The concept of permanent establishment (“PE”), first introduced in the 1940s, has not been mentioned frequently in Hong Kong as the taxability of profits has relied on the question of the source of profits. After the launch of Base Erosion and Profit Shifting (BEPS), a project by the Organization for Economic Co-operation and Development, the definition of PE has a new chapter internationally. The enactment of Inland Revenue (Amendment) (No.6) Ordinance 2018 has also brought the international standard to life in Hong Kong.
Would this change of definition of PE bring more controversy or settlement of tax issues?
The Italian Chamber of Commerce, in collaboration with Ernst & Young, is glad to present this webinar that will provide insights on the change of meaning of PE in Hong Kong and its tax implications. Our experts will deepen the impact of the new definition to Hong Kong resident and non-resident companies, comparing the PE and enforcement in the Asia Pacific region.
ABOUT THE SPEAKERS
Wilson Cheng, Partner, Greater China Tax Controversy Co-Leader Hong Kong Tax Controversy Leader, EY
Wilson is a Tax Partner in Hong Kong, with more than 20 years of Hong Kong corporate tax and transaction tax experiences. He provides tax advisory and compliance services to conglomerates, listed companies as well as US and European-based multinational corporations.
His tax experiences include group structure rationalization, tax due diligence review, pre-acquisition tax structuring advice, cross-border transaction planning and compliance, IPO review and restructuring as well as tax accounting advice. He has extensive experience in dealing with Hong Kong tax authorities, for example assisting corporations in settling pro-longed tax disputes on contentious tax issues. More recently, he advised his clients on tax-efficient procurement model and structure, withholding tax planning as well as the application of tax resident certificate for tax treaties between Hong Kong and overseas jurisdictions.
Sangeeth Aiyappa, Director, Transfer Pricing, Greater China, EY
Sangeeth has over 14 years of transfer pricing experience with Ernst & Young, with significant experience in Greater China, OECD and other Asian based transfer pricing documentation and planning.
Sangeeth has been involved in a wide range of transfer pricing projects covering tangible, intangible and service transactions. Her project experience includes the evaluation of inter-company pricing policies for planning and compliance purposes, defence documentation, documentation for advance pricing arrangements and setting up systems for accurate service cost allocations.
She has extensive experience with tax planning and cross-border tax structuring projects with respect to the restructuring of principal structures, evaluating alternative operating models and redesigning transfer pricing policies/models.
IN COLLABORATION WITH