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Double Taxation Treaties & Tax Agreements

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					2006                    Double	Taxation
                        Treaties	&
                        Tax	Agreements
 Key Media ConferenCe



                        Date	 :	17	October	2006
                        Time	 :	9.00am	–	5.00pm
                        Venue	:	Meritus	Mandarin	Hotel,	Singapore



                        D
                                   ouble Taxation Agreements (DTAs) commonly known as tax treaties seek to eliminate instances
                                   of double taxation, and are concluded as a result of cross-border investment activities.
                                With the growing complexities of the tax laws throughout the region, this one-day conference
                        highlights the recent tax developments and strategies that can be used in tax planning with a focus
                        on the Asia-Pacific region and China. Hear from leading experts on ways to equip your organisation
                        with the means to successfully conduct operations overseas.


                        ATTEND DOUBLE TAXATION TREATIES & TAX
                        AgREEmENTS AND LEARN:
                        •   Double Taxation Treaties & Tax Agreements – What you need to know and why they are important
                        •   The role of OECD Model, how treaties are constructed and the latest OECD Developments
                        •   Recent developments in Singapore holding regime
                        •   The emerging trends of the tax regime in Asia-Pacific and China
                        •   Tax planning considerations for companies venturing into these markets
                        •   New and effective strategies for dealing with emerging challenges facing tax treaties
                        PLUS: Practical applications for regionalising companies


                        WHO SHOULD ATTEND
                        •   CEOs / CFOs / COOs / CPAs
                        •   Managing Directors / General Managers
                        •   Tax Professionals / Tax Managers / Finance Managers
                        •   Accounting Professionals / Auditors
                        •   In-house Legal Counsels / Tax Lawyers / Tax Advisors

                        FOR mORE iNFORmATiON – CONTACT CATHERiNE
                             (65) 6423 4631 ext 213  (65) 6423 4632  catherine@keymedia.com.sg  www.keymedia.com.sg


                                  RegisteR now + save $200
                        Participating Organisations:                                              Supported by:




                                                                                                  Another event organised by:
TOpiCS iNCLUDE:                                                                                                                                                  OUR pANEL OF DiSTiNGUiSHED
                                                                                                                                                                 SpEAKERS:
Principles of Double Taxation                                                     Understanding the Tax                                                          Ernst & Young
and Tax Treaties – The                                                            Regime in the Asia Pacific                                                     Sunghak (“Andy”) Baik
Essentials                                                                        Region and China                                                               US Desk Leader (US Tax Partner)
•	 Factors	that	determine	the	scope	of	tax	liabilities                            •	 General	overview	of	income	and	withholding	                                 International Tax Services
•	 Concept	of	Permanent	Establishment	(PEs)	                                         tax	rates	in	Asia                                                           Andy BAik	leads	the	Pan	Asia	tax	coordination	for	
   and	withholding	taxes                                                          •	 Main	tax	issues	to	be	observed	in	                                          key	multinational	clients.	He	has	an	all	around	cross-
•	 Characteristics	and	effects	of	different	tax	                                     structuring	cross-border	investments                                        border	tax	background	well	suited	to	serve	global	
   mechanisms                                                                     •	 Tax	treaty	planning	possibilities:	holding	                                 tax	engagements	for	MNCs.	Andy	has	a	diverse	
                                                                                     structures, financing structures                                            work	experience	in	both	US	and	Asian	tax	systems	
The Agency Concept under                                                          •	 Recent	developments	in	Singapore	holding	
                                                                                                                                                                 and	has	advised	MNCs	on	both	US	outbound	and	
Tax Treaties                                                                                                                                                     inbound	international	tax	issues	including	treaties.	He	
                                                                                     regime
                                                                                                                                                                 is	also	a	frequent	author	on	international	tax	subjects	
•	 Agency	concept	under	OECD	Treaty                                               •	 Real	examples	of	DTAs
                                                                                                                                                                 and	has	written	articles	on	topics	such	as	transfer	
•	 The	activities	of	an	agent	and	Permanent	
                                                                                  Fundamental Concepts of                                                        pricing	and	tax	planning	in	Asia.
   Establishment	(PE)
•	 Independent	agents	vs	dependent	agents                                         Tax Treaties – Overview and
                                                                                  Planning Possibilities of Key
                                                                                                                                                                 Horwath First Trust Tax
•	 Transfer	pricing	issues	under	agency	structure
                                                                                  Articles                                                                       Services Pte Ltd
•	 Practical	applications	for	regionalising	
                                                                                  •	 Resident	article	and	application	of	corporate	                              Sivakumar Saravan
   companies
                                                                                                                                                                 Director, Tax Services
                                                                                     tie	breaker	rule
Organisation for Economic                                                                                                                                        SivAkumAr SArAvAn	has	extensive	experience	
                                                                                  •	 Dividends,	interest	and	royalty	artless	and	                                in	tax	consultancy	work	especially	in	the	area	of	
Co-Operation and Development                                                         practical	applications                                                      cross-border	taxation.	The	industries	that	he	has	
– The OECD Model                                                                  •	 Capital	gains	article	and	planning	                                         experience	 in	 providing	 tax	 consultancy	 work	
•	 The	underlying	principles	of	Double	Taxation	                                     possibilities                                                               include	 banking,	 fund	 management,	 financial	
   Agreements	and	Various	Articles                                                •	 Other	income	article	and	planning	                                          services,	 manufacturing,	 trading,	 healthcare,	 e-
•	 Member	countries	and	the	impact	of	being	a	                                       applications                                                                commerce	and	high	technology	related	industry.	He	
   non-member	including	Singapore	and	China                                       •	 Treaty	shopping	structures	and	concerns                                     is	familiar	with	transfer	pricing	issues	associated	with	
•	 Recent	OECD	developments                                                       •	 Tax	sparing	introduction	and	planning                                       global	trading	and	other	related	party	transactions.	
                                                                                                                                                                 As	Horwath	First	Trust	has	a	substantial	number	
                                                                                                                                                                 of	 China-based	 and	 China-bound	 clients,	 Siva	
Registration includes presentations, lunch, networking sessions, refreshments and delegate pack.                                                                 routinely	advises	clients	on	China	tax	implications	
                                                                                                                                                                 of	inbound	investments	in	China.
REGISTRATION		                                                         This will become a Tax invoice when payment is made.

        Early	Bird	Special:	S$795	+	5%	GST	(For	registration	and	payment	received	by	18 September 2006)
                                                                                                                                                                 Deloitte & Touche
                                                                                                                                                                 Sum Yee Loong
        Conference	Fee:	S$995	+	5%	GST.	                             10%	off	for	group	booking	of	3	or	more
                                                                                                                                                                 Tax Partner - Singapore
        15%	off	for	SCCA	members				(Please indicate membership ID:                                                                        )                     Sum yee Loong	has	over	20	years	experience	
                                                                                                                                                                 in	 Singapore	 taxation	 (public	 accounting).	 He	
Please	reserve	               	seat(s)	at	‘double Taxation Treaties & Tax Agreements”	conference	on	17	October	2006.
                                                                                                                                                                 provides	 advisory	 tax	 services	 to	 multi-national	
delegate 1		Name	                                                                      		Position	
                                                                                                                                                                 companies	 and	 local,	 corporate	 and	 individual	
                                                                                                                                                                 clients.	His	specialties	include	corporate	structuring	
Email	
                                                                                                                                                                 &	restructuring,	restructuring	for	IPO,	acquisition	&	
delegate 2		Name	                                                                      		Position	                                                               mergers	and	international	tax	planning.	He	is	also	
Email	                                                                                                                                                           Associate	 Professor	 (Adjunct)	 at	 the	 Singapore	
delegate 3		Name	                                                                      		Position	
                                                                                                                                                                 Management	 University.	 He	 is	 examiner	 for	 the	
                                                                                                                                                                 Advance	Taxation	 Paper	 (Singapore	 Variant)	 of	
Email	
                                                                                                                                                                 the	ACCA	 and	 the	 author	 of	 the	 Singapore	Tax	
Company	Main	Contact	                                                                                                                                            Workbook	published	by	CCH.	
Company	                                                                		Billing	Company	

Billing	Address	
                                                                                                                                                                 Loyens & Loeff
                                                                                                                                                                 Michiel Boeren
Email	                                                                    		Nature	of	Business	
                                                                                                                                                                 Tax Associate
                                                                                   Signature:
Tel	                                                                                                                                                             michieL Boeren	 specialises	 on	 inbound	 tax	
Fax		                                                                                                                                                            planning	 which	 includes	 corporate	 income	 tax	
                                                                                                                                                                 planning,	personal	income	tax	planning	and	indirect	
Total	Amount	Payable	
                                                                                                                                                                 taxation	in	a	variety	of	Asian	countries	and	in	a	variety	
NB Reservations confirmation will be sent via email. 	        Code:Email                                                                                         of business sectors, such as financial institutions,
PAymenT	Please	send	your	cheque/bank	draft	made	payable	to	“Key	Media	Pte	Ltd”	to	121	Telok	Ayer	Street,	#02-01,	Singapore	068590.		TeLegrAPhic                  trading	and	manufacturing	companies.	Prior	to	his	
TrAnSFerS	A/C	name:	Key	Media	Pte	Ltd	Bank:	Overseas-Chinese	Banking	Corporation	(OCBC).	Address:	227	Orchard	Rd,	#11-01	Specialist’s	Shopping	
Centre,	Singapore	238858	Bank	code:	7339	Branch	code:	508	A/C	No.	317	674-001.		noTice	The	organisers	may	at	anytime,	with	or	without	giving	prior	
                                                                                                                                                                 appointment	in	Singapore,	he	was	a	tax	practitioner	
notice,	cancel,	postpone	or	change	the	content	of	any	published	particulars,	without	liability.	Payment	must	be	received	prior	to	the	conference	to	guarantee	   with	Loyens	&	Loeff	in	the	Netherlands,	working	
your	place.	Walk-in	delegates	with	payment	will	only	be	admitted	on	the	basis	of	space	availability	at	the	conference.		cAnceLLATionS	All	cancellations	
must	be	recieved	in	writing	28	days	prior	to	the	event	or	100%	cancellation	fee	applies.		incorrecT mAiLing inFormATion	If	you	receive	multiple	                 on	Dutch	tax	compliance	matters,	and	advising	his	
mailings	or	if	your	company	details	are	incorrect,	please	let	us	know	so	as	to	update	our	database.	If	you	do	not	wish	to	have	your	name	on	our	mailing	list,	
kindly	inform	us	in	writing	and	we	will	remove	it	from	our	listing.
                                                                                                                                                                 clients	on	Dutch	and	European	tax	matters

				
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Description: Double Taxation Treaties & Tax Agreements