China Tax Update Seminar

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Session Two

Session Three

Session Four

The Taxation Institute of Hong Kong and CPA Australia are pleased to invite you to our joint seminar on China tax update. During the seminar, leading tax professionals from the Big 4s will give you an update of the latest tax and regulatory developments in the PRC, discuss some regulations and tax cases to be noted, and provide insight on planning opportunities.

Topics

Recent cases on taxation of non-residents and audit trends Speaker:

Saturday 7 January 2012 (9:30am - 1:30pm)

Good transfer pricing documentation from a China tax authorities' perspective

Tax e�cient restructuring strategies for intra-group restructuring and business acquisitions

China Individual Income Tax implications and social security contribution requirements on non-resident employees

Since the announcement of the State Administration of Taxation (SAT) of China on a series of tax rules and regulations to tighten up the tax administration of non-resident companies (NRC) since 2008, the total tax revenue from NRC has increased from about 0.8% of all tax revenue in 2009 to 1% of all tax revenue for the half-year ended 30 June, 2011.

With the establishment of Non-resident Taxation Department, more national and local tax enquiries, inspections and audits are coming. Companies outside of China which have cross-border transactions with China should pay special attention to the requirements and take note of reported tax cases to ensure they have implemented suitable tax risk management procedures.

This session aims to provide you with a good understanding of the recent development of transfer pricing in China. In 2009, China’s State Administration of Taxation formally issued a circular entitled Guo Shui Fa (2009) No. 2, which contains the ‘Implementation Measures of Special Tax Adjustments (Trial)’ with transfer pricing documentation requirements. At the end of this session, you will be able to gain basic knowledge on the requirement and content of transfer pricing documentation from a China tax authorities’ perspective.

This session will introduce the implications of the newly amended Individual Income Tax Law and Social Security Law to expatriates working in China, from both the regulatory and implementation perspectives.

In light of the increased global mobility of multinational companies, we will also explore China tax issues related to cross-border arrangements and possible Permanent Establishment (PE) issues, and discuss China tax implications on the PE and tax planning ideas.

Furthermore, this session will provide some practical recommendations for HR and �nance personnel in dealing with expatriates’ immigration and fund remittance procedures.

Organisers:

Caesar Wong, Tax Partner, Deloitte

Speaker: Rhett Liu, Partner, Transfer Pricing Services, PwC

Speaker: Angie Ho, Tax Partner, KPMG

Speaker: Jane Hui, Partner, Transaction Tax, Ernst & Young

With rapid changes in the global economy, corporations need to look for ways to sustain themselves in a volatile environment and grasp every opportunity for growth. Mergers & acquisitions have therefore become a popular measure for both the strong and the weak. In view of this trend, Chinese tax authorities issued a series of regulations on corporate restructuring covering income tax and turnover tax matters during restructuring/acquisition. This seminar will highlight the key features of these new regulations and the speaker’s experience in dealing with tax matters within a transaction life-cycle.

Venue: The Hong Kong Federation of Youth Groups Building

China Tax Update Seminar

Caesar Wong Tax Partner, Deloitte

Rhett LiuPartner, Transfer Pricing Services, PwC

Jane HuiPartner, Transaction Tax, Ernst & Young

Angie HoTax partner, KPMG

About the speakers

Saturday 7 January 2012 (9:30am - 1:30pm)

Caesar Wong is a Tax Partner with Deloitte. He has more than 19 years of experience in providing China and cross-border tax and business services, and is now based in southern China. Caesar has served multinational and domestic corporations in a wide range of industries with investments in various cities across China and overseas. He has advised corporations on entrance strategies, cross-border investment structures, due diligence studies, business integration and restructuring, company formation and registration, pro�t repatriation schemes, indirect tax planning, transfer pricing strategies, tax audit solutions and tax ruling applications. Caesar has successfully helped a major multinational hi-tech group secure the �rst Advance Pricing Agreement (APA) in Shanghai in early 2001, which was also the �rst APA in China applicable to service income.

Rhett Liu is a partner of Transfer Pricing Services at PwC. He has been actively involved in assisting clients in defending transfer pricing audit and tax investigation cases, reviewing and evaluating transfer pricing risks, rationalising transfer pricing policies, formulating cost recharging policies and applying for Advance Pricing Agreements (APAs) in China. Rhett has facilitated the �rst few APAs concluded in China. Rhett periodically contributes to professional publications on the development and major issues of the China transfer pricing environment. He also speaks regularly on the subject for professional seminars and conferences in Hong Kong and southern China.

Angie Ho is Tax partner at KPMG. She has over thirteen years of experience in providing tax services to multinational corporations in Hong Kong and China. She specializes in advising on assignment related matters, including tax compliance and cross-border taxation, expatriate tax planning, equity compensation planning, remuneration design, tax audit defense, social security, Forex and others. Angie is a regular speaker for public seminars. Prior to joining KPMG, Angie worked for an international accounting �rm and the Inland Revenue Department.

Organisers:

Jane Hui is a partner at Transaction Tax of Ernst & Young. She has substantial experience in tax issues associated with transaction targets with PRC operations in various industries including manufacturing, insurance, banking, advertising, real estate investments, pharmaceutical, mining, steel, chemical and infrastructure. She is therefore familiar with the transaction environment in the PRC and the issues associated with doing deals in China. Jane also has extensive experience in PRC tax, and has become a full-time transaction tax partner since 2005. Jane is also the China tax technical leader, leading a team that provides technical support to tax professionals and being involved in assisting government authorities with tax policy formulation.

Venue: The Hong Kong Federation of Youth Groups Building

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CPA Austalia Ltd T: 2891 3312 hk@cpaaustralia.com.au 20/F Tai Yau Building, 181 Johnston Road, Wanchai

China Tax Update SeminarSaturday 7 January 2012 (9:30am - 1:30pm)

Fee: HK$600 for CPAA and TIHK membersHK$750 for CPD Alliance & non-members

Time: 9:00am to 9:30am (Registration)9:30am to 1:30pm (Seminar)* with a 30 minutes break in between