To promote tax transparency and combat tax evasion, Hong Kong indicated its commitment to implement certain measures by the Organization for Economic Co-operation and Development (“OECD”) to counter base erosion and profit shifting (“BEPS”) of enterprises. At the same time, Hong Kong would continue to combat tax evasion and avoidance by conducting field audit and investigation.
The purpose of this seminar is to provide insights on the approach adopted by the Hong Kong Inland Revenue Department (“IRD”) in the tax audit cases and the tips in handling tax audit cases conducted by the IRD. We will further provide an update on BEPS and discuss how transfer pricing could be leveraged in a tax audit settlement. The key topics will include:
– Selection criteria of tax audit target
– Process of the tax audit in Hong Kong
– Tips in handling tax audit conducted by the IRD
– Brief BEPS updates – Hong Kong Consultation Paper to counter BEPS
– Impact of BEPS on companies – challenges & opportunities
– Case sharing
About the Speakers:
Dennis Chan, Senior Advisor, Tax Controversy Services, EY
Dennis is a former senior officer of the Hong Kong Inland Revenue Department (“IRD”). He spent his first career in the IRD for more than 35 years. He has extensive experience in Hong Kong taxation. Dennis worked in different Units and Sections within the IRD, including profits tax, salaries tax, tax audits and investigations. He has the technical skills in dealing with tax affairs of multi-national corporations and listed companies including source of profits issue and capital/revenue claims. He handled profits tax assessments on financial institutions for about 6 years. He also led the criminal tax investigation team for about 7 years to tackle potential tax evasion cases, instituted criminal prosecution against them and successfully secured convictions on many blatant tax evasions cases.
Martin Richter, Partner, International Tax Services – Transfer Pricing, EY
Martin is the Partner in charge of EY’s transfer pricing practice in Hong Kong, advising clients in both Hong Kong and Mainland China. Martin is based in Hong Kong and has 17 years of transfer pricing experience, gained from Big 4 practices in London, Washington DC, and Hong Kong. Martin advises on a full range of different transfer pricing project types, including policy design and implementation, tax aligned restructurings, audit defense, advanced pricing agreements, as well as general compliance and documentation. He has deep experience in advising on a multitude of intercompany transaction types, including establishing and supporting unit prices for tangible goods; fees for services; royalties / licenses / franchises for intangibles; and financing costs for financial transactions.
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