Transcript South-East Asia Focus: Dealing with developing tax systems
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
South East Asia Panel
Country developments www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Indonesian Scenario
Permana Adi Saputra
Taxand Indonesia
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Tax Challenges in an Age of Scrutiny
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Tax Challenges in an Age of Scrutiny
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Tax Avoidance, Tax Audit, and Tax Incentives
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
How Tax Avoidance is Tackled Transfer pricing Regulation regarding the application of ALP (Per 43/PJ/2010 as amended by Per 32/PJ/2011) Exchange of Information Thin capitalization Indonesian Tax Office has an authority to re determine debt as capital Treaty shopping Indonesia has signed 61 tax treaties, including the new tax treaty with Hong Kong that will be effective in Indonesia on 1 January 2013 DGT issued a DGT-form to provide certainty in applying the tax treaty (Per 61/PJ/2009 and amended with Per 24/PJ/2010) Controlled Foreign Company Determination of dividend of an Indonesian tax payer in relation to its shareholding in a foreign company. (Article 18 par. 2 Income Tax law No. 36/2008 and Minister of Finance Regulation No. 256/PMK.03/2008)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Challenges and Issues in Audit Process Tax audit is focused on certain industries: Mining, palm oil, mass media, chemical, automotive, construction, wholesaler, bank and insurance, real estate, consultancy, processing industry Individual tax payers are also the focus of tax audit: Tax consultant, lawyer, notary, and tax payer who has relation with a company which is being or has been audited Tax audit can be made in the last 5 years, however the tax payer must keep documentation for 10 years Duration of audit process Normal audit is 8 months, transfer pricing is 24 months, and gathering / examination of preliminary evidence for a tax criminal case has practically no time limit Verification is the new audit procedure in Indonesia Tax revenue target for 2012 is IDR13.30 trillion (US$1.46 billion)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Tax Incentives to Encourage Investment Tax facility for certain industries in certain locations Accelerated depreciation Loss compensation of not more than 10 years 10% dividend tax rate Reduction in net income by 30% of the investment value Tax holiday for new capital investment in pioneering industrial sectors Industries: base metal, oil refinery and base organic chemical, machinery, renewable energy, telecommunication equipment Corporate income tax holiday for 5 to 10 years after the start of commercial production; 50% income tax reduction for two years after the end of the tax holiday period; a maximum dividend tax rate of 10% If the taxpayer already has a tax facility, the tax payer can not propose to get tax holiday
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
9
Indonesia’s New Transfer Pricing Regime
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Authority in Making Adjustments Article 18(3) of Income Tax Law No. 36/2008 regarding related-party transactions states as follows: The Director General of Taxes shall be
authorized
to
re-determine the amount of income and deduction as well as determine debts as capital
to calculate the amount of taxable income for Taxpayer possessing
special relationship
with another Taxpayer
, in accordance with the Arm’s Length Principle
by using the Comparable Uncontrolled Price method, Resale Price Method, Cost Plus Method or other methods
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Definition of Related Party Based on Article 18 (4) part a, b, c of Income Tax Law No. 36/2008, special relationship between tax payers exists under the following circumstances: Taxpayer has capital participation directly or indirectly, a minimum of 25% (twenty five percent) at another Taxpayer (one or more Taxpayers); or Taxpayer controls another Taxpayer or two or more Taxpayers are under the common control directly or indirectly; or There is family relation both biologically and by marriage in vertical and / or horizontal lineage of the first degree
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Related Party Transactions The types of related party transaction to be disclosed in the Corporate Income Tax Return consist of: Transactions involving Tangible Properties Transactions involving Capital Goods Transfer / Utilization of Intangible Properties Loans Transfer of Services Transfer / Acquisition of Financial Instruments Cost Allocation Others
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Related Party Transactions Transfer Pricing Documentation is required for the following: Transactions between a tax payer or Permanent Establishment in Indonesia, and a taxpayer outside Indonesia Transactions between two tax payers or Permanent Establishment in Indonesia that are subject to different tax rates due to, among others: Imposition of final and non final income tax in certain business sector Imposition of sales tax on luxury goods Transactions conducted with a taxpayer-contractor under an Oil & Gas Cooperation Contract
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Safe Harbor Transfer Pricing Documentation is not required for related party transactions with total value not exceeding IDR10 billion (approximately US$1.1 million) in one fiscal year for each counterparty Note: Transactions below the threshold limit Must still be disclosed in the Corporate Income Tax Return Must still comply with the arm’s length principle May still be the subject of a tax audit
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Selection of Transfer Pricing Methods The hierarchical application of Transfer Pricing methods has been replaced with the
‘most appropriate method’
approach Transactional Net Margin Method (TNMM) is no longer the last-resort method and can be appropriately applied if one of the transaction parties performs either special contribution or complex / closely linked transactions
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Intangible Assets Intangibles are assets which generally have long useful life, have no physical form, are used in business operation, and are not for resale Intangible assets can be classified as: Trade Intangibles (e.g. patent, know-how) Marketing Intangibles (e.g. trademark, trade name)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Obligation to Submit TP Documentation Submission of Transfer Pricing Documentation along with the Corporate Income Tax Return (four months after fiscal year-end with two months extension) is required No specific penalty shall apply in case of failure to comply with the above
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Transfer Pricing Penalties No specific Transfer Pricing penalties The following penalties apply in case of non-payment of tax or tax underpayment arising from Transfer Pricing adjustments Administrative sanction in the form of interest at 2% per month for a maximum of 24 months on the amount of tax underpayment in the Tax Assessment Letter (SKPKB)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Mutual Agreement Procedure (MAP) The Indonesian Tax Authority issued in 2010 the regulation regarding procedure in applying for a MAP MAP application can be processed simultaneously with the filing of objection or appeal
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Advance Pricing Agreement (APA) The Indonesian Tax Authority issued in 2010 the regulation regarding procedure in applying for an APA Important provisions in the APA regulation: Validity Period is three (3) years Submit of annual compliance report is required Tax payer’s documents and information during the APA process shall remain private and confidential
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Thank you
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Philippines Scenario
Euney Marie J. Mata-Perez
Taxand Philippines
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
How Tax Avoidance is Tackled
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Overview Exchange of Information Regulations No consolidated rules on anti-tax avoidance Source of rules: Legislation Regulations issued by the Commissioner of Internal Revenue Court decisions Revenue driven
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Access of Taxpayers Information Exchange of Information Regulations RA 10021: exchange of Information Act of 2009 Prior to RA 10021: authority of the CIR to inquire into taxpayer’s bank deposits is limited to two grounds: (1) determining estate of a decedent, and (2) when taxpayer files an application for compromise. (Exceptions to Bank Secrecy Act) New ground: a taxpayer subject of request for supply of tax information from a foreign tax authority pursuant to an international convention or agreement
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Prior Tax Treaty Relief Application New Tax Treaty Relief Procedures Filing of Tax Treaty Relief Applications (TTRA) is mandatory before a transaction Before the occurrence of the first taxable event Failure of observe the period shall have the effect of disqualifying the TTRA But the BIR does necessarily act on the application, so doubt on interpretation remains
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Additional Disclosure Requirements - FS New Additional FS Disclosures Disclosure on information on taxes, duties and license fees paid or accrued during the year in the audited financial statements (2010) Some implications: Entail additional administrative burden Premature or untimely disclosure of assessments and pending cases
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Additional Disclosure Requirements - ITR Supplemental Information Return Additional attachment to ITRs of individuals Additional disclosures to the ITRS: Requiring information on passive and tax exempt income Includes final taxes withheld on each type of income Basis for exemptions clearly indicated Difficult to comply and implement
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Promulgation of Allocation Rules Allocation of costs and expenses amongst income earnings of banks and financial institutions Rules on the allocation of costs and expenses among the income earnings of banks and financial institutions Prescribed methods: Specific identification Allocation based on gross income earnings
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Review/Reversal of Previous Interpretations Upstream mergers Refusal to issue rulings that these are exempt Further control in a tax exempt transfer to gain control no longer tax exempt VAT on tax-free transfers
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Taxpayer Monitoring Requiring withholding agents to apply for TIN on behalf of non-resident aliens not engaged in trade or business in the Philippines Benchmarking Matching Improvement of data capturing Machine readable returns Additional disclosures
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Challenges/Issues in Audit Procedures
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Audit Challenges Over-riding Persistent call for the Commissioner of Internal Revenue to meet increasing targets New Interpretations on Prescription Technicalities on VAT refunds (Aichi case) Failure to indicate details of the transaction in the required return is tantamount to a non-filing of return (10 years)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Audit Challenges Authority to receive assessment notices No case or regulations address the issue on the authority of a corporation’s employee to receive assessment notices for purposes of due process Stricter rules on evidence Due process Assessment of tax-exempt entities who are making profits
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentives to Encourage Investments
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentive Laws No new laws Existing laws RA 7916, Special Economic Zone Act of 1995 (PEZA) EO 226, Omnibus Investments Code (BOI) RA 7227, Bases Conversion & Dev. Act (BCDA) Tourism Act 180 other laws
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
General Incentives Income tax holiday 5% tax on gross income, in lieu of other taxes Exemption from duties and taxes on importation of capital equipment and raw materials Exemption from local taxes except real property tax Net operating loss carry-over
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Others Inclusion in the Investments Priorities Plan Amendment to the Negative List Relaxation of nationality restriction Generally, foreign ownership in all forms of gambling is limited to 40% 2011 list added an exception: except those covered by investment agreements with PAGCOR operating in ecozones administered by PEZA
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Recent Developments Harmonization of Incentives House Bill 4935 Creation of an Investment Promotion Action Center at the Board of Investments Various Senate Bills – for harmonization DOF Version Limited scope and period of incentives Proposed reduction of VAT from 12% to 10%
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Thank you
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Thailand Scenario
Chinapat Visuttipat
Taxand Thailand
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
How Tax Avoidance is Tackled
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Overview No specific rules on anti-tax avoidance Source of rules: Tax Legislations Civil and Commercial Code Court Decisions Tax competition in the region
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Integrating System Among Three Tax Authorities Integration with E-filing The Revenue Department The Customs Department The Excise Department Bank transactions and records Reconciliation via online data of tax filings
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Transactions in Focus of Tax Authorities Cross-border transactions among related parties Complicate and unexplainable transactions Import of goods with separation of license Royalties transactions Management and consulting services Cost allocation and reimbursable expenses
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Anti-avoidance Tools Under Consideration Transfer pricing Thin capitalization Treaty shopping Controlled foreign company General anti avoidance rules
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Challenges and Issues in Audit Procedures
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Challenges in Audit Process Time / cost and opportunity to play in the game of tax audit When taxpayers are the winner in game Nike ’s case (customs issues on license fee) Halliburton ’s case (taxpoint on profit remittance) What if they lost the game Pizza Hut ABB SGS ’s case (royalties taxed on marketing) ’s case (withholding tax on subsidy fund) ’s case (VAT 0% on export of service)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Issues in Audit Process Tax refund or not refund Personnel in audit process: Put the right man on the right job Share premium is not a safe-habor Oxychem’s case (tax on deemed subsidy) NEC’s case (tax on deemed subsidy)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentives to Encourage Investments
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentive Laws and Tax Privileges Investment Promotion (BOI): Tax and non-tax 3/5/8 years tax holiday Land ownership Foreign business restriction Work permit and visa for expat Revenue Code ROH / IPC Entire business transfer / Amalgamation
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Recent Developments Corporate tax rate reduction from 30% To 23% in 2012 To 20% in 2013 and 2014 Personal tax rate reduction from progressive tax rate 10-37% to 10-35% will be enacted in 2012 AEC full entry in 2015 Free flow of capital and labor
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Thank you
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
In-house perspective
Morrie Cheng
Sun Life Financial, Asia-Pacific Head of Tax
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Taxpayer’s perspective
• Protectionism: • Triggered by economic circumstances • Tax audits and assessments • Emphasis on indirect tax • Pendulum over swung?: e.g. indirect transfers of domestic shares • Work in progress: • Equilibrium: taxation and foreign direct investment • Sustainability: forecasting, budgeting, measurement … • Reasonableness: at least the opportunity to conclude or disagree • Consistency and coordination among governmental functions?
• Surely, happy to dialogue!
Morrie Cheng 2012
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Internal outsourcing/offshoring
• Business transformation: • Process improvement • Technology • Outsourcing/offshoring: external vs. internal (e.g. shared services centres) • Considerations on internal outsourcing/offshoring including: • Strategy • Costs including tax!
• Resources: e.g. infrastructure, talents • Sustainability • Benefits Morrie Cheng 2012
Tax considerations
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
• First and foremost, early involvement of tax department!
• Special regimes or special zones • Business models: structuring, supply chain and functional analysis • Transfer prices • Taxation: personal taxation included?
• Tax modeling: investment, expansion/reinvestment, exit, etc.
• Treasury: thin capitalization, forex restrictions, etc.
• Indirect tax: VAT, GST, service tax and customs, etc.
• Withholding tax: dividends, royalties, service fees, etc.
Morrie Cheng 2012
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Common topics
• Start up costs • Profit repatriation: formalities, withholding tax • Software and hardware: customs and withholding tax • Indirect tax: input, local consumption vs. export • Transfer pricing “management”?
• Tax accounting and managerial performance: tax contingencies … • Permanent establishments?
• “Sustainability of taxation” • Staff mobility: mobile employees, assignees, etc.
• Structure maintenance and exit • India, the Philippines, China or elsewhere?
Morrie Cheng 2012
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore Doing Business in the Philippines: Business Process Outsourcing (BPO) Euney Marie Mata-Perez
Taxand Philippines
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Business Process Outsourcing (BPO) BPO Background Data transcription Engineering design Information and communications technology (ICT)
BPO includes
Software development; animation ICT support services Contact centers Business/ knowledge process outsourcing
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background Governing Law Foreign Investments Act of 1991 General policy No foreign equity restriction for export enterprises Allows 100% foreign ownership in domestic market enterprise (except those included in negative list) BPO/IT business can be 100% foreign-owned as an export enterprise
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background Foreign Investments Act of 1991 General Policy: BPO/IT business can be 100% foreign-owned as an export enterprise Common forms of business presence Branch Subsidiary
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background Volume 2011: US$11 Billion in revenues in Philippines 638,000 or 22% more employees in the same period 24% higher in 2010; 21% growth in 2011 By the end of 2011 416,000 employees US$7.4 billion in services to the world Largest contact center hub in the world Remained largest sector of Philippines IT-BPO at 65% of total industry
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background By 2016 (according to BPAP): Philippine IT-BPO could more than double to US$25 billion Equivalent to 10% share of global market Growth Potential To meet goal, industry must: Accelerate its talent development initiatives Obtain stronger government support If achieved, IT-BPO industry could employ up to 1.3 million Filipinos and account of 9% of GDP
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background Competitive Advantages Global leader in voice BPO (over 340,000 employees) No. 2 destination for non-voice IT-BPO services (over 200,000 employees) Low infrastructure and labor costs (up to 80% less than in developed countries) Large pool of college graduates each year (over 400,000 graduates) Good English-speaking skills (over 70% of college graduates speak English)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background Competitive Advantages Young and fresh talent pool Large developed Central Business Districts suitable for BPOs (2 million square kilometers leased to BPOs) Customer-centric, warm, and hospitable culture (positive customer feedback) Strong government and academe support (training and curriculum support) Various investment incentives
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentives Source of Incentives Omnibus Investments Code (EO 226) Special Economic Zone Act of 1995 (PEZA Law) Bases Conversion and Development Act of 1992 (BCDA Law)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentives BOI Incentives 2011 Investment Priorities Plan includes BPO activities, information technology (IT), and IT-enabled services IPP: minimum investment cost of USD2,500 per seat, for contact center project Covers cost of equipment, fixtures and fixed assets, except land ICT Projects with project cost of USD5 million in the initial year qualifies for pioneer status
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Current Issues PEZA BPO using e-commerce may be registered with PEZA for enjoyment of incentives under the PEZA law Must be located in an ECOZONE (including buildings) At present, majority of the firms in the ICT industry are PEZA-registered As of March 2012, there are 159 PEZA-registered IT Parks/Centers
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Current Issues PEZA incentive of 5% on gross income BIR has issued a ruling that royalties are not deductible from gross income Allowable deductions: Direct salaries; production supervision salaries; raw materials used in manufacture; goods in process; finished goods; supplies and fuels used in production; depreciation of machinery and equipment; rent and utility charges; financing charges associated with fixed assets
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Current Issues Transfer pricing BIR not yet so strict on transfer pricing Proposed transfer pricing regulations not yet issued, although the BIR adheres to OECD transfer pricing guidelines in principle Local Governments Since 5% tax on gross income is in lieu of all other taxes, local governments are reluctant to endorse new PEZA buildings
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Thank you
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
South East Asia Panel
Presenter Profiles www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Presenter Profile Euney Marie J. Mata-Perez
Taxand Philippines
E.
T.
[email protected] (632) 811-2498 ‘Euney’ Marie Mata-Perez is based in Taxand Philippines where she is a Partner of Salvador & Associates. “Euney” has more than 19 years’ experience in tax practice and commercial transactions. Euney specialises in tax and corporate matters, and has extensive experience in mergers and acquisitions, infrastructure projects, project finance and loan transactions, tax advisory work and advocacy work involving refunds and assessments. She was previously a Senior Associate in SyCip, Salazar, Hernandez & Gatmaitan, where she worked for more than 10 years. Euney graduated Salutatorian of her class from the Ateneo de Manila University College of Law (1992), and
summa cum laude
in her undergraduate course from the University of San Carlos, Cebu City. Euney is a Certified Public Accountant, and worked as an auditor with SGV & Co. She has contributed to several foreign and local publications, including CCH Doing Business in Asia, and is a lecturer at the TAXAND Regional Junior School. At present, she is the Executive Vice President of the Tax Management Association of the Philippines.
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Morrie Cheng Asia-Pacific Head of Tax
Sun Life Financial
Presenter Profile E.
T.
+852 2918 3839 Morrie Cheng is Head of Tax, Asia of Sun Life Financial. He has responsibility for Sun Life's tax function in Asia. Mr. Cheng joined Sun Life in 2008. Mr. Cheng has a wide range of international tax and insurance tax experience including Associate Asia Tax Director at Swiss Re and Regional Head of Tax at Henkel. Mr. Cheng holds a Bachelor of Arts in Accountancy from City University of Hong Kong and is a qualified chartered accountant.
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Permana Adi Saputra
Taxand Indonesia
Presenter Profile E.
T.
[email protected] +62 21 835 6363 Permana Adi Saputra is based in Taxand Indonesia where he serves as a Transfer Pricing Partner with PB Taxand. Permana’s experience includes assisting clients with the preparation of transfer pricing documentation, representing clients in tax audit, tax objection and appeals related to transfer pricing cases, and assisting clients in applying for Advance Pricing Agreements. His expertise also includes supply chain management and price / profit structuring. Permana actively participates in discussions with Tax Officers regarding transfer pricing issues. Permana is also very active in conducting in house Transfer Pricing seminars and workshops in for businesses as well as taking part in the local and international Transfer Pricing Summit. Permana started his career in 1992 as a government auditor and worked for more than 6 years with the Ministry of Finance - Republic of Indonesia. Permana then worked for Deloitte before joining PB Taxand to establish the Transfer Pricing Division.
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Chinapat Visuttipat
Taxand Thailand
Presenter Profile E.
T.
+66 (0) 2 632 1800 Chinapat Visuttipat is based in Taxand Thailand where he is a Partner / Director and the head of Tax Services at HNP Counsellors Ltd – Taxand Thailand. Chinapat has more than 20 years of experience in tax and legal advising multinationals on corporate and commercial contracts, cross-border transactions, hotel and property, M&A and transactional tax, private equity fund, tax audit supports as well as tax litigation including tax planning for inbound and outbound investment. He is now a visiting lecturer for the master degrees tax program at both state and private universities in Thailand and has presenting at several public tax seminars and conferences. Chinapat has contributed to many international and local publications on tax, including International Tax Review and Bloomberg BusinessWeek Thailand. At present, Chinapat is a member of Tax Committee under the Thai Chamber of Commerce and Board of Trade of Thailand including Tax Mediator under the Central Tax Court.
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore ABOUT TAXAND
Taxand provides high quality, integrated tax advice worldwide. Our tax professionals, nearly 400 tax partners and over 2,000 tax advisors in nearly 50 countries - grasp both the fine points of tax and the broader strategic implications, helping you mitigate risk, manage your tax burden and drive the performance of your business.
We're passionate about tax. We collaborate and share knowledge, capitalising on our collective expertise to provide you with high quality, tailored advice that helps relieve the pressures associated with making complex tax decisions.
We're also independent —ensuring that you adhere both to best practice and to tax law and that we remain free from time consuming audit-based conflict checks. This enables us to deliver practical advice, responsively.
Taxand is a global organisation of tax advisory firms. Each firm in each country is a separate and independent legal entity responsible for delivering client services.
© Copyright Taxand Economic Interest Grouping 2011 Registered office: 1B Heienhaff, L-1736 Senningerberg – RCS Luxembourg C68