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CIMA & TIHK Joint Seminar: Update on Transfer Pricing 21/F Kam Sang Building, 255-257 Des Voeux Road Central, Hong Kong Tel: (852) 2810 0438 Fax: (852) 2523 1263 Web Site: www.tihk.org.hk E-Mail: [email protected] SEMINAR OUTLINE Part 1 : Transfer pricing research in China A joint seminar organized by The Taxation Institute of Hong Kong on behalf of The Taxation Institute of Hong Kong Educational Trust & CIMA Part 2 : How transfer pricing can help in resolving tax audit and investigation cases This seminar covers China’s international transfer pricing issues from a research perspective. Specifically, this seminar provides research findings relate to transfer pricing methods, and explains their applications to transfer pricing practices. This seminar also analyses the risk of transfer pricing tax audit and discusses selected audit cases of FIEs and MNCs in China. CPD accreditation is currently being sought with the Law Society of Hong Kong. The Base Erosion and Profit Shifting (“BEPS”) and Transfer Pricing (“TP”) Bill was passed by the Legislative Council and gazetted as Inland Revenue (Amendment) (No. 6) Ordinance 2018 (the BEPS and TP Ordinance). With the formal introduction of the TP regulatory regime into Hong Kong tax legislation, the Inland Revenue Department (“IRD”) is following the global trend and taking a more aggressive attitude on TP issues in cross-border intercompany transactions. As such, it is expected that TP will be the key tax controversy area in the near future. With more TP-related tax disputes, it’s foreseeable that the difficulties in handling such cases is greatly enhanced. On the contrary, it is also possible for taxpayers to use TP methodology to resolve the existing tax audit cases in a more effective way. In this seminar, the speakers from PricewaterhouseCoopers will share the below highlights: Introduction of the new TP legislation in Hong Kong Recent development of tax controversy and dispute resolution in Hong Kong How to use TP to resolve tax controversy cases Precaution measures to prevent potential tax disputes on TP in the future Real life case studies

Transcript of RbSsXE gM dUIsNboAt Rgf sO TUsMTdMLohI N sfEt f bsdi … J px Xsbot gf s TsMdMoh dbo i f mT Mo sf t...

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CIMA & TIHK Joint Seminar: Update on Transfer Pricing

21/F Kam Sang Building, 255-257 Des Voeux Road Central, Hong Kong

Tel: (852) 2810 0438  Fax: (852) 2523 1263  Web Site: www.tihk.org.hk  E-Mail: [email protected] 

SEMINAR OUTLINE

Part 1 : Transfer pricing research in China

A joint seminar organized by The Taxation Institute of Hong Kongon behalf of The Taxation Institute of Hong Kong Educational Trust & CIMA

Part 2 : How transfer pricing can help in resolving tax audit and investigation cases

This seminar covers China’s international transfer pricing issues from a research perspective.

Specifically, this seminar provides research findings relate to transfer pricing methods, and

explains their applications to transfer pricing practices. This seminar also analyses the risk of

transfer pricing tax audit and discusses selected audit cases of FIEs and MNCs in China.

CPD accreditation is currently being sought with the Law Society of Hong Kong.

The Base Erosion and Profit Shifting (“BEPS”) and Transfer Pricing (“TP”) Bill was passed by

the Legislative Council and gazetted as Inland Revenue (Amendment) (No. 6) Ordinance

2018 (the BEPS and TP Ordinance).  With the formal introduction of the TP regulatory

regime into Hong Kong tax legislation, the Inland Revenue Department (“IRD”) is following

the global trend and taking a more aggressive attitude on TP issues in cross-border

intercompany transactions.  As such, it is expected that TP will be the key tax controversy

area in the near future.  With more TP-related tax disputes, it’s foreseeable that the

difficulties in handling such cases is greatly enhanced. On the contrary, it is also possible

for taxpayers to use TP methodology to resolve the existing tax audit cases in a more

effective way.  In this seminar, the speakers from PricewaterhouseCoopers will share the

below highlights:

Introduction of the new TP legislation in Hong Kong

Recent development of tax controversy and dispute resolution in Hong Kong

How to use TP to resolve tax controversy cases

Precaution measures to prevent potential tax disputes on TP in the future

Real life case studies

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21/F Kam Sang Building, 255-257 Des Voeux Road Central, Hong Kong

Tel: (852) 2810 0438  Fax: (852) 2523 1263  Web Site: www.tihk.org.hk  E-Mail: [email protected] 

ABOUT THE SPEAKERS

1. Professor Agnes Lo, Associate Professor of Lingnan University, Hong Kong

Professor Agnes Lo is an Associate Professor of Lingnan University, Hong Kong. She mainly teachesTaxation that covers a wide range of topics in taxation including international tax planning, transferpricing, and tax policy and its relevance to society. Professor Lo has been a faculty member at LingnanUniversity for nearly 15 years. Her primary research areas include corporate governance and disclosure,and tax avoidance in general and avoidance through transfer pricing in particular. Professor Lo co-authored a book entitled “International Transfer Pricing in China: Post WTO,” the content of which wasused as training materials for the HKICPA workshops. She has also published her work in the mainstreamaccounting journals including The Journal of the American Taxation Association, Journal of CorporateFinance, Journal of Accounting and Public Policy, International Tax Journal, etc. Her research work hasalso been featured in numerous issues of the local business magazine as such Capital Magazine.

2. Ms Wengee Poon, Director, PricewaterHouse Coopers Limited

With extensive experience in transfer pricing, Wengee has resolved transfer pricing matters for numerous multinational corporations.  Her experience includes assisting clients in determining theirtransfer pricing structures, formulating transfer pricing policies, preparing transfer pricing documentationand performing post-implementation structure maintenance services. Wengee has served a broad spectrum of multinational corporations in various industries including garments,chemicals, telecommunications, electronics, pharmaceuticals in the manufacturing, distribution andservicing aspects.   Wengee is also a speaker at public seminars and has contributed to professional publications.  She holds aBachelor degree in Economics and Statistics and a Master degree in Business Administration from theUniversity of Rochester, New York, U.S.A.

3. Ms Karen Au, Senior Manager, PricewaterHouse Coopers Limited

Karen has over 10 years professional experience in the taxation field and extensive experience in assisting clients to resolve Tax Controversy cases with the Hong Kong Inland Revenue Department andfocusing on tax audit and investigation.Karen has been providing Hong Kong tax controversy and business related advisory to local, regional andmultinational clients, particularly those in the industries of apparel and electronic manufacturing,pharmaceutical, general trading, sourcing, financial services and asset management.Over the years, she assists companies and individuals in dealing with pro-longed tax disputes andconducting tax advisory assignments including group restructuring, inter-company fee arrangement andpost implementation health check using the tax audit methodology. Karen is a fellow member of the Association of Chartered Certified Accountants (ACCA) and member of theHong Kong Institute of Certified Public Accountants (HKICPA) and the Taxation Institute of Hong Kong.  Sheis also a Certified Tax Adviser (Hong Kong).

CIMA & TIHK Joint Seminar: Update on Transfer Pricing

A joint seminar organized by The Taxation Institute of Hong Kongon behalf of The Taxation Institute of Hong Kong Educational Trust & CIMA

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Language : Cantonese

Proficiency : Intermediate Level

(For detail, please refer to the Institute's website)

Fee : HK$250 for TIHK members

HK$300 for members of CPD Alliance

HK$350 for non-members

(Online Enrolment is suggested, please click here )

2 CPD HOURSDate : 16 May 2019 (Thursday)

Time : 6 : 45 pm - 8 : 45 pm (6 : 15 pm registration) 

Venue : Room UR8, SCOPE, 8/F, United Centre,            

                95 Queensway, Admiralty, Hong Kong

Speakers :

1. Professor Agnes Lo, Associate Professor of Lingnan University,         

    Hong Kong

2. Ms Wengee Poon, Director, PricewaterHouse Coopers Limited

3. Ms Karen Au, Senior Manager, PricewaterHouse Coopers Limited

Registration Form (Please “ ” appropriate box) Program code: 20190516

Payment Method

Online payment is encourage, please visit : http://www.tihk.org.hk/v2/event/detail/601By Cheque: 

Please send a crossed cheque payable to “The Taxation Institute of Hong Kong Educational Trust” Cheque No: ________________________________Bank Code:_________________________________________

TIHK members: $250                                                                  Non-members: $350 CPD Alliance: $300, please specify:  _________________________________________________________________ Name: ______________________________________  Membership No (if any): ______________________________ Company: ________________________________________________________________________________________ Address: _________________________________________________________________________________________ Day-time Tel: _________________________________ E-mail (for confirmation): _____________________________

Notes:

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2.1. All applications are accepted on a first-come-first-served basis.

Successful applicants will receive an e-mail confirmation at least 2 working days before the seminar. Unsuccessful applicants will also be notified around the same time. If you have not heard from the Institute regarding your registration 2 days before the seminar or if you have any other enquiries related to the seminar, please contact Mona Ho at 2810 0438 or [email protected] REFUND will be made unless the seminar is cancelled.If a black rainstorm warning or typhoon no.8 is hoisted, all scheduled seminars may be cancelled or postponed. Please refer to our website announcement on the date of the seminar. The Institute reserves the right to change the venue, date, speaker or to cancel the seminar due tounforeseen circumstances.All personal data collected from the enrolment process and administration of the CPD Programmes  willonly be used for the purpose of the administration of the seminar on which members are enrolled. TheInstitute may also use the collected data for statistical research and analysis and for other internal uses.

Please send the completed form together with full payment with the cheque to 21/F, Kam Sang Building, 255-257 Des Voeux Road, Central

CIMA & TIHK Joint Seminar: Update on Transfer Pricing

A joint seminar organized by The Taxation Institute of Hong Kongon behalf of The Taxation Institute of Hong Kong Educational Trust & CIMA