transfer pricing: new reporting requirements seminar are ... · includes preparation of strategy...

Transfer Pricing: New Reporting Requirements SeminarAre you ready?

Thursday, 24 August 2017 Morning Session: 8.30 a.m. – 12.00 p.m.Afternoon Session: 1.30 p.m. – 5.00 p.m.

Deloitte Touche Tohmatsu Tax Services Sdn. Bhd.Meet Point 1 & 2Level 15 Menara LGB1 Jalan Wan KadirTaman Tun Dr Ismail60000 Kuala Lumpur

02

Brochure / report title goes here | Section title goes here

OverviewIn line with BEPS Actions 8-10 and Action 13 recommendations, the Inland Revenue Board (“IRB”) has recently released revisions to the Malaysian Transfer Pricing Guidelines 2012 (“MTPG”). The revisions pertain to the guidance on Arm’s Length Principle and Documentation, while introducing separate new chapters on Intangibles and Commodity Transactions. It is important for taxpayers to identify potential areas of risks or gaps in intragroup pricing policies, actual practices and transfer pricing documentation, and make required changes or build adequate defensible positions for audits. The revision of MTPG reflects the IRB’s continued focus on transfer pricing, the current stance on enforcement, and the likely approach to be adopted in future audits. With greater clarity on the requirements, it is imperative that the IRB would enforce higher degree of compliance as reflected in the expanded scope of penalty conditions.

Through this seminar, we would share with you the implications of these developments, especially on the critical issues/items to be dealt with during audit and how to successfully manage them.

Key highlights• New changes in compliance requirements and contents of transfer

pricing documentation • New guidance on Arm’s Length Principle – risk and capital• Specific guidance in performance of arm’s length analysis of

Intangibles and Commodity Transactions

We would also like to take this opportunity to provide a quick re-cap of the recent change in the Malaysian Withholding Tax regime (i.e., the re-imposition of withholding tax on offshore services and the expansion of the meaning of royalty), and how these could impact your existing transactions.

Transfer Pricing: New Reporting Requirements Seminar | Are you ready?

03

AgendaMorning session

Afternoon session Event

08:30 13:30 Registration

09:00 14:00 Panel discussion with representatives from the Inland Revenue Board:

• Updates to MTPG – background and the IRB’s thought process behind the amendments, including clarifications on key new requirements, penalty elaborations, etc.;

• The IRB’s experience in transfer pricing audits in recent years and level of compliance among taxpayers; and

• Pointers from the IRB to help taxpayers improve the quality of transfer pricing documentation to meet expectations and qualify for penalty protection.

10:30 15:30 Coffee break

11:00 16:00 Update on new three-tier documentation requirement: our implementation experience thus far; key painpoints for Malaysian and foreign-owned groups; international best practices, etc.

11:30 16:30 New withholding tax regime – are you in compliance?

12:00 17:00 End

One-to-one clinic consultationsComplimentary consultations are open to participants to meet with our professionals on any tax-related queries, either immediately after the seminar, or on a separate date.

Since these consultations will be on a first-come-first-served basis, please reserve your slot at the earliest. A reply to your reservation request will be sent to confirm the date/time of the consultation.


04

Guest speakersWan Ramiza Wan GhazaliDirector, Inland Revenue Board of Malaysia

Puan Wan Ramiza Wan Ghazali is a Director of the IRB, in charge of transfer pricing policies. She has a Masters in Business Administration from University of Miami, Coral Gables and a Bachelor of Science in Business Administration from University of Lincoln, Nebraska.

Puan Wan Ramiza has more than 26 years of experience in the IRB and is presently Head of Mutual Agreement Procedure & Transfer Pricing Policy Division in the Department of International Taxation. She was previously the head of Multinational Audit Division in the Multinational Tax Branch. She has represented the IRB in meetings with OECD Working Party 6 on Taxation of Multinational Enterprises and is the resource person for transfer pricing at the Malaysian Tax Academy – OECD and Taxation of International Transaction.

Amir Zainuddin Abdul HamidPrincipal Assistant Director, Inland Revenue Board of Malaysia

Encik Amir Zainuddin Abdul Hamid graduated with Bachelor of Accountancy from University Putra Malaysia and obtained his Masters in Business Administration from University Kebangsaan Malaysia.

He joined the IRB in 2002 and is presently a Principal Assistant Director of the IRB, in charge of transfer pricing policies. He is involved in OECD Working Party 6 on Taxation of Multinational Enterprises and is also one of the resource people for transfer pricing at the Malaysian Tax Academy – OECD and Taxation of International Transaction.


05

Deloitte speakersTheresa GohNational Transfer Pricing Leader

Theresa Goh is the National Transfer Pricing Leader of Deloitte Malaysia and carries more than 30 years’ experience as a tax professional encompassing both tax and transfer pricing matters. She is based in Kuala Lumpur, and her experience covers transfer pricing, tax audits, investigations, tax advisory work, supply chain management and business model optimization projects for clients in a wide range of industries, including manufacturing, services, telecommunications and the oil and gas sectors.

Theresa’s experience in tax and transfer pricing controversy management includes preparation of strategy for litigation involving anti-avoidance issues and application of alternative transfer pricing methods during audits. She is instrumental in shaping Malaysia’s first and only three advance pricing agreements (APAs) to date. Under Theresa’s leadership, Deloitte Malaysia won the Malaysia Transfer Pricing Firm of the Year award in 2016, bestowed by the International Tax Review. Her expertise in transfer pricing has garnered a slew of international recognitions, most recently – International Tax Review 2016 Malaysian Tax Controversy Leader and Transfer Pricing Lawyer of the Year by Lawyer Monthly Legal Awards 2016.

Theresa is a council member of both the Malaysian Institute of Certified Public Accountants (MICPA) and the Chartered Tax Institute of Malaysia (CTIM). She is an approved tax agent under the Malaysian Income Tax Act, 1967.

Tan Hooi BengInternational Tax Leader

Hooi Beng is the International Tax Leader of Deloitte Malaysia. He is based in Kuala Lumpur and has more than 18 years of experience in corporate and international tax. He has vast experience in advising multinational corporations on corporate structuring and restructuring, mergers and acquisitions, international offshore financial centres, business model optimisation, tax treaties and cross-border taxation generally.

Hooi Beng is an associate member of the Chartered Tax Institute of Malaysia, a Chartered Accountant of the Malaysian Institute of Accountants as well as a licensed tax agent under the Malaysian Income Tax Act, 1967. He holds a Bachelor of Accounting from the University of Malaya.

He has advised multinational companies on acquisition structure from tax-efficiency perspective; income tax, stamp duty and real property gain tax issues arising from merger and acquisition exercise; group simplification / group integration exercise from tax perspective post merger and acquisition exercise; and performed tax due diligence on concessionaire company, companies in aviation, trading, manufacturing, oil and gas, Labuan leasing and plantation sectors.


06

Gagan Deep NagpalTransfer Pricing Director

Gagan has three years’ experience in operational transfer pricing and more than seven years’ consulting experience spanning industries and functions, from Consumer Durables, Manufacturing, IT & ITES, to Pharmaceuticals, Automotive and Telecommunications.

Over the years, he has consulted on various transfer pricing matters, by evaluating transfer pricing models and assisting on Advance Pricing Agreement procedures and MAP cases; assisting clients in preparation of transfer pricing policies and operationalising transfer pricing in the set-ups; being involved in high-end litigation on complex transfer pricing issues; providing compliance services to clients and representation on behalf of clients in tax audit proceedings; being involved in many TESCM planning engagements which cover extensive advisory on international tax and transfer pricing matters; and providing FIN 48 view on transfer pricing matters.

Gagan holds a Master of Commerce from University of Shimla, India. He is a member of Institute of Chartered Accountants of India, New Delhi.


07

RegistrationWhen and whereDate: Thursday, 24 August 2017Time: Morning Session: 8.30 a.m. – 12.00 p.m. Afternoon Session: 1.30 p.m. – 5.00 p.m.Venue: Deloitte Touche Tohmatsu Tax Services Sdn. Bhd. Meet Point 1 & 2 Level 15 Menara LGB 1 Jalan Wan Kadir Taman Tun Dr Ismail 60000 Kuala Lumpur

To register / enquire Name: Ng Shu Min Email: [email protected]: +603 7610 8716

Name: Esther TanEmail: [email protected]: +603 7610 8034

Registration• No later than 18 August 2017• Payment is non-refundable• No extra charge for substitute delegates• Payment must be made by the registration closing date

as seats are limited and on a first-come first-served basis• A valid tax invoice will be issued in the name of

participating entities

Registration feesRM350 per delegate (inclusive of 6% GST)

Payment detailsCompany name: Deloitte Tax Services Sdn BhdBank: United Overseas Bank (Malaysia) BerhadSwift code: UOVBMYKLAccount number: 202-301-9827

Crossed cheque or bank draft payable to: Deloitte Tax Services Sdn Bhd

One-to-one clinic consultationsPlease indicate if you would like to reserve a slot in the registration form below. Your request will be confirmed via a separate email.

Disclaimer The organiser reserves the right to cancel and/or make changes to the programme, venue, speaker replacements and/or topics if warranted by circumstances beyond its control.


08

Deloitte Malaysia is a privacy-conscious global organisation. We will treat the information we collect from you as a result of your registration and participation for this event in accordance with our Privacy Policy, which is located at http://www.deloitte.com/my

Participant 1

Name (Mr / Mrs / Ms)

Designation

Email

Mobile phone no.

Special dietary requirement, if any:

Morning session Afternoon session

Participating company details

Company name and business registration number

Address

Phone no.

Fax

Contact person

Email

Participant 2

Name (Mr / Mrs / Ms)

Designation

Email

Mobile phone no.

Special dietary requirement, if any:

Morning session Afternoon session

Registration form

Due to overwhelming response in past briefings, we are offering two seats per company

One-on-one clinic consultationWe would like to reserve a slot for a one-on-one clinic consultation in the following area(s):

Business Tax Transfer Pricing

Global Employer Services GST & Indirect Taxes

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”), its network of member firms, and their related entities. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as “Deloitte Global”) does not provide services to clients. Please see www.deloitte.com/my/about to learn more about our global network of member firms.

Deloitte provides audit, consulting, financial advisory, risk advisory, tax and related services to public and private clients spanning multiple industries. Deloitte serves four out of five Fortune Global 500® companies through a globally connected network of member firms in more than 150 countries and territories bringing world-class capabilities, insights, and high-quality service to address clients’ most complex business challenges. To learn more about how Deloitte’s approximately 245,000 professionals make an impact that matters, please connect with us on Facebook, LinkedIn, or Twitter.

About Deloitte Southeast AsiaDeloitte Southeast Asia Ltd – a member firm of Deloitte Touche Tohmatsu Limited comprising Deloitte practices operating in Brunei, Cambodia,Guam, Indonesia, Lao PDR, Malaysia, Myanmar, Philippines, Singapore, Thailand and Vietnam – was established to deliver measurable value tothe particular demands of increasingly intra-regional and fast growing companies and enterprises.

Comprising 290 partners and over 7,400 professionals in 25 office locations, the subsidiaries and affiliates of Deloitte Southeast Asia Ltd combine their technical expertise and deep industry knowledge to deliver consistent high quality services to companies in the region.

All services are provided through the individual country practices, their subsidiaries and affiliates which are separate and independent legalentities.

About Deloitte in MalaysiaIn Malaysia, services are provided by Deloitte Tax Services Sdn Bhd and its affiliates. © 2017 Deloitte Tax Services Sdn Bhd

transfer pricing: new reporting requirements seminar are ... · includes preparation of strategy...

Documents