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Executive Education
Clariden Leadership Institute
Tax Efficient Transfer Pricing and Intra-group Financing (US)
Matthew Andrew
Ernst & Young

This program has been independently accredited and certified by CPD
Matthew Andrew, Ernst & Young

 

  • Co-author of “Thought Leaderships on Selected Aspects of Singapore Taxation – A Taxation Book By the Tax Community for the Tax Community” (Edition 1 & 2), and various other publications in BNA Bloomberg and IBFD
  • Registered Tax Professional with the Inland Revenue Service (PTIN), Barrister and Solicitor of the NZ High Court and recipient of World Class New Zealand Network Award
  • Adjunct Professor at Singapore Management University (School of Accountancy) and Malaysia Institute of Supply Chain Innovation (School of Supply Chain) from 2014 to 2015

 

Matthew Andrew is Partner in America National Operating Model Effectiveness (OME) Practice at Ernst & Young Chicago. With 18 years working as Partner in various tax functions at Ernst & Young and PwC around the globe, Matthew is a tax expert in the United States, Singapore, Australia and New Zealand. He has worked with many Fortune 500 companies on international tax and transfer pricing matters in relation to the Asia Pacific.

 

Outside of his consultancy and advisory role, Matt taught at Singapore Management University (School of Accountancy) and Malaysia Institute of Supply Chain Innovation (School of Supply Chain) from 2014 to 2015 as Adjunct Professor. He is also the co-author of Thought Leaderships on Selected Aspects of Singapore Taxation – A Taxation Book By the Tax Community for the Tax Community – Edition one and two, along with multiple publications with reputable tax publications such as BNA Bloomberg and IBFD.

 

Matt is a member of the Singapore Institute of Taxations Professionals, registered Tax Professional with the Inland Revenue Service (PTIN), and Barrister and Solicitor of the New Zealand High Court. He was the recipient of World Class New Zealand Network Award, which recognizes inspirational and outstanding New Zealanders, in 2015.

 

Testimonials

“Matt has helped us implement a centralized Principal model in Singapore. He assisted us in designing a structure that integrated international tax, transfer pricing, indirect tax and supply chain concepts. We appreciated Matt’s deep knowledge of local issues, but at the same time providing guidance that was practical to implement.” - US MNC – FMCG Industry

 

“We work with many advisors that provide great advice in their specialist area. It’s rare to find an advisor that can take a broad perspective across technical areas and combine this knowledge to establish a practical business friendly solution.” - US MNC – Chemical Industry

 

“We have asked Matt to become a member of our business advisory board. This is because Matt provides practical advice on technical issues – something that our business and commercial leaders really appreciate.” - New Zealand MNC – FMCG industry

Other Faculty Speakers

Christine Schwarzl
Advanced Diploma in Tax (International Tax and Transfer Pricing)
Accredited by Chartered Institute of Tax (UK)
  • Former Director at Ernst & Young Singapore and PricewaterhouseCoopers Singapore
  • Over 25 years of global experience in tax consulting and business strategy, providing Asia Pacific transfer pricing advice for MNCs in Australia, New Zealand, China and Korea
  • Qualification includes Advanced Tax Program, Singapore Tax Academy; Advanced Diploma in Tax, Chartered Institute of Tax, UK; PMP Project Management certification, Singapore

 

Christine Schwarzl comes with over 25 years of experience in tax consulting, building and transforming business. Christine has provided transfer pricing advice and valuation support for MNCs across the Asia-Pacific region. As an experienced business and tax professional, her tax consulting service spans from developing efficient business models and associated transfer pricing planning models, transfer pricing documentation and inter-company agreement development, to Permanent Establishment and Residency advisory, and preparation for client tax incentive requests in ASEAN countries.

 

Part of her career was spent working at senior positions in areas of transfer pricing and international tax at Ernst & Young Singapore and PricewaterhouseCoopers Singapore. She completed Advanced Diploma Tax Studies at Charted Institute of Tax, UK, and Advanced Tax Program at Singapore Tax Academy. Christine is also a qualified PMP project manager, with a high level of experience in project management.

This course has been independently certified as conforming to universally accepted CPD guidelines. On average, this executive program contributes 16 hours towards your CPD.

Program Summary

 

Since Apple's unprecedented $14 billion EU tax penalty, tax authorities worldwide are now scrutinizing international companies' tax practice to examine their structure and compliance. In fact, EU Commissioner has warned that this is only the beginning for international firms. To help you achieve full tax compliance and efficiency in your tax planning, Clariden is pleased to invite you to our 2-day Tax Efficient Transfer Pricing and Intra-Group Financing program.

 

Led by EY’s International Tax Partner, Matthew Andrew, and a qualified tax consultant with more than 25 years of experience, Christine Schwarzl, this comprehensive program designed for tax leaders will show you how to align your intra-group financing and transfer pricing strategy to ensure your organization's tax structure is compliant and at the same time, tax efficient. The trainers will walk you through the considerations and issues of transfer pricing, as well as authorities’ perspective on the issue. Coupled with financing structures, you will also explore the implications of BEPS surrounding hybrid entity mismatches and how financing models need to adapt to comply with BEPS guidelines.

 

In addition, Matthew and Christine will provide you with insights into the economic, trade, and investment landscape of the region, along with the latest developments of BEPS, to help you ensure tax compliance and minimize/ avoid tax disputes.

 

Through case studies and interactive discussion, they will challenge you intellectually and stretch your thoughts constructively throughout the program. They will guide you to make sense of current transfer pricing principles and better control transfer pricing practice, so you can guard your profit against unnecessary loss.

 



Programs, dates and locations are subject to change. In accordance with Clariden Global policy, we do not discriminate against any person on the basis of race, color, sex, religion, age, national or disability in admission to our programs.

Introduction

 

With transfer pricing scandals hanging over corporate giants like Apple and Facebook in 2016, transfer pricing continues to be a hot issue for multi-national corporations. As penalties for found cases of transfer pricing extend to not only financial terms, but also in terms of reputation damage and extra scrutiny from tax authorities, businesses have to take extra measures to help themselves navigate through the complex sea of international tax legislations and guidelines.

 

Understanding your need for better transfer pricing insights, this comprehensive 2-day program will help tax professionals improve their intra-group financing practices and protect their organizations’ bottom line. With the help of EY’s international tax expert, Matthew Andrew, and a qualified tax consultant with more than 25 years of experience, Christine Schwarzl, this program will help you discover how to develop intra-group financing strategies to achieve tax effectiveness with different business models.

 

Designed for tax leaders, this comprehensive program will show you how to align your intra-group financing plan with your organization’s value chain framework. Matthew and Christine will walk you through the considerations for transfer pricing. You will also have the chance to look at transfer pricing from tax authorities’ perspective and learn how different financing instruments affect your intragroup financing strategy. In addition, the trainers will provide you with insights on the economic, trade, and investment landscape of the region, along with the latest developments of BEPS, to help you ensure tax compliance and minimize / avoid tax disputes.

 

Through case studies and interactive discussion, Matthew and Christine will challenge you intellectually and stretch your thoughts constructively throughout the program. By the end of the course, you will be able to make sense of current transfer pricing principles and better control transfer pricing practice, so you can guard your profit against unnecessary loss.

 

What You Can Expect

 

  • Stay on top of current trade and investment trends in the region
  • Save cost during intra-group financing with value chain analysis
  • Explore measures to achieve tax-effectiveness within a value chain framework
  • Discover transfer pricing considerations to build better transfer pricing strategies
  • Understand transfer pricing issues with different core financing structures 
  • Learn to apply BEPS guidelines to financing models and ensure tax compliance
  • Apply key concepts on value chain, financing structures, with BEPS guidelines to develop sustainable transfer pricing and financing models for your organization

Who Will Benefit Most

 

This program is designed for but not limited to tax specialists, finance and accounting professionals, trade and customs professionals, supply chain and logistics experts who are seeking to learn or increase their experience with international tax, indirect tax and transfer pricing concepts, as well as MD / GM / CEO and Head of businesses who are considering restructuring their businesses.

Program Outline

 

DAY 1 (09:00 - 17:00)

 

Session 1: Economic, Trade and Investment Context

  • Macroeconomic and microeconomic context for investment into the region
  • FDI and portfolio capital inflows to the region and within the region
  • Economic development strategies and tax incentives in APAC, and the interaction with FDI
  • Trade patterns within the region and key drivers of these
  • A review of the trends and the evolution of trade and FDI flows
  • Core trade theory concepts
  • Key industry sectors and trends 

 

Session 2: Value Chain and Business Model Concepts

  • Definition of the value and supply chain concepts
  • Review of what these mean for MNCs
  • Value chain analysis in the context of transfer pricing
  • Value creation through the value chain
  • How value and supply chains differ, and why
  • Tax-effectiveness within a value chain framework

 

Session 3: Business (Re)Structuring – Aligning Value Chain Substance to Transfer Pricing Strategies

  • Core Transfer Pricing concepts
  • Defining value chain substance and business models – BEPS Action Point 8 - 10 and 13
  • Why businesses restructure the way that they do
  • Practical transfer pricing considerations and issues
  • Tax authority and regulatory viewpoints transfer pricing strategies

 

DAY 2 (09:00 - 17:00)

 

Session 4: Core Financing Structures

  • Debt vs equity
  • Hybrid financing instruments
  • Hybrid entity mismatches
  • Common hybrid financing models – case studies

 

Session 5: Application of BEPS to Financing Models

  • BEPS Action Points 2 and 5 – adapting financing models to hybrid mismatch and harmful tax practice legislation
  • Action point 4 – interest deductions disappearing for hybrid models
  • Asia tax authority policy on these issues – what we know so far

 

Session 6: Case Study – Applying What We Know

  • Case study applying key concepts from first 2 days re transfer pricing and financing models – overlaying BEPS concepts – to develop sustainable transfer pricing and finance models

CFOs Leadership :
Experience Clariden
Discover how our leadership program has shaped the perspectives of CFOs across Asia
 
Venue: The Marker San Francisco
Date: 5 - 6 Jun 2017
Faculty: Matthew Andrew
Early Bird 1: US$1,995 (10 Apr 2017)
Early Bird 2: US$2,195 (by 8 May 2017)
Regular Fee: US$2,295
Group Discount: 2nd participant get 10%, or register 3 participants and 4th participant get a complimentary seat
(1 discount scheme applies)
Contact: karen.woods@claridenglobal.org
 
 
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