaysia if it is not sourced in Malaysia.
• If family members are not Malaysian tax resident: Same tax implications apply.
Malaysia
100%
• Tax treatment in the Philippines if family members are Philippines tax resident: No CFC rules in the Philippines. For a Philippine individual taxpayer, any investment income
whether it be directly or through a family office structure will be subject to Philippines income tax.
Gratuitous transfer of assets, whether during the lifetime or through inheritance, by a Philippine individual to any Singapore entity is subject to donor’s tax or estate tax, respectively, which is 6% of the fair market value of the property transferred.
Irrevocable transfer to a trust will likewise be subject to the taxes imposed on the immediately preceding paragraph; and income earned by the trust is subject to the same income tax rate imposed on the settlor.
• If family members are not Philippines tax resident: No adverse Philippines tax risks.
Philippines
100%
• Tax treatment in the Thailand if family members are Thailand tax resident: No CFC rules in Thailand. Disposal of assets (shares, cash, etc.) into structure may
trigger Thailand taxation. Different types of taxation and tax rates may apply depending on the type of asset, etc.
Thailand has inheritance and gift taxes—but the implications can be managed.
Where a Thailand family member receives profits from the trust, if the beneficiaries are individuals, he/she will only be subject to personal income tax at the progressive rate ranging from 0-35% under the Thai Revenue Code once all of below conditions are satisfied: (i) he/she is a Thai tax resident; and (ii) he/she brings the profits (foreign sourced income) into Thailand in the same calendar year that he derives such profits.
• If family members are not Thailand tax resident in the tax year: No adverse Thailand tax risks.
Thailand
100%
• Vietnam has strict rules relating to exchange controls and outbound investment.
• As such, based on experience, most wealthy Vietnam families focus on the domestic market. This may soon change due to potential upcoming relaxation in the relevant regulatory laws.
• Some common features of wealthy Vietnam families are: First capital earned in 1990s: either by doing
business abroad before returning to Vietnam for investment, or by starting small business in Vietnam from zero to hero.
Next generation are relatively young. Succession planning will be an urgent need
In the next 5 years, there will be a sizeable generational shift to 2nd Gen with an estimation of more than 50% VFB having 2nd Gen in the board.
Real estate is the most common industry in which wealth originates. Most of millionaires invest their money into or having real estate related business.
• Common planning structure.
Family governance
• Rules and structures agreed in advance: To provide clarity and align expectations of family members. About how the family makes decisions and monitors performance
governing the family business, family wealth and family office. • Includes succession planning for key decision makers and pre-agreed
conflict resolution mechanism. • Such as:
Family Constitution. Family Board.
• Critical particularly when the founder(s) pass as a Code of Conduct for how NextGen interact with each other and with the family business/family office.
What is family governance?
Family governance overarching legal structures, family business, family office
Family
Personal
• If family business shares are locked up in structure, family disputes may be prolonged if there is no exit route or method to mitigate family disagreements via conflict resolution mechanisms.
• Documented statement of family’s core values, rules, policies and procedures that the family members agree upfront to align their expectations.
• The journey is key. • Allows each member to be heard:
Anticipate and debate issues calmly in advance.
Not when disputes have erupted. • Avoid feeling that policies are targeted at certain
persons. • Establish fair processes. • Intergenerational buy-in essential for future
compliance—co-develop succession plan together.
Starting point—Family Constitution
Need for Family Governance
Family constitution
Values The family values that have successfully guided the firm in its relations with customers, employees, suppliers, partners, competitors, and the community are detailed.
Employment policy The requirements family members need to meet in order to be considered for employment are enumerated.
Next-generation family-member development This policy sets out the commitment and procedures guiding the education and professional development of next-generation members.
Ownership policy Stock ownership, classes of stock, and ownership transfer policies are defined.
Family bank Special funds allocated to sponsor the development of new ventures or new initiatives by members of the family are discussed and the overall terms of use of these funds are explained.
Dividends and family benefits policy This section of the constitution educates and guides shareholders on the expectations for returns on invested capital.
Family constitution (cont.)
Liquidity policy This article discusses business valuation, buy-sell agreements in force, redemption funds, if any, and their use in wealth-creating events.
The Board of Directors or Advisory Board Its make-up, standing, authority, and relation to management, shareholders, and other entities are discussed.
Family Council meetings Their purpose, primary functions and relation to the board and shareholder meetings are discussed. Membership and its standing and operating procedures are discussed.
Shareholder meetings Their role is discussed, as are their authority and legal standing. Their relation to the board and the family council is also discussed.
If a family office has already been created, the constitution would also list and define the role of a family office and its relationship to shareholders, the family council, the board, and management of the family's other enterprises.
Structuring Southeast Asia focused funds
Recent developments and relevant considerations
Moderator
Panellist
Speakers
David Michael Allgaier Partner Deloitte China
Elaine De Guzman Partner Deloitte Philippines
Reggy Widodo Partner Deloitte Indonesia
Chen Siew-kee Investment Management Tax & Legal Leader Deloitte Asia Pacific
Han Junwei Senior Manager Deloitte Singapore
Macro overview of capital flows
Global AUM By Region, 2019, US$ $T
Asia Pacific Insights overview—in a world of slow organic growth, Asia Pacific stands out as an area of strong potential
Macro overview of capital flows
APAC accounts for 17% of global AUM…
5% 5%
…but will account for 73% of new flows going forward
China
Australia
Japan
5.3%
Global AUM: $79 T
Investment management themes and trends in Southeast Asia
• Trends and developments impacting capital inflows and outflows: Countries opening up to foreign investors (e.g., foreign equity ownership
liberalisation in Mainland China). Focus on sustainable investment and green finance. In Singapore, the MAS will
place US$2 billion with asset managers under the Green Investments Programme that was announced in 2019.
More significant outbound investments are being made by Asia Pacific investors with substantial capital (e.g., sovereign wealth funds, growth in family offices).
• Private equity investors are very active in Asia Pacific. A large amount of “dry power” is yet to be deployed.
• Tax authorities continue to focus on the investment management sector. Common Reporting Standard (CRS) reviews and audits have commenced in locations such as Singapore (as participating locations act to meet their Organisation for Economic Co- operation and Development peer review obligations).
• Global tax and non-tax factors: New fund vehicles in Singapore (i.e., the Variable Capital Company [VCC]) and
Hong Kong (e.g., Limited Partnership Fund (LPF). Coupled with various developments (including the Economic Substance Law and Private Fund Law in the Cayman Islands), there are both push and pull factors driving an onshorisation of fund management and certain fund vehicles.
Tax reform continues. For instance, the Omnibus Tax Law in Indonesia. At a product level, the changes may encourage investment into local mutual funds.
Latest trends and emerging themes
Investment management themes and trends in Southeast Asia
Regional passport and regulatory developments
Comparison of regional passport initiatives in Asia
ASEAN Collective Investment Schemes (CIS) Hong Kong–China MRF Asia Region Funds Passport
Eligibility • Qualifying CIS operators in Singapore, Malaysia, Thailand and Philippines.
• Retail investors.
• Hong Kong and mainland Chinese operators of compliant local funds.
• Qualifying fund operators from Australia, Japan, South Korea, New Zealand, Thailand.
• Streamlined authorisation process.
• Domiciled on the host country, fund registered with home regulator.
• Streamlined authorisation process.
• Fund must be registered in home country as a Passport fund.
• Streamlined authorisation/notification process.
shareholder equity of US$1 million.
• Authorised for over one year. • Fund size not less than RMB200 million. • Less than 20% of assets in host country. • Investment management function remains on home
country. • Must appoint a host country representative. • Distribution to host country investors doesn’t exceed
50 % of total assets.
• Five years experience, US$500 million FUM for fund manager, qualifications test.
• Min financial resources of US$1 million + 0.1% (capped at US$20 million).
• Mandatory custodian. • Independent oversight.
• Transferable securities, money market instruments, deposits, units of other CISs and financial derivatives.
• Additional rules apply for money market funds, master feeder funds, funds of funds and exchange-traded funds.
• Only general equity funds, balanced funds, bond funds and unlisted index funds—no money market funds.
• Only liquid assets, mandatory diversification, no leverage, restrictions on using derivatives.
Ongoing requirements
• Home regulator rules generally apply. • Ongoing reporting in host jurisdiction. • Breach reporting requirement.
• Home jurisdiction rules generally apply unless it relates to sale and distribution.
• Breach reporting requirement.
• Assets are managed in accordance with home economy laws, unless it relates to disclosure and distribution.
• Ongoing reporting to both economies. • Breach reporting requirement.
Initiatives by the ASEAN Capital Markets Forum to promote ASEAN CIS • Philippines joined as 4th signatory to the ASEAN CIS framework in
May 2021. • Working to harmonise disclosure standards. • Considering to extend the scheme to new fund types, e.g.,
infrastructure funds. • Exploring the use of digitalization to facilitate cross border offerings.
Other initiatives by MAS • Continues to promote VCCs with strong take-up of more than 300
VCCs registered since introduction of new structure in January 2020; MAS reviewing criteria for registering VCCs (e.g., single family offices).
• Established Singapore Fund Industry Group to review regulatory and tax policies, enhance capacity development, improve promotion of Singapore as a fund management hub and develop industry utilities that improves operational productivity and efficiency.
• Regulatory focus—climate risk (environment risk management guidelines for asset managers to come into effect from June 2022); conduct (misconduct reporting extended to registered fund managers).
Regulatory updates
Fund structuring in Southeast Asia
Fund structuring
Investment SPV
Fund Vehicle
Investor level • Home country considerations (differences with US, EU, Asia investors). • Investor preferences (including the ability to access Double Tax Treaties). • Investor reporting regimes and requirements.
Fund manager level • Choice of location. • Ability to manage offshore funds and offshore fund exemptions.
Fund/platform level • Fund vehicle choice—new Asian fund vehicles (Singapore, Hong Kong). • Fund platform (Singapore fund exemption schemes). • Impact of funding sources/types. • Linkage with investor preferences (including exit considerations).
Asset level • Exit issues and operational taxes (including non resident capital gains tax and indirect transfer rules
[Indonesia, Vietnam]). • Alternatives (including Private equity/venture capital and Real Estate).
Case studies
Structuring SEA PE funds for European and US investors
Case study 1
Indonesia real estate fund for Southeast Asian investors
Case study 2
Appendices
Appendix A
Mutual funds involve large pools of investors and usually have a larger focus on equities and fixed income products. A typical structure used by mutual funds is the Singapore unit trust which has the following features: • Allows for a fund to be open-ended. • Allows for investors to have limited liability. • Allows for the segregation of assets under an umbrella fund/sub-fund
structure. • No Singapore stamp duty imposed on issuance, transfer, or redemption of
units. • However, it is usually difficult for a trust to claim tax treaty benefits.
Mutual funds: Singapore Unit Trust
Use cases for the Singapore VCC
Unitholders
Viability of VCC as alternative?
Pros • Similar to the unit trust, a VCC allows for a fund to be open-ended, for investors to have
limited liability, and for the segregation of assets under an umbrella fund/sub-fund structure.
• There is an additional benefit of a VCC being potentially able to claim tax treaty benefits—subject to challenges in local tax jurisdictions.
Cons • A transfer of shares in a VCC triggers stamp duty (however, issuance and redemption of
shares do not).
Shareholders
VCC
Another common fund entity used is the Ireland VCC: • Corporate entity with separate legal personality. • Can operate as umbrella fund with segregated sub-funds. • Potentially able to claim tax treaty benefits based on Ireland’s wide treaty network. • No Irish tax on income and gains of fund insofar as it does not have any Irish taxable
investors. No Irish stamp duty on issue, transfer or redemption of shares.
Mutual funds: Corporate vehicle (e.g., Irish VCC)
VCC
(Ireland)
Pros • Singapore VCC similar to Ireland VCC in many ways—both can operate as umbrella funds with
segregated sub-funds; both are corporate entities potentially able to claim tax treaty benefits. • “Onshorisation” by choosing Singapore over Ireland where the fund manager is located here.
Cons • For the VCC, tax exemption will depend on Singapore’s 13X and 13R fund incentives. The fund
incentive will be applied to the VCC as a whole (and not to each sub-fund)—Actions of one sub- fund on investment strategy can affect the tax exemption status of other sub-funds.
Mutual funds: Irish VCC (cont.)
VCC
(Singapore)
PE funds usually make investments over at least a 3-5 year horizon. We typically see PE funds use a Cayman LP as a pooling vehicle. Key features are: • Transparent entity to serve as pooling vehicle may be attractive to PE investors due to fiscal.
transparency, tax benefits at home jurisdiction, CFC considerations etc.
Holding companies may be used: • To claim treaty benefits. • To mitigate tax on exit (subject to indirect transfer rules). • For capital structure management purposes (usually involves multiple layers of holding
companies).
Exempted LP (Cayman)
Pros • VCC potentially able to claim tax treaty benefits—subject to local jurisdiction challenges. • “Onshorisation” by choosing Singapore over Cayman Islands.
Cons • VCC has separate legal entity and is tax opaque—may be unattractive to PE investors who often
prefer transparent pooling entities due to local rules, e.g., Japanese investors. • Less familiar to international investors. • Transfer of shares in VCC may trigger stamp duty c.f. complex stamp duty analysis if transfer
instruments for a Cayman LP holding an underlying Singapore Co are executed or brought into Singapore.
Private equity funds: Cayman LP + Hold Co
Hold Co 2
Hedge funds often engage in active trading rather than passive holding of investments, resulting in less emphasis on tax treaty benefits. A common structure we see for hedge funds is the Cayman SPC.
The Cayman SPC is also often used for ‘bespoke’ private funds or multi-family office funds which are set up by service providers for clients who require individualised structures.
Features of a Cayman SPC are • Corporate entity with separate legal personality. • No requirement to employ a management company. • Can operate as umbrella fund with segregated sub-funds. • No Cayman Islands tax. • However, unable to access tax treaty benefits.
Hedge funds/‘Bespoke’ funds/MFO Funds: Cayman SPC
SPC
(Cayman)
Pros • Singapore VCC similar to Cayman SPC in many ways—both can operate as umbrella funds with
segregated sub-funds. • VCC potentially able to claim tax treaty benefits—subject to challenges in local tax jurisdictions. • “Onshorisation” by choosing Singapore over Cayman Islands.
Cons • Singapore VCC requires a Singapore manager; cf. Cayman SPC which does not have an analogous
requirement. • For the VCC, tax exemption will depend on Singapore’s 13X and 13R fund incentives. The fund
incentive will be applied to the VCC as a whole (and not to each sub-fund)—Actions of one sub- fund on investment strategy can affect the tax exemption status of other sub-funds.
Hedge funds/‘Bespoke’ funds/MFO Funds: Cayman SPC (cont.)
VCC
(Singapore)
Appendix B
Can the VCC as a CIV fund qualify for treaty benefits? • The OECD in a 2010 report considered whether CIV funds would qualified for treaty relief. These conclusions in the 2010 report were endorsed in the
Base Erosion And Profit Shifting (BEPS) Action 6 report. • The OECD definition of a CIV fund is a fund that is
Widely held; Holds a diversified portfolio of securities; and Subject to investor-protection legislation in the country in which it is established.
• In assessing whether a CIV fund qualifies for treaty benefits, the OECD identified the key issues as are whether it qualifies as a “person”, a tax “resident”, and the “beneficial owner” of the income it receives.
• We expect a VCC to satisfy each item A VCC is a corporate entity and would be a “person” for tax treaty purposes. Singapore’s tax laws allows a VCC to be a tax “resident” if its control and management takes place in Singapore. Turning to the issue of “beneficial ownership”, the OECD view is that a CIV that falls within its definition should be treated as the beneficial owner
of the income it receives, so long as the managers of the CIV have discretionary powers to manage the assets on behalf of the holders of interest in the CIV. This should be satisfied in the case of a VCC.
CIV funds and treaty relief—Threshold issue
• The Final BEPS Action 6 Report contains one example on the application of the PPT to a CIV fund. There are three examples on the application of the PPT to a non-CIV fund (Regional investment platform example, Securitisation company example, and Immoveable property example).
• The OECD examples for non-CIV funds highlight the importance of economic substance in the jurisdiction of the holding company and commercial purpose/reasons for choosing that location.
CIV funds and treaty relief—The VCC and anti-treaty shopping measures
• RCo: Resident of State R. • Collective investment vehicle.
— Manages diversified portfolio of investments. — Currently 15% of portfolio is held in shares of companies resident of
State S (SCos), from which RCo receives annual dividends. • A majority of investors in RCo are residents of State R, but a number of
investors (the minority investors) are residents of States which do not have treaty with State S.
• Investors’ decisions to invest in RCo not driven by any particular investment made by Rco.
• RCo’s investment strategy not driven by tax position of its investors. • RCo considered benefit under R/S treaty when deciding to investment in
Scos. • RCo pursues policy of full distribution of profits to investors.
CIV funds and treaty relief—OECD Example for application of PPT: CIV fund
RCo
SCos
R
S
Investors
DWHT: •30% domestic rate •10% under R-S treaty
Dividends
PPT does not apply
Majority of RCo’s investors are resident of State R
“In making its decision to invest in shares of companies resident of State S, RCo considered the existence of a benefit under the State R-State S tax convention with respect to dividends, but this alone would not be sufficient to trigger the application of PPT. The intent of tax treaties is to provide benefits to encourage cross border investment and, therefore, to determine whether or not PPT applies to an investment, it is necessary to consider the context in which the investment was made… Unless RCo’s investment is part of an arrangement or relates to another transaction undertaken for a principal purpose of obtaining the benefit of the Convention, it would not be reasonable to deny the benefit of the State R-State S tax treaty to RCo.”
• RCo operates exclusively as regional investment platform for Fund through acquisition and management of a diversified portfolio of private market investments located in a regional grouping that includes State R.
• Factors supporting State R Knowledgeable directors. Skilled multilingual workforce. State R’s membership of a regional grouping and use of the regional grouping’s common
currency. Extensive double tax treaty network: low withholding tax rates.
• RCo employs experienced management team. • RCo’s board of directors
Majority are State R resident directors with investment management expertise. Members of Fund’s global management team.
• RCo now contemplating an investment in Sco. Only part of RCo’s overall investment portfolio.
• Benefit of R/S treaty is taken into account by Rco.
CIV funds and treaty relief—OECD Example for application of PPT: CIV fund
“In making its decision whether or not to invest in SCo, RCo considers the existence of a benefit under the R/S treaty with respect to dividends, but this alone would not be sufficient to trigger the application of the PPT. The intent of tax treaties is to provide benefits to encourage cross-border investment and, therefore, to determine whether or not the PPT applies to an investment, it is necessary to consider the context in which the investment was made, including the reasons for establishing RCo in State R and the investment functions and other activities carried out in State R. In this example, in the absence of other facts and circumstances showing that RCo’s investment is part of an arrangement or relates to another transaction undertaken for a principal purpose of obtaining the benefit of the treaty, it would not be reasonable to deny the benefit of the R/S treaty to RCo.”
RCo
SCo
(Regional investment platform)
DWHT: •30% domestic rate •5% under R-S treaty •10% under T-S treaty
PPT does not apply
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2021 Southeast Asia Financial Services Tax Conference

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