The Italian Chamber of Commerce is pleased to invite you to attend a business seminar on the change of Permanent Establishment meaning in Hong Kong and its tax implication.
Despite being first introduced in 1940s, the concept of permanent establishment (“PE”) has started to be widely mentioned in Hong Kong, and generally worldwide, after the launch of Base Erosion and Profit Shifting (BEPS) project by the OECD in 2015. This program had the aim to tackle international tax avoidance by high-profile multinationals. Moreover, the enactment of Inland Revenue (Amendment No.6) Ordinance 2018 has brought a big change because it primarily implements the international standards of the BEPS package and codifies the transfer pricing principles into the Inland Revenue Ordinance (IRO).
Would this brand-new definition of PE bring more controversy or settlement of tax issues? That’s the main theme that this seminar will deepen.
ABOUT THE SPEAKERS
Wilson Cheng, Partner, Hong Kong Business Tax Services / Tax Controversy Services, EY
Wilson is the Tax Controversy Leader in Hong Kong, with around 20 years of Hong Kong corporate tax advisory experiences. He provides a wide spectrum of tax controversy services to conglomerates, listed companies as well as the US and European-based multinational corporations.
He has extensive experiences in dealing with Hong Kong tax authorities, for example assisting corporations in settling pro-longed tax disputes on contentious tax issues in Hong Kong. More recently, he advised his clients on new tax incentives scheme in Hong Kong and then assisted the client to obtain an advance ruling from the Hong Kong tax authorities. His other tax experiences include group structure rationalization and restructuring, cross-border transaction planning and compliance, IPO review and restructuring.
Martin Richter, Partner, Transfer Pricing Services, 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 advises on a full range of different transfer pricing project types, including policy design and implementation, tax aligned restructurings, audit defence, 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.
Cherry Lam, Partner, Hong Kong International Tax Services, EY
Cherry has extensive experience in advising multinationals corporations on international and Hong Kong tax matters and assisted her clients in numerous global and regional projects, including principal structure planning, operating model structuring, outbound investment planning, legal entity rationalization, licensing structure planning, tax health checks, IPO structure planning etc.
She is knowledgeable in serving clients in a wide range of industry including e-commerce, technology, industrial and consumer products, hospitality, logistics and transportation.
IN COLLABORATION WITH