China Corporate Income Tax Planning 1.5 by WillyWoodcock


									                                                              Dinner Talk

                                                                CPD units

                                                             China Corporate Income
                                                             Tax Planning
                                                             By Bolivia Cheung and Barry Cheung

                                               The new Corporate Income Tax (CIT) Law was effective from 1 January 2008.
                                               Certain clarifications and implementation rules of the CIT law were issued in
17 November 2009, Tuesday
                                               early 2009.
M Hotel                                        How will the changes affect foreign investors?
81 Anson Road
Shenton Room, Level B1                         The seminar will illustrate the following concepts via the following case study:
(Nearest MRT Station: Tanjong Pagar)           XYZ Group has a Regional Headquarters in Singapore, with 5 subsidiaries in
                                               China. The subsidiaries enjoyed a tax holiday previously. The PRC subsidiaries
Time                                           produce both for export and domestic sales in China and held by a BVI special
7:00pm - 9:00pm                                purpose vehicle (SPV) as part of the exit strategy. The Group is considering
(Registration from 6:30pm onwards)             selling one subsidiary with a significant amount of retained earnings and the
                                               buyer is a domestic Chinese group. The following questions will be addressed:
(Inclusive of light snacks and refreshments)
                                               ·   What are the chinese tax authorities currently focusing on in terms of tax
S$45 ACCA Members                                  avoidance?
S$50 ACCA Affiliates/ Students                 ·   What are the tax incentives which the PRC subsidiaries may enjoy?
S$55 Non-Members                               ·   How to reduce the tax on selling off the PRC subsidiary?
                                               ·   Can the PRC subsidiaries have RMB inter-company loans within China?
*ACCA Approved Employers enjoy a 10%
group discount off Non-Members rate            ·   How will the PRC thin-capitalization rules affect the financing in China?
(Minimum 3 staff members)                      ·   How will the new CIT law affect the dividend withholding tax?
                                               ·   Are there any potential dividend planning strategies to reduce withholding
Enrolment Deadline                                 tax?
11 November 2009, Wednesday                    ·   Can a Singapore SPV be inserted to replace the BVI SPV?
                                               ·   What are the feasible holding and operating structure within the PRC?
                                               ·   What are the CIT implications of mergers? What are the other factors to be
                                                    considered during mergers?
                                               ·   Is it possible to use a China Holding Company to hold all the PRC
                                                   subsidiaries? What are the pros and cons?

                                               It will be followed by a Q&A session.

                                                  ACCA SINGAPORE          T +65 6734 8110
                                      435 ORCHARD ROAD #15-04/05          F +65 6734 2248
                                    WISMA ATRIA SINGAPORE 238877
                                                   About the Speakers
Bolivia Cheung, Tax Partner, KPMG China
Bolivia advises multinational clients on taxation, customs duty and business regulations in respect of the
structure of investment and assists clients in developing business activities in China, with her major focus
on financial services, property development and domestic major groups. She has extensive experience
advising clients on cross-border transactions and the repatriation of funds from China in a tax efficient
manner and has assisted clients in tax due diligence and advised on mergers, acquisitions and IPO proj-
ects in the PRC.

She has recently participated in various consultancy projects for major domestic and foreign property de-
velopers and shared her insight and experience on the existing restrictions on foreign exchange and direct
investment in the PRC property market.

She has written articles on taxation and customs issues for various journals. She is also a regular speaker
on PRC issues.

Bolivia is the Chairman of the Steering Team of ACCA Southern China, Member of ACCA, Member of CPA
Australia and the Fellow Member of the Hong Kong Institute of Certified Public Accountants.

Barry Cheung, Tax Manager, KPMG China

Barry has extensive experience in advising multinational clients on China taxation, foreign exchange con-
trol and business matters. His experience includes advice on a number of substantial group restructurings
in China, setting companies, merger and acquisition, tax due diligence and pre-IPO advisory. He has been
the tax manager in charge of various domestic and overseas listing, restructuring and property investment
tax advisory project. He is in charge of providing China tax advisory to several multinational companies
for their investments in China.
ACCA Dinner Talk
Enrolment Form for “China Corporate Income Tax Planning”
- Tuesday, 17 November 2009, at M Hotel

Contact Person’s Particulars
Contact Person :                                           Membership No.:

Designation :                                              Company         :

Tel           :                                            Fax             :

*Address      :

E-mail        :

All Participants Details (Single cheque payment)
      Name of Participant/s                        Company/Title                 Reg No. (If applicable)      Amount

                                                                                         Amount Payable:

Payment Method

 Cheque payable to “ACCA Singapore Pte Ltd”             Bank                            Cheque No.


Important notes:
1. ACCA Singapore reserves the right to cancel or make any adjustments to the event.
2. Enrolment by fax is NOT accepted.
3. Please indicate on the reverse side of your cheque, Your Name, Contact Details and Event Name.
4. Full payment must be received prior to the event. Registration forms submitted without payment will not be accepted.
5. Enrolment is on a first-come-first-served basis.
6. No cancellations 3 days before the event but substitutions will be permitted.
7. Enrolment confirmation will be sent via e-mail to each enrolee after enrolment dateline.
   (E-mail address must be provided)
8. Receipts & Invoices will be issued upon request.

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