Download the pdf version of the detailed program here.
Download the pdf version of the timetable and roundup here.
Young IFA Network Seminar - Tax Compliance, Tax Administration and the Digital Transformation
In this day and age, regulatory compliance has become a major burden for businesses, as well as creating additional workloads for tax administrators. How can this burden be reduced to achieve effective tax compliance and efficient tax administration?
Many countries around the world have commenced the digital transformation of tax administration as envisaged in the OECD Tax Administration 3.0. This transformation has the potential to make taxation a more seamless process from the taxpayer respective, building in compliance in more areas and significantly reducing burdens.
This seminar will explore the digital transformation of tax administration and compliance as well as its impacts.
Speakers: Mr. Lucas Ting (Chairing), Mr. Ignacio Gepp, Mr. Jared Garfield, Ms. Michelle Kim.
Plenary 1. Tax Reform and Society - (PANEL including OECD/EU)
East Asia faces significant demographic and social challenges. The future of tax law in the region will be influenced by the emerging OECD/EU/UN-led consensus on international taxation and domestic pressures to respond to societal challenges. Our mixed panel of practitioners and public sector experts will consider common themes in the evolution of domestic tax law and how the legislative process is affected by both international and local concerns.
The implications for extensive tax reforms, including incentive systems, tax rates and the allocation of tax burdens will be profound for practitioners and taxpayers alike. This session will discuss tax law and societal challenges and trends in Asian jurisdictions.
Speakers: Mr. Thomas Vanhee (Chairing), Mr. David Bradbury, Mr. Thenesh Kannaa.
Plenary 2. Tax and ESG (PANEL including OECD/EU)
This session will explore from an Asian perspective how ESG can impact the tax morale of companies and the perception of corporate tax compliance in the marketplace. Companies (including tax advisors) are facing increasing pressure to “do it right” (pay fair taxes and be transparent on their tax policies). This pressure comes not only from tax authorities, the media, and society, but also from investors and employees.
What should companies consider with respect to setting and implementing their ESG tax policies? What is the role of governments and tax advisers in this context? These questions and related issues will be considered.
Speakers: Dr. Veerinderjeet Singh (Chairing), Ms. You-Lee Jung, Mr. Tom van der Lee, Dr. Suranjali Tandon, Prof. Clemence Garcia.
Workshop 1. Pillar 2: Developments and Practical Issues
This session will address Pillar 2 developments and practical issues, including the following: Are jurisdictions in Asia prepared for Pillar 2 implementation? How should countries adjust or change their tax incentives and subsidies? How are departures from the GloBE rules being handled? Are MNEs in Asia suitably prepared? Will Pillar 2 reduce tax disputes for MNEs? What are the planning strategies MNEs might use in response to Pillar 2? These questions and related issues will be discussed.
Speakers: Mr. Jesse Kavanagh (Chairing), Mr. David Bradbury, Mr. Luis Coronado, Mr. Jefferson Vanderwolk.
Workshop 2. Indirect Taxes: VAT and Customs in Asia
Indirect taxes in Asia warrant more attention. Indirect taxes can broaden the tax base and serve as an important tool to raise awareness that public services come at a cost. Typical questions relate to how to deal with indirect taxes and how to mitigate them. An expert panel from various Asian countries will discuss these and related issues.
Speakers: Mr. Aliff Fazelbhoy (Chairing), Mr. Naohito Suzuki, Mr. Thenesh Kannaa.
Workshop 3. Tax Transparency: Past, Present and Future
A decade after FATCA became effective, the trend toward transparency continues. The OECD has recently published a new information exchange standard for crypto assets and a proposal for information exchange concerning foreign owners of real estate properties. The United States enacted the Corporate Transparency Act, and more countries have established beneficial ownership registers. This session will explore these reforms and their implications for taxpayers and tax professionals, focusing on Asian jurisdictions.
Speakers: Mr. Todd Beutler (Chairing), Prof Noam Noked, Prof Yoshinori Ikeda, Mrs. Anne Quenedey.
Workshop 4. Tax Evasion and Money Laundering
The interaction between tax evasion and anti-money laundering laws raises various challenges.
The Financial Action Task Force has declared that tax evasion must be treated as a predicate office under anti-money laundering laws, which raises unresolved issues: What foreign taxes are covered? What features or activities should give rise to a suspicion that tax evasion is occurring? How does one determine whether cash or other property represents the proceeds of tax evasion? How does one trace such proceeds through the tax evader’s accounts? How far back in time does one trace the original source of funds? Can tax evasion occur before tax returns are due to be filed? Different jurisdictions have taken different approaches, and many institutions adopt simplistic approaches that defy technical robustness. This session will explore these questions and related issues.
Speakers: Mr. Kenny Foo (Chairing), Ms. Ji-Suk Kim, Prof. Dr. Martin Wenz.
Women of IFA Network Seminar - Artificial Intelligence: What Does It Hold for Practitioners and Administrators?
Artificial Intelligence can now be found everywhere and is becoming an important tool in legal and tax practice. How can tax practitioners and tax administrations use it? Who uses it already? How should tax professionals manage AI-related risks such as quality and confidentiality?
This session will discuss these questions and other issues concerning AI in tax practice and administration in Asia.
Speakers: Mrs. Anne Quenedey (Chairing), Prof Yuri Matsubara, Ms. Grace Waworuntu, Mr. Alain Lecouedic.
Plenary 3. The New(?) United Nations Tax Convention
The UN is generally seen by many as an open forum for emerging economies. This is in contrast to the OECD which is often considered the rich countries’ club. This follows, amongst others, from the UN Model Tax Treaty, which focuses on source taxation, whereas the OECD Model Tax Treaty focuses more on residence taxation.
In November 2022, the UN’s Economic and Financial Committee tabled a resolution proposing the establishment of a UN Tax Convention that will give low- and middle-income countries more decision-making powers over global tax affairs. The resolution’s adoption is considered a diplomatic win for the African states that initially proposed it. A further report on the progress of this resolution was issued in August 2023.
Issues that arise from this development are numerous: Will the ‘new global tax body’ undermine the OECD’s position? Will it create a conflict between the UN and the OECD on fundamental tax policies? Can the ‘new forum’ achieve a broader consensus than the OECD and better represent the interests of the global south? This session will discuss these issues and their implications for Asian jurisdictions.
Speakers: Prof. Kees van Raad (Chairing), Mr. Michael Lennard, Mrs. Rachel Saw, Mr. Radhakishan Rawal.
Workshop 5. Domestic v. Global Anti-Avoidance Principles – Convergence and Challenges
This session will focus on the interaction between evolving domestic anti-avoidance measures and international law doctrines of treaty abuse, including the principal purpose test in tax treaties. Speakers will draw from their own experiences in practice and their technical insight into domestic legislation to identify common trajectories in domestic anti-avoidance legislation, and how this is likely to interact with anti-treaty abuse/treaty shopping provisions.
The prospects for dispute resolution, including arbitration and other forms of alternative dispute resolution, will further be considered in light of an Asian tax landscape that will likely become more contentious in the near future.
Speakers: Mr. Thanneermalai SP SM Somasundaram (Chairing), Mr. Nico Derksen, Mr. Abhishek Mundada.
Workshop 6. Growing Disparities Between Tax Residence Rules – Are We Heading to Global Anarchy?
Disparities between countries’ rules concerning the tax residence of individuals are becoming extreme as countries are sacrificing principles for an immediate cash grab. Australia is about to introduce a 45-day presence test. The UK has complex rules, the US has a different system entirely, and there is little uniformity. Even the 183-day test is generally a deeming provision and not a safe harbour in many countries.
This session will discuss this trend and consider ways to increase uniformity and certainty.
Speakers: Mr. Peter Chen (Chairing), Prof. Kees van Raad, Mr. PVSS Prasad.
Workshop 7. Latest and Hottest Tax Developments in Asia: Do You Really Know What Happens Next Door?
A panel of experts will discuss key developments in various countries that affect tax practitioners in Asia Pacific.
Speakers: Mr. Ichwan Sukardi (Chairing), Mr. Andrew Choy, Mr. Steve Minhoo Kim, Ms. Mayuko Nakamura, Ms. Diya Gabija, Suk Ching Yap.
Workshop 8. NGOs and Tax Evasion
This session will discuss the role of non-governmental organizations, such as OXFAM and the Tax Justice Network, in combating tax avoidance and aggressive tax planning by global corporations. Who are they, what are their campaigns and strategies, how successful have they been, and what are their challenges ahead?
Speakers: Prof. Dr. Martin Wenz (Chairing), Mr. John Lazaro.
Plenary 4. The Future of the Tax Profession
Will the harmonization of international tax norms and the increasing influence of the OECD fundamentally change the tax profession? How will this trend affect the market for tax advice? How can the tax profession evolve to meet those coming opportunities and challenges? A diverse panel of accountants and legal professionals will share their experience in responding to the changing demands of clients and the often quite radical changes in tax administrations’ policies.
Discussion points will include legal professional privilege, the future of tax planning and tax structuring, and the emergence of normative doctrines of ‘good corporate citizenship’ that could impact both the scope of and approaches towards tax planning.
Not to be missed is the trend towards increased reporting obligations on tax advisers, including Mandatory Disclosure Rules under DAC6, CRS MDRs, and the EU’s recent proposal for further regulation of professional enablers.
Speakers: Mr Simon Rae (Chairing), Mr Stanley Ho, Mr. Ignacio Gepp, Dr. Veerinderjeet Singh, Mrs. Ami Leng.