International Tax Dialogues
All sessions will take place from 6.30 to 8pm at the office of Withers KhattarWong, located at 80 Raffles Place, #25-01 UOB Plaza 1 Singapore 048624.
Discussion Moderator: Stephen Phua, National University of Singapore
Date: 29 August 2017, Tuesday
Section 33 and the GBF case
The need for a GAAR is as uncontroversial as the desire to minimise tax burdens is understandable. Where tax reduction is achieved through contrivance, counteraction of any tax advantage obtained is less objectionable. However, the same may not be true where taxpayers take advantage of specific tax reliefs. If the goal of enacting a specific tax relief is to promote desired outcomes, the application of GAAR solely to regulate the utilisation of such reliefs may severely undermine the certainty required to ensure their success. This talk will evaluate the merits of applying section 33 to the facts in GBF v The Comptroller of Income Tax  SGITBR 1 and canvass alternative solutions that may strike a more desirable balance between competing interests.
Discussion Moderator: Dennis Schafer, Loyens & Loeff Singapore LLP
Date: 14 September 2017, Thursday
Withholding tax in the era of BEPS, CIVs and the digital economy
During the IFA 2018 Seoul Congress, one of the two main topics will cover withholding tax in the era of BEPS, CIVs and the digital economy. Dennis Schäfer provides the Singapore input for the IFA report on this topic and will present this during an ITD session. Dennis will discuss the domestic Singapore and international aspects of withholding taxes. In addition, he will discuss the position of CIVs and the serious challenges raised by the digital economy.
Discussion Moderator: Tracey Kuuskoski & Hong Chan Kim, Ernst & Young Solutions LLP
Date: 27 September 2017, Wednesday
Is your business and tax function fit for a digital tax world?
The digital economy is rapidly transforming how companies do business globally — from how goods and services are sold, where companies base their operations to how they connect with their customers. In a digitally disrupted world, companies need to navigate every aspect of the digital business transformation.
The discussion will cover the latest trends in the digitalization of tax function and tax administration, technology solutions to help companies keep abreast, and even get ahead of, tax authorities’ requirements on transparency and real-time reporting, and proactive measures and practices to assist a company’s tax function in getting up to speed in this digital age.
Discussion Moderator: Vikna Rajah, Rajah & Tann Singapore LLP
Date: 3 October 2017, Tuesday
Anti-avoidance measure of general nature and scope GAAR and other rules
Subject 1 of the IFA 2018 Seoul Congress will cover General Anti-Avoidance Rules (GAARs) and other anti-avoidance general measures. Branch Reporters are invited to describe in detail their domestic GAARs or general anti-avoidance judicial doctrines, in respect to their statutory design features and according to the questions provided to them. In the second part of the report, case law on the operation of the GAARs or other similar rules or doctrines should be depicted by the reporters. And in the third part, they are expected to portray any existing safeguard to the taxpayers in the operation of the GAAR or other similar rules or doctrines.
Vikna Rajah is the Singapore Branch Reporter for Subject 1 and he will present his draft branch report before opening the floor for discussion.
CPE hours: 1.5/session
A certificate of attendance will be provided after each session.
Per Session 3 Sessions
(participants to confirm and make payment before 13 May 2016)
Type of member
|IFA Individual members||FREE||FREE|
|IFA Corporate members||FREE for up to 2 persons per firm||FREE for up to 2 persons per firm|
|SIATP and STEP members||S$30||S$100|
To register, please email Aileen Chung (firstname.lastname@example.org) and Rachel Ong (email@example.com).