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2016 QUEENSLAND TAX FORUMAn economy in transition

13.5 CPD hours 18–19 August 2016

Brisbane Marriott Hotel

2 - THE TAX INSTITUTE - 2016 Queensland Tax Forum

WELCOME2016 Queensland Tax Forum

Early bird offer – Register before Friday 1 July 2016 to SAVE!

Welcome to the 2016 Queensland Tax Forum.

We live in interesting times and a year on we seem no closer to achieving any semblance of “tax reform”. However what we do know is that the economies here in Queensland, in Australia and globally are in transition. The way our clients do business is changing. How do we get ahead of the game?

We open the forum this year with a keynote address from Treasury’s Roger Brake, Acting Deputy Secretary of the Revenue Group, who will consider the importance of strategic tax reform and policy development in this time of economic transition. Following this address we are again offering two streams in our program: one stream was developed for those members advising in the SME market and the other focuses on advisers and in-house tax managers and teams in the corporate market. I commend the program to you.

I am also pleased to welcome Kate Carnell, the newly appointed Small Business and Family Enterprise Ombudsman who will address the SME delegates on the scope and powers of the new role.

This year you can once again purchase an employer ticket, which allows you to send multiple staff from your office to attend select sessions with a single ticket.

We hope you take full advantage of this two-day forum and bring plenty of questions for our speakers who are all experienced specialists in their respective fields.

Sarah Blakelock, CTAChair, 2016 Tax Forum Organising Committee

Thank you

The Tax Institute gratefully acknowledges the generous assistance of the 2016 Queensland Tax Forum Organising Committee:

Sarah Blakelock, CTA, KPMG (Chair, 2016 Tax Forum Organising Committee)

SME Stream Committee:

Steven Lutz, CTA, Lutz & Associates (Chair, SME Stream Committee)Rosalie Cattermole, CTA, PwCNeal Dallas, CTA, McInnes Wilson LawyersSandra Girgenti, BDOTony Hoffman, CTA, Hoffman Kelly Chartered AccountantsStephen Holmes, CTA, WMS Chartered AccountantsJodie Mills, CTA, Small Myers HughesKatherine Patel, HLB Mann JuddLetitia Weatherhead, ATI, DKM Group

Corporate Stream Committee:

Stuart Landsberg, CTA, PwC (Chair, Corporate Stream Committee)Andrew Cornish, CTA, BHP BillitonTim Hands, CTA, Grant ThorntonBrendon Lamers, ATI, KPMGEvan Last, CTA, DeloitteJasmine Leonard, ATI, Rio Tinto LtdAndrew Lowe, CTA, Aurizon Holdings LtdPeter Nearhos, CTA, QICPraty Patel, CTA, StockwellReid Zulpo, ATI, EY

Proudly supported by:

THE TAX INSTITUTE - 2016 Queensland Tax Forum - 3

Day one – Thursday 18 August 2016

Time Plenary

8.00am–8.45am Registration

8.45am–9.00am President’s WelcomeSpeaker: Arthur Athanasiou, CTA, President, The Tax Institute

Opening AddressSpeaker: Sarah Blakelock, CTA, Chair, Forum Organising Committee

9.00am–10.00am Session 1: Keynote Address – “Tax Reform and Policy for an Economy in Transition” Speaker: Roger Brake, Acting Deputy Secretary of the Revenue Group, Treasury

The Acting Deputy Secretary of the Revenue Group, Roger Brake, will consider the importance of tax reform and policy for an economy in transition.

10.00am–10.30am Morning tea

Time SME stream Time Corporate stream

10.30am–12.00pm Session 2A: Trusts and Trust Losses – Everything You Need to KnowSpeakers: Paul Banister, CTA, Grant Thornton; Damian O’Connor, CTA, Tax + Law

Trusts are common SME structures, yet too often they are used incorrectly or are assumed to be something they are not. This session will be delivered from two perspectives and consider:

� What should be included in a trust deed � Important trust tax law cases, and what they mean in practice � Resettlements, variations and vesting � Tax accounting for trusts � Family trust elections and interposed entity elections – what you should consider?

10.30am–11.30am Session 2B: Topical M&A in the TropicsSpeakers: Reid Zulpo, ATI, EY; Natalie Chang, EY

M&A activity is at record highs, driven by industry consolidation and the requirement to replace organic growth with inorganic growth. This session provides an overview of the big issues that are testing the resources of advisers and the ATO, including:

� Asset push-down and consolidation issues on acquisition � How to effect an asset/entity spin-out � Consolidation issues that arise on leaving.

12.00pm–12.30pm Session 3A: Small Business Restructure RolloverSpeaker: Mark West, CTA, McCullough Robertson

The small business restructure rollover (applicable from 1 July 2016) provides restructure opportunities not previously available to small businesses, allowing for asset transfers from companies to individuals and trusts. However, there are traps and anti-avoidance measures which need to be taken into account when applying the rollover. This session considers:

� The conditions that need to be met and the consequences of choosing the rollover to apply

� What the concept of a “genuine restructure of an ongoing business” means for the purposes of the integrity rule in the rollover

� What the concept of “ultimate economic ownership” means � Whether consideration needs to be paid as part of the rollover even if the law does not require it.

11.30am–12.30pm Session 3B: How to Approach A Transaction – Interacting with the ATOSpeakers: Brendon Lamers, ATI, KPMG; Peter Maher, ATO

Managing the big issues and working with the ATO to deliver appropriate outcomes is an important part of any M&A transaction. The ATO is becoming increasingly involved in transactions in “real time” and appropriate engagement is crucial. This session considers the practical implications of:

� Corporate reorganisations as part of a transaction � Specific issues arising out of the nature of investors � The ATO’s views on topical transaction issues (eg MITs) � The ATO’s approach to transaction management including FIRB.

TECHNICAL PROGRAM


TECHNICAL PROGRAM

Day one – Thursday 18 August 2016 (cont)

Time SME stream Corporate stream

12.30pm–1.30pm Lunch

1.30pm–2.30pm Session 4A: Expatriates and International Assignees – A Tax Guide For An Employer’s First TimeSpeakers: Hayley Lock, KPMG; Melissa Rowbottom, Hatch Pty Ltd

With more SMEs seeking to expand their operations globally, tax practitioners are increasingly required to provide advice to employers not only on their business tax considerations, but also on the various employer and employee obligations in those jurisdictions. For an SME undertaking this activity for the first time, there is a confusing network of rules to navigate. This session provides an overview of the key tax issues for employers and employees to ensure SME clients are aware of their various obligations, including:

� Being a good corporate citizen – are your employees paying the correct individual income tax in the correct jurisdiction?

� Fringe benefits tax and expatriate employment packages � Employer superannuation obligations and bilateral social security agreements � Reciprocal health care agreements and private health insurance requirements.

Session 4B: Mastering The Indirect Tax Function – From Both SidesSpeaker: Tony Windle, ATI, Grant Thornton

This session will consider the challenges and the solutions of mastering the indirect fashion efficiently. Increasingly, technology can be used not only to manage indirect tax exposures but also to add value across the business. This session provides insights from both the adviser and the client on their experiences in a global indirect tax enterprise resource planning (ERP) implementation, including:

� Business transformation and value realisation across the aspects of people, process and technology in an ERP environment

� Tax determination versus compliance – what do they really mean? � Culture change across business to appreciate tax risk when automating indirect tax.

2.30pm–3.30pm Session 5A: Employee Share Schemes in an Emerging EconomySpeaker: Stephen Holmes, CTA, WMS Chartered Accountants

The tax rules for employee share schemes (ESS) have been criticised for being too complex, inflexible and failing to provide genuine incentives for SME business to attract and retain key workers. The ESS rules have recently been amended and now include a specific concession for start-ups. This session considers:

� The operation, practical effect and opportunities arising from the latest changes to the ESS rules, including the start-up concession for SME businesses

� How to establish and maintain an SME ESS, including the documentation of a scheme and the issues to be addressed when providing both tax and corporate advice

� The practical alternatives to an ESS for SMEs to reward and attract workers � When an ESS is advantageous and when non-ESS arrangements should be considered.

Session 5B: Managing A Changing Tax and Shared Services FunctionFacilitator: Andrew Lowe, CTA, Aurizon Panel: Praty Patel, CTA, Stockwell; Patrick Grob, Deloitte

Managing a tax and shared services function to add value in changing economic times is likely to include outsourcing of some tasks. This session provides insights on the “how to”, “tips and traps” and “war stories” in the life cycle of an outsourcing project, including:

� Identifying the problem and need � Consideration of the enablers – process simplification, standardisation and IT systems

� Investigating and evaluating alternative structures, locations and providers � Internal deliverables including board approval requirements, rollout strategy, business case capital requirements and cost reductions

� Set-up, rollout and management of the ongoing service provision including KPIs, training and risk management.

3.30pm–4.00pm Afternoon tea


TECHNICAL PROGRAM

Day one – Thursday 18 August 2016 (cont)

Time Plenary

4.00pm–5.30pm Session 6: Part IVA – Eight FactorsSpeaker: Anthony Portas, CTA Panel: Kirsten Fish, CTA, ATO; Bill Thompson, CTA, Minter Ellison Panel moderator: Sarah Blakelock, CTA, KPMG

There are eight factors in Part IVA which must be considered in determining whether a party has a dominant purpose of obtaining a tax benefit in connection with a scheme. The session will:

� Consider the history and meaning of each of the eight factors � Analyse the principles which have evolved from case law in respect to each of the eight factors � Compare and contrast some of the principles which have arisen from those cases, including the circumstances which have led to a factor being decided for, against or neutral to a taxpayer

� Consider the ATO guidance on the eight factors.Following the main presentation, a panel will provide practical guidance on how to consider each of the eight factors in a day-to-day Part IVA analysis.

5.30pm–7.00pm Networking drinks and canapés

Day two – Friday 19 August 2016

Time Plenary

8.00am–8.30am Registration

8.30am–9.30am Session 7: Economic InsightSpeaker: Daryl Conroy, Suncorp Bank

Our economy globally, nationally and locally is in transition. This session will provide an insight into where our economy is heading and what we can expect on the horizon.

9.30am–11.00am Session 8: Your Career – Maximising Potential in a Changing EnvironmentFacilitator: Praty Patel, CTA, Stockwell Panel: Stuart Cameron, CTA, Suncorp Group; Andrew Lowe, CTA, Aurizon Holdings Ltd; Janet McLeod, The WRAP Group; Linda Tapiolas, CTA, Cooper Grace Ward Lawyers

In our constantly changing world, we as businesses and tax professionals need to adapt to survive. The greater challenge is to adapt in such a way as to maximise our potential and that of our teams. This session will provide insights into:

� Growing the business – understanding the business acumen and drivers, how to create value and have an impact on strategy � Investing in your career and those of your team for a seat at the table – the enablers, the inhibitors and avoiding the roadblocks � Managing teams for peak performance � Managing the risk profile of your business or your clients and its impact on your career.

11.00am–11.15am Morning tea


TECHNICAL PROGRAM

Day two – Friday 19 August 2016 (cont)


11.15am–12.45pm Session 9A: Division 7A and UPEs – Where Are We At and Where Are We Going?Speaker: Linda Tapiolas, CTA, Cooper Grace Ward Lawyers

With the review of Div 7A by the Board of Taxation underway, it is appropriate to consider the application of Div 7A and what changes might occur following the completion of the Board of Taxation’s review. This session considers:

� Current hot topics in Div 7A � How Div 7A applies to commercial groups where a company forms part of a trading or investment structure

� The difficult interrelationship between Div 7A and UPEs � When to use the various options the Commissioner allows � Potential changes after the review is complete.

Session 9B: State TaxesPanel: Sarah Blakelock, CTA, KPMG; Andrew Cornish, CTA, BHP Billiton; Mark Robertson QC, CTA, Barrister; James Petterson, ATI, Deloitte

With an economy in transition, the fiscal outlook for Queensland requires a careful review of Queensland’s revenue law and tax administration policy including areas for state revenue law reform and what this means practically for taxpayers transacting in Queensland. This session provides insights into the most challenging issues facing both policymakers and taxpayers alike, including:

� How taxpayers can manage transactional tax risk in the context of state taxes � An overview and critique of a taxpayer’s rights to challenge decisions made by the Commissioner of State Revenue in comparison to the federal regime

� The Office of State Revenue’s current approach to tax administration policy and practical tools taxpayers can employ to navigate commercial challenges

� Possible opportunities for state tax policy reform and how such reform could drive investment in a rapidly transitioning state economy.

12.45pm–1.45pm Lunch

1.45pm–2.45pm Session 10A: Business Tax Considerations in a Global EconomySpeaker: Greg Travers, CTA, William Buck

In our current economy, we are seeing growing numbers of SMEs seeking to expand their operations and customer base globally. Accordingly, it is essential that advisers to SMEs have an awareness of the key issues in structuring, profit repatriation and other compliance matters to ensure unfavourable outcomes are avoided. This session considers key areas to be addressed when advising our clients on their cross-border business expansion, including:

� When do you have a permanent establishment and what regulatory and compliance issues must be considered when you have one?

� How do double tax agreements work with respect to withholding taxes, foreign tax credit entitlement, franking credits and GST/VAT?

� Ensuring you have the right structure to facilitate cross-border operations and how to effectively repatriate offshore profits to manage the overall tax rate at the shareholder level

� When the transfer pricing provisions apply.

Session 10B: Tax Issues For Distressed TimesSpeakers: Teresa Dyson, CTA, Deloitte; Evan Last, CTA, Deloitte

Current economic conditions and global uncertainty is resulting in significant commercial challenges for Australian businesses. This session considers how tax professionals should manage the resulting tax issues, including:

� Losses – ensuring maximum recoupment including proposed changes to SBT � Asset sales – availability of capital losses (ss 165-CC and 165-CD) � Increased debt and asset impairments – managing thin capitalisation, including the use of revalued tax balance sheets and the worldwide gearing ratio

� Franking credits – managing available franking credits with reduced Australian profits and international footprints.


TECHNICAL PROGRAM

Day two – Friday 19 August 2016 (cont)


2.45pm–3.45pm Session 11A: Address from the Small Business and Family Enterprise OmbudsmanSpeaker: Kate Carnell, Ombudsman: Small Business and Family Enterprise

Kate Carnell commenced her role as Australia’s first Small Business and Family Enterprise Ombudsman in March 2016. It is early days, but the new Small Business Ombudsman has identified two key roles. First, to act as an advocate for small and medium business and to be a conduit to government for them – a single entry point. Second, to focus on alternate dispute mechanisms, so small businesses don’t get caught up in lengthy and expensive disputes which may ultimately end up in court, whether that is with a regulator (such as one of the revenue authorities) or in commercial disputes. The Ombudsman’s terms of reference are wide and practical. We look forward to hearing from Kate about her first six months in the role and some of the opportunities she is seeing to make it easier for small and medium business in Australia, and the practical ways the Ombudsman’s office can assist small and medium business and family enterprises.

Session 11B: Changing Times in International Tax Speakers: Peter Collins, FTI, PwC; Michael Bona, CTA, PwC

This session provides an update on the major legislative and administrative changes in the international tax environment in recent times, including:

� The changed transfer pricing environment, including s 815-B and the ATO’s focus on debt pricing post-Chevron

� The politics and the practicalities of the multinational anti-avoidance law (MAAL) � The practical implications of the new(ish) participation exemption, including what this means for quasi-equity interests

� A survey of other relevant administrative and legislative international tax changes.

3.45pm–4.00pm Afternoon tea

4.00pm–5.00pm Session 12A: Transitioning to Retirement with an Eye on Super – Five Issues for SME OwnersSpeakers: Neal Dallas, CTA, McInnes Wilson Lawyers; Chris Wyeth, CTA, ipac

The super and tax rules have specific interactions that impact on retirement decisions, especially for SME owners. This session considers five issues that can affect the transition to retirement phase, including:

� Transitioning the next generation into the business � Specific Div 152 issues for would-be retirees � What contribution strategies should be considered in the lead-up to retirement? � Is it a “no brainer” for an SME owner to commence a transition to retirement pension?

� What if retirement doesn’t work out? What is the impact of transitioning back to the workforce?

Session 12B: Tax Transparency is Here to StaySpeakers: Ann-Maree Wolf, CTA, Rio Tinto Ltd; Andrew Porter, AFIC

The demand for tax transparency in Australia is increasing and the pressure on Australian corporates to respond will increase. This session considers tax transparency in Australia and practical aspects related to strategy and compliance, including:

� The tax transparency state of play globally and how this has shaped the debate in Australia

� Emerging tax transparency initiatives within the Australian framework, including the proposed Tax Transparency Code, the rules on general purpose financial statements and the impact of ATO disclosures on tax data

� Practical issues relevant to determining your organisation’s response to the changing tax transparency environment.

5.00pm Forum close


PRESENTER PROFILESAn overview of our experts

Arthur Athanasiou, CTA, a partner at Thomson Geer Lawyers, has many years experience in complex tax litigation and tax audit negotiations and settlements. Arthur’s main area of practice is taxation advisory, with an emphasis on dispute resolution, particularly in the SME sector, with both the ATO and the SRO. He also has broad experience in the taxation of trusts and SME entities, with an emphasis on Div 7A and high-wealth individuals and family groups. Arthur has extensive experience in all areas of direct and indirect taxation and has qualified as a Chartered Accountant. He has also held senior taxation and management positions in the transport and motor vehicle industries, with specialist experience in logistics, supply chain, chain of responsibility and contract warehousing. Arthur is the President of The Tax Institute as well as a State Councillor, and also chairs the Law Institute’s Tax Law Advisory Committee. Arthur is an Accredited Tax Law Specialist and a widely published writer on taxation issues. He regularly appears in the mainstream media, and presents at tax seminars and discussion groups. Arthur has been recognised in Doyle’s Guide 2015 as a recommended tax lawyer in Victoria.

Paul Banister, CTA, is a Chartered Accountant and a Partner at Grant Thornton, leading their tax division in Brisbane. He has over 30 years experience working with clients to help them navigate through complex and potentially risky tax and commercial issues. His expertise includes domestic and international tax planning, transaction advisory and support, superannuation structuring and advice, succession planning and estate planning. Paul has presented at many professional and business forums, both in Australia and internationally. He is also a contributing author to Thomson Reuter’s Financial Planning Handbook.

Sarah Blakelock, CTA, is a partner in KPMG’s Tax, Disputes & Controversy team. Sarah assists taxpayers and their advisers in the resolution of tax disputes with both the federal and state revenue authorities, whether at risk review, audit or objection stage, through strategic engagement and negotiation with the revenue authorities. Sarah also has extensive experience in the conduct of litigated tax

disputes before the federal and state courts and tribunals and the High Court.

Michael Bona, CTA, is a corporate tax adviser at PwC with over 13 years experience advising Australian and foreign multinational companies on the tax aspects of their businesses, specialising in cross-border transactions, financing and M&A in the resources sector. Michael holds a Bachelor of Laws (with Hons) from the University of Queensland and Masters of Laws from the University of Melbourne. He is admitted to practice in Queensland, Victoria and Western Australia.

Roger Brake is the Acting Deputy Secretary of the Revenue Group within Treasury, which provides advice to the Government on revenue and taxation policy matters. Rogers’s previous positions included the Division Head of the Tax White Paper Task Force, heading up the Treasury team who support the Tax White Paper process. Roger has also led the Treasury division responsible for revenue forecasting, costings, distributional analysis and modelling, being Chief Adviser (International) in Macroeconomic Group and Principal Adviser in Financial System Division, including heading up the Treasury team for the Cooper superannuation review. He has also led the Treasury’s retirement and personal income tax division and has had a senior executive secondment to the ATO.

Stuart Cameron, CTA, has been working at Suncorp since 1998, including as its Group Taxation Manager from December 1999 to September 2013, and in a sponsorship role establishing a finance shared services function including offshored aspects. Currently, Stuart has group oversight of financial risk management in balance sheet and business operations, group financing and capital activities. Most recently, Stuart has focused on the financial risk consequences of organisational redesign and regulatory reform, including Basel III, for financial institutions.

Kate Carnell, AO, is the Australian Small Business and Family Enterprise Ombudsman (ASBFEO). The role of the ASBFEO

is to advocate for small businesses and family enterprises, to provide access to alternate dispute resolution services to assist in avoiding expensive legal proceedings, and to ensure that government policies and regulations take into account the needs of small businesses and family enterprises. Kate is well known and respected in the not-for-profit and business communities having served as CEO of the Australian Chamber of Commerce and Industry, beyondblue and the Australian Food and Grocery Council. Kate also served as Chief Minister of the ACT from 1995 to 2000 and was appointed Officer of the Order of Australia in 2006.

Natalie Chang of EY has more than 13 years experience in corporate tax advisory in both public practice and as a corporate tax manager, including a year in EY’s New York office. Natalie has extensive international and transaction tax experience with a focus on the energy and infrastructure sectors. Natalie has recently worked on several significant infrastructure and PPP transactions in Australia. Previously, Natalie was the Australian Head of Tax at a global oil and gas group.

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

Darryl Conroy has over 20 years experience in the field of finance and treasury. Darryl is the economic face of Suncorp Bank and sits within the Treasury team in Brisbane. He has been with Suncorp since 2004. In this role, Darryl writes regular articles and market updates on the economy and provides analysis on interest rates, foreign exchange and commodities. Previous roles include the management of a corporate treasury for an insurance and banking corporation. Darryl is a member of the Australian Financial Markets



Association (AFMA) and completed postgraduate studies with the Securities Institute of Australia (FINSIA) and CPA Australia.

Andrew Cornish, CTA, is currently Manager, TAX APAC Operations at BHP Billiton, managing taxes across BHP Billiton’s coal operations in Australia, Indonesia and the US. With over 12 years experience, Andrew has previously held positions with Ausenco and EY. During this time, Andrew has advised on direct and indirect tax compliance, mineral royalties, transfer pricing, audit and dispute resolution, policy development and structuring (joint ventures and M&A). Andrew has significant experience in the resource industry and a proven record in managing high-performing tax teams that deliver results.

Neal Dallas, CTA, is a Principal in McInnes Wilson Lawyers’ Superannuation and Revenue Group. He has extensive experience advising clients in the areas of superannuation, tax, estate planning and asset protection. He has advised corporate, industry and self-managed funds and their employers across a range of superannuation-related matters, including fund establishment, fund mergers and transfers, benefit payment issues, superannuation borrowing arrangements, taxation of contributions and earnings, fund wind-ups and trustee training.

Teresa Dyson, CTA, is a Senior Tax Partner at Deloitte, advising clients on infrastructure, financing, corporate tax issues, M&A activity and tax controversy matters. Teresa is actively involved in the legal and tax professions and is the former Chair of the Board of Taxation and Chairman of the Business Law Section of the Law Council of Australia.

Kirsten Fish, CTA, is Chief Tax Counsel at the ATO. She joined the ATO in December 2014 as Deputy Chief Tax Counsel (North). Kirsten is one of the highest legal authorities within the ATO, providing technical leadership in relation to significant tax issues, cases and rulings. Prior to joining the ATO, Kirsten was a Tax Partner at Clayton Utz with a focus on the financial services industry

and provided finance and investment transaction advice. She has won a number of awards, including being named “Rising Star” in Tax (2013) in the Euromoney LMG Australasian Women in Business Law Awards, and was voted by peers as one of Australia’s Best Lawyers in Tax in 2013.

Patrick Grob, CTA, is a Tax Partner at Deloitte and leads Deloitte’s Australian Tax Management Consulting practice, specialising in tax strategies, board reporting, tax risk management frameworks, tax technology solutions and tax transformation projects. Patrick brings a practical, commercial approach to working with clients. He has over 20 years of experience working within Corporate Group Tax teams in Australia and the UK. Prior to joining Deloitte in 2015, Patrick was Head of Tax at Suncorp, where he had responsibility for all tax compliance, reporting and advisory obligations across Australia and New Zealand.

Stephen Holmes, CTA, is a Partner at WMS Chartered Accountants based on the Gold Coast. Stephen has a particular focus on CGT, taxation implications of trusts and SME tax issues generally. He assists clients to legitimately reduce their overall tax burden by innovative structuring and detailed planning. He is a regular resource for other accounting professionals on tax matters. He is also a regular speaker on tax matters across south-east Queensland and northern New South Wales. In addition to holding masters degrees in both Taxation and Economics, Stephen completed a Juris Doctor degree at Bond University Law School in 2013 with first class honours.

Brendon Lamers, ATI, is a Partner at KPMG working in the Infrastructure and Property Tax team. He has over 15 years experience in providing taxation advice to a variety of financial institutions, foreign pension funds, infrastructure arrangers as well as to large domestic and multinational corporate clients. He has also worked at Babcock & Brown advising on numerous acquisitions and disposals. Brendon has advised various infrastructure consortiums during the bid and mandate phases of several infrastructure projects.

Evan Last, CTA, is a Partner in the Deloitte Brisbane tax practice. He has over 15 years corporate and international tax experience and has advised on a broad range of tax issues to Australian and foreign listed corporations, large private companies, private equity firms and government-owned corporations across all industries. He has significant experience in advising clients on the international tax aspects of inbound and outbound investments, tax due diligence and transaction support, tax consolidations, cross-border financing, tax losses and tax-effect accounting. Evan is currently the Chair of the Queensland Professional Development Committee for The Tax Institute and is also a Chartered Accountant.

Hayley Lock is the lead of KPMG’s Employment Taxes practice in Queensland with over 10 years of experience in assisting clients with FBT, payroll tax, PAYG withholding and superannuation guarantee obligations. Hayley started her career working in commerce preparing the FBT returns for one of Queensland’s largest listed companies. Following this, Hayley joined KPMG and has since assisted a wide variety of clients on a broad range of FBT compliance and consulting jobs. In particular, Hayley has assisted in the preparation of FBT returns for some of Australia’s largest energy and natural resources sector companies. This experience provides Hayley with an excellent understanding of some of the practical challenges that employers face in meeting their FBT obligations.

Andrew Lowe, CTA, has over 18 years tax and finance experience. This has included working in professional services as a Chartered Accountant with Arthur Andersen and as an in-house tax manager for the Australian arm of the UK listed mining group, Anglo American. More recently, he held the head of tax and then deputy CFO roles with listed waste management group Transpacific, where his responsibilities included tax, statutory and group accounting, insurance, carbon and shared services. Andrew has recently joined listed rail freight operator Aurizon Holdings Ltd in his current role as Manager Group Tax and Shared Services Finance. During his professional career, Andrew has worked on transactions and projects spanning M&A, direct and indirect taxes, relationship



management and taxation audits with various regulators, along with management of transactional teams, statutory and group reporting, process improvement opportunities and operational projects.

Peter Maher is a Director in the ATO’s Public Groups & International area. Peter currently leads the ATO’s Infrastructure Team and as such is involved with most state privatisations and also major infrastructure transactions. Peter also oversees the administration of the National Tax Equivalent Regime. Peter has also worked for a Big 4 accounting firm, has been engaged by the World Bank to work with the tax administrations of a number of developing countries, and currently is engaged as a consultant with the International Monetary Fund advising the Chinese State Administration of Taxes.

Janet McLeod is an Organisational Psychologist and has been working in the field of psychology for over 15 years. Janet is an experienced consultant, facilitator, coach and speaker. She brings experience, skill and innovative thinking to the areas of leadership and executive development, workplace wellbeing and performance, and cultural alignment. Her work incorporates best practice methods and creative designs to produce sustainable change. Janet’s clients include Daimler, Mercedes Benz, KPMG, Department of Justice, Deakin University, Swinburne University, and Lumo Energy.

Damian O’Connor, CTA, is the Managing Principal of the specialist taxation firm Tax + Law. He has more than 40 years experience in tax and commercial and family legal issues in Brisbane and Melbourne. His experience includes 23 years with the Australian Taxation Office and as a tax partner of a national law firm. He is a regular presenter for The Tax Institute, professional development providers, professional associations and universities.

Praty Patel, CTA, joined the Stockwell Group as the COO responsible for Stockwell Group’s operations (including Property Development, Funds Management and Property Management),

strategic initiatives in conjunction with the management team and to further support the Accounting & Finance Department. Praty worked as a Chartered Accountant and became a member of the ICAA in 1998 and a Chartered Tax Adviser of The Tax Institute. He has over 18 years of experience in finance (across APAC, Africa, North America and South America), including M&A, international finance, taxation and treasury, within chartered accounting (Ernst & Young) as well as publicly listed companies (Ausenco Limited, London Stock Exchange).

James Petterson, ATI, an Account Director at Deloitte in Brisbane, advises government and private sector clients in relation to state taxes matters, including stamp duty, payroll tax and land tax matters. James advises on state tax matters across all Australian jurisdictions and has extensive experience in advising clients on stamp duty planning in relation to corporate restructuring and acquisitions, advising government on major infrastructure divestment projects, and advising clients on transactions across all business sectors. In addition, James is a contributing author to LexisNexis’s Australian Stamp Duties Law.

Anthony Portas, CTA, was most recently the Head of Tax, Asia Pacific for the Anglo American mining group, where he spent 18 years in various tax roles. Prior to that he was a manager at a Big Four firm. Anthony has had extensive involvement in tax policy and technical matters, and was a former chair of the Minerals Council of Australia tax committee, and a Corporate Tax Association executive committee member. He was also a member of the Resource Tax Implementation Group, formed by Federal Treasury to develop the legislation for the former Minerals Resource Rent Tax.

Andrew Porter joined the Australian Foundation Investment Company (AFIC) in January 2005. He is a Chartered Accountant and has had over 20 years experience in accounting and financial management both in the UK with Andersen Consulting and Credit Suisse First Boston (CSFB), and in Australia where he was Regional Chief Operating Officer for the Corporate and Investment Banking

Division of CSFB. He is also a non-executive Director of the Royal Victorian Eye & Ear Hospital and a member of the National Executive of the G100, the peak body for CFOs.

Mark Robertson, CTA, is a Queen’s Counsel with chambers in Brisbane and Sydney. He has appeared in many anti-avoidance cases Australia-wide for taxpayers and for the Commissioner.

Melissa Rowbottom is a Chartered Accountant and the Global Mobility Tax Lead (Asiapac) at Hatch Pty Ltd. Melissa began her career in professional services with PwC in Sydney. She has over 10 years experience working with clients to address the complex employment tax issues associated with moving individuals across international markets. Melissa has worked with clients across a wide range of industries assisting them to enter and set up operations in new locations. Melissa has gained expertise in a mixture of tax jurisdictions and has worked with PwC in the UK and US, developing a strong expatriate tax focus in these countries and a global outlook. Now working with Hatch, Melissa has the opportunity to practically apply her international tax experience to the challenges faced by the resources industry on a day-to-day basis.

Linda Tapiolas, CTA, is a Partner in the Cooper Grace Ward Lawyers Commercial Team. She provides a range of support services to accountants, financial planners and other professional advisers. This includes technical advice on complex tax, CGT, Div 7A issues, and acting on business sales and acquisitions to ensure clients achieve commercial and tax-effective outcomes. Prior to joining Cooper Grace Ward, Linda worked as an accountant for 18 years advising clients on capital gains, business acquisitions and restructuring. She also conducted seminars and training sessions on various topics including CGT small business concessions.

Bill Thompson, CTA, is Minter Ellison’s Australian Tax Practice Leader. He is a past National Chair of the Taxation Committee Law Council of Australia, a past Chair of The Tax Institute, Queensland Division and a past executive officer of the Taxes



section of the International Bar Association. He advises Australian and international corporates and high-wealth private groups on structuring and transactional matters. He brings to his advice significant experience concerning the resolution of disputes involving statutory anti-avoidance provisions, including those in s 260, Part IVA, the GST and state taxes. Bill, for example, was the instructing solicitor in the Pincus case and in the Eastern Nitrogen case at all levels. He is well known as a presenter and author on tax issues and has been an invited speaker on many occasions for tax conferences of the IBA, and also for the American Bar Association Tax Committee (Foreign Lawyers) and the Taxation Academy of Singapore. He is Minter Ellison’s Brisbane Managing Partner.

Greg Travers, CTA, is the Director in charge of the Tax Services division of William Buck in Sydney. His clients are predominantly private businesses, both Australian and foreign-owned, as well as higher wealth individuals and families. The work undertaken by Greg is primarily advising on issues and transactions such as restructuring, exit strategies, business acquisitions and international expansion, along with referrals from accountants, lawyers and other advisers. Greg is the author of The Tax Adviser’s Guide to Part IVA, published by The Tax Institute.

Mark West, CTA, is a Partner at McCullough Robertson and is qualified both in law and as a Chartered Accountant. He advises clients on tax matters generally, including income tax, CGT, GST and payroll tax, and has acted in appeals to the AAT and Federal Court.

Tony Windle, ATI, is a Partner in Indirect Tax at Grant Thornton and is the Global Head of Indirect Tax for Grant Thornton International. Tony advises clients throughout Australia and across Asia-Pacific and Europe, the Middle East and Africa to reduce the marginal cost and streamline the management of indirect taxes affecting their business or transaction. He works across many Grant Thornton International member firms to support those tax practices regarding new tax systems (Malaysia GST, India GST, UAE VAT), and also leads project implementation teams for tax technology and system upgrades on a global basis.

Ann-Maree Wolff, CTA, is General Manager Taxation, Asia Pacific at Rio Tinto with regional responsibility for all taxation matters related to Rio Tinto’s businesses in Australia and the broader Asian region. She has been a tax practitioner in the resources industry for over 20 years and has actively participated in tax policy consultation and advocacy for much of that time. Ann-Maree is also a member

of the Board of Taxation, which is a non-statutory advisory body that provides the Australian Government with real-time advice on tax policy issues by contributing a business and tax community perspective to improving the design and operation of taxation laws.

Chris Wyeth, CTA, is a Client Adviser at ipac providing financial and investment advice. His practice focuses on retirement planning for senior employees in listed companies, government and the universities as well as exit strategies for SME owners. Chris has extensive practical experience in designing and implementing superannuation strategies and regularly advises both Australians and expats on managing their wealth.

Reid Zulpo, ATI, of PwC has more than 17 years advisory and corporate experience as a tax professional. Reid has extensive transaction tax structuring and execution experience (both inbound and outbound) across several sectors, including infrastructure, power & utilities, private equity, financial services, property and managed funds in Australia, the US, Canada, Asia and UK/continental Europe. Reid has recently advised on a number of large corporate M&A transactions in Australia. Reid was also previously the Group Head of Tax for a listed company in Australia, which had substantial operations in the US, UK and Europe.


Registration options

Full forum registration includes: � Attendance at any session of your choice (maximum 12 sessions)

� Electronic access to downloadable forum materials via the event app

� Morning and afternoon refreshments

� Lunch

� Ticket to the networking drinks function on Thursday 18 August

� 13.5 CPD hours.

Employer ticket includes: � MOST POPULAR TICKET! Share one registration between multiple attendees from the same firm. Allocate any 12 sessions and receive electronic access to downloadable materials via the event app

� Multi-user registration (register up to 12 delegates from the same organisation)

� Attendance at any session of your choice (total 12 sessions)

� Electronic access to downloadable technical papers and presentations

� Morning and afternoon refreshments.

Single-day registration includes: � Attendance at any session of your choice (for your selected day)

� Electronic access to downloadable forum materials via the event app

� Morning and afternoon refreshments (for your selected day)

� Lunch (for your selected day)

� Day one – 6.5 CPD hours / day two – 7 CPD hours.

The Tax Institute CPD event appThe Tax Institute understands the impact that an event of this nature has on the environment, especially when printing delegate materials. The event app is easy to use and contains program information, materials (technical papers and slides), evaluation forms and more. We encourage all delegates to download the app on their phone or tablet prior to this event. Once the materials are available, an email will be sent to delegates with access details (approximately five days before the event).

Printed materialsPrinted materials are not included in your registration. A delegate folder with printed materials (technical papers and slides) can be purchased at a cost of $100.

Group discount Purchase four full registrations and receive the fifth FREE. This offer cannot be redeemed in conjunction with any other offer, promotional code or discount. All attendees must be from the same firm and all registration forms must be submitted together.

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

Confirmation of registrationOn receipt of registration and payment, you will receive an email containing your confirmation letter and tax invoice.

CPD AccreditationFull forum attendance counts for 13.5 hours of Structured Continuing Professional Development Accreditation with The Tax Institute. Single-day attendance counts for 6.5 hours on Thursday 18 August and 7 hours on Friday 19 August. Employer ticket attendance will be allocated accordingly to each attendee.

Special dietary requirementsPlease indicate any special dietary requirements on the registration form.

FURTHER INFORMATIONWhat, when and how to



The venue The forum will be held at the Brisbane Marriott Hotel, 515 Queen Street, Brisbane, Queensland 4000.

Getting thereBus services run to the King George Square Bus Terminal, and both Central and Fortitude Valley train stations are within reasonable proximity of the venue. Please contact us if you require a map with further details.

ParkingParking at the Brisbane Marriott Hotel is accessible via Howard Street. A special forum rate of $35 per car, per day is available to delegates – please let the parking attendant know that you are attending The Tax Institute’s Queensland Tax Forum to obtain this rate. Email [email protected] to ensure a space is reserved for you.

Dress code Business attire is suitable for the duration of the forum.

Changing or transferring sessions Attendance at the forum is fully transferable. Replacements can be nominated at any time; however, please email ALL changes to [email protected] to ensure that your data is updated, name tags are accurate and CPD hours are allocated to the correct attendee. If your changes are received more than three working days prior to the commencement of the forum, a revised confirmation letter will be sent.

Note: There may be an additional cost depending on the member status of the registered attendee and the replacement.

mailto:[email protected]



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. If the replacement is not a member, the non-member registration fee will apply. CPD hours will be allocated to the individual attending the session. The Tax Institute cannot accept responsibility for delegates’ late transport arrivals or non-arrivals due to delays.

PrivacyWe take your privacy seriously, and our policy can be viewed at taxinstitute.com.au/go/footer/privacy.

EnquiriesIf you have any enquiries, please contact the Queensland Division on 07 3225 5200 or email [email protected].


Join Australia’s leading professional tax bodyThere is no time like the present to join Australia’s premier tax body. Take advantage of the special new Affiliate member introductory offer of only an additional $300 on the member registration fee (valid to 30 June 2017).

Member benefits include: � Taxation in Australia journal � TaxVine e-newsletter � TaxLine Research Service – free to members � CPD event discounts � Publications and tax product discounts � Association with Australia’s leading professional tax body.

For more information, please visit membership.taxinstitute.com.au/join.

Graduate Diploma of Applied Tax Law

The Graduate Diploma of Applied Tax Law has been designed to meet the changing needs of the tax profession. The program combines advanced technical and practical skills with high-level academic governance. It utilises the experience of working tax practitioners to equip you with the practical skills that can be applied in the workplace. It will enable you to establish a competitive edge in your career and prepare you for the changes of tomorrow.

To find out more about how the Graduate Diploma of Applied Tax Law will benefit you, visit taxinstitute.com.au/GradDip or call 1300 TAX EDU (1300 829 338).



2016 Queensland Tax Forum | 18–19 August 2016 4160801M1/WD

Early bird offer Register on or before Friday 1 July 2016 to SAVE!

Full forum registrationThis registration option includes participation in the full technical program, access to all materials via the event app and all meals and refreshments during forum hours. Registration fees do not include printed materials, travel, accommodation or hotel incidentals.

To assist in lowering the environmental impact of the 2016 Queensland Tax Forum, the standard registration option will ONLY provide electronic access to materials. PowerPoint presentations and technical papers will be available via the event app for all participating delegates to download. Information on how to access these materials will be sent to all registrants by email approximately a week prior to the forum.

For an additional fee of $100, you may opt to receive all available materials in hard-copy format. Please indicate your selection on the registration form.

Note: These tickets are not transferable between delegates on the day. For a transferable ticket please fill out the employer ticket registration form.

Day registrationThis registration option entitles one delegate to attend a full day of technical sessions, refreshments during forum hours and electronic access to all materials via the event app. Select your session choices (for your selected day only) on the registration form.

For an additional fee of $100, you may opt to receive all available materials in hard-copy format at the forum. Please indicate your selection on the registration form.

Registration options (all prices include GST)

Full forum registration – 13.5 CPD hours Early bird Standard

Member $1,550 $1,770New member* $1,850 $2,070Non-member $1,860 $2,125

Material options:

I understand that the registration fees do not include printed materials. Access to materials will be electronic.

Add $100 to receive printed technical papers and presentations

Total registration fee $

Day registration Early bird Standard

Thursday 18 August 6.5 CPD hours Member $745 $925New member* $1,045 $1,225 Non-member $995 $1,230

Friday 19 August 7 CPD hours Member $845 $1,025New member* $1,145 $1,325 Non-member $1,095 $1,315

Material options:



Total registration fee $

*New member price entitles you to affiliate membership ending on 30 June 2017. For more information see page 14.

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:

Personal details

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

First name:

Last name:

Member no: Company:

Postal address:

Suburb:

State: Postcode:

Tel: Fax:

Email:

Dietary requirements:

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

Full forum registration total $

Single-day registration total $

Total payable $

I enclose a cheque* for $

OR

Please charge my credit card $

AMEX Visa MasterCard Diners

Card no. / / /

Expiry date:

Cardholder’s signature:

Cardholder’s name:

*Please make cheque payable to The Tax Institute.

Payment method

INDIVIDUAL REGISTRATION FORMA tax invoice and confirmation letter will be sent on receipt of your registration. Please photocopy a blank form for additional delegates. All prices quoted include GST. ABN 45 009 392 372

| Page 1 of 2

Register

OnlineSave time, register online at taxinstitute.com.au/QTF

Fax07 3225 5222

MailPO Box 7071, Riverside Centre, Brisbane QLD 4000


Day one – Thursday 18 August 2016 – 6.5 CPD hours

PlenaryPresident’s Welcome and Opening Address (8.45am–9.00am)

Session 1: Keynote address – “Tax Reform and Policy for an Economy in Transition” (9.00am–10.00am)

Session 2

2A: Trusts and Trust Losses – Everything You Need to Know (10.30am–12.00pm)

2B: Topical M&A in the Tropics (10.30am–11.30am)

Session 3

3A: Small Business Restructure Rollover (12.00pm–12.30pm)

3B: How to Approach a Transaction – Interacting with the ATO (11.30am–12.30pm)

Session 4 (1.30pm–2.30pm)

4A: Expatriates and International Assignees – A Tax Guide for an Employer’s First Time

4B: Mastering the Indirect Tax Function – From Both Sides


5A: Employee Share Schemes in an Emerging Economy

5B: Managing a Changing Tax and Shared Services Function

Plenary

Session 6: Part IVA – Eight Factors (4.00pm–5.30pm)

Day two – Friday 19 August 2016 – 7 CPD hours

PlenarySession 7: Economic Insight (8.30am–9.30am)

Session 8: Your Career – Maximising Potential in a Changing Environment (9.30am–11.00am)

Session 9 (11.15am–12.45pm)

9A: Division 7A and UPEs – Where Are We At And Where Are We Going?

9B: State Taxes


10A: Business Tax Considerations in a Global Economy

10B: Tax Issues For Distressed Times


11A: Address from the Small Business and Family Enterprise Ombudsman

11B: Changing Times in International Tax


12A: Transitioning to Retirement with an Eye on Super – Five Issues for SME Owners

12B: Tax Transparency is Here to Stay

Session selection

Note: If you have chosen the day registration option, only options for your specific day are valid (ie they cannot be spread across the two days).

INDIVIDUAL REGISTRATION FORM Page 2 of 2


Registration options (all prices include GST)

Early bird ticket $1,895

Standard ticket $2,095

Material options:



Total ticket fee $

Employer ticket co-ordinator details

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

First name:

Last name:

Member no: Company:

Postal address:

Suburb:

State: Postcode:

Tel: Fax:

Email:

Dietary requirements:

Please tick this box if you do not wish your name to be included on the delegate list provided to all delegates

Employer ticket registration total $

Total payable $

I enclose a cheque* for $ OR

Please charge my credit card $

AMEX Visa MasterCard Diners

*Please make cheque payable to The Tax Institute.

Card no. / / /

Expiry date:

Cardholder’s signature:

Cardholder’s name:

Payment method

Membership and education program promotion

I am interested in becoming a member of the 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.

2016 Queensland Tax Forum | 18–19 August 2016 4160801M1/WD

EMPLOYER TICKET REGISTRATION FORMA tax invoice and confirmation letter will be sent on receipt of your registration. Please photocopy a blank form for additional delegates. All prices quoted include GST. ABN 45 009 392 372

| Page 1 of 2

Register on or before Friday 1 July 2016 to SAVE!

Employer ticketThis registration option will allow the sharing of one registration between multiple attendees from the same firm. Allocate 12 sessions and receive electronic access to forum materials. Please note that printed materials and forum lunches are not included in this price. For an additional fee of $100, you may opt to receive all available materials in hard-copy format at the forum. Please indicate your selection on the registration form.

Session selectionPlease complete the form overleaf indicating the sessions that each person is attending. Please note that sessions will be allocated on a first-come, first-served basis, so please make your selections as soon as possible to avoid disappointment. Please ensure the form is correct as CPD hours will be allocated accordingly.

Note: Employer tickets do not include attendance at the networking lunches.

Once you have registeredYou will receive a tax invoice and confirmation letter including details of your session selections. Please check your session details and contact The Tax Institute’s Queensland Division on 07 3225 5200 or email [email protected] if any details are incorrect.

Register

OnlineSave time, register online at taxinstitute.com.au/QTF

Fax07 3225 5222

MailPO Box 7071, Riverside Centre, Brisbane QLD 4000



Session selection

Session number Attendee’s preferred full name (for name badge)

Tax Institute member/non-member number (if known)

Attendee’s email address (required)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

EMPLOYER TICKET REGISTRATION FORM Page 2 of 2

Note: Sessions are subject to availability.

EMBRACE YOUR DIGITAL TAX WORLD

Accessing the conference online

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

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 30 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 2016 Queensland Tax Forum mobile web application, suitable for your web-enabled smartphone or device. Visit the website taxinstitute.com.au for the download link.

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

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.

Scan QR code with your mobile device for more info or to register.

taxinstitute.com.au0157

QLD

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16

Level 11, 167 Eagle Street, Brisbane QLD 4000

Tel: 07 3225 5200 Fax: 07 3225 5222

For information, please contact our Qld division: [email protected]

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