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Following the enactment of the Inland Revenue (Amendment) (No. 6) Ordinance in 2018 which formally introduced the base erosion and profit shifting ('BEPS') and transfer pricing regulatory regime in Hong Kong, Mutual Agreement Procedure ('MAP') and Advance Pricing Arrangement ('APA') have been codified in the Inland Revenue Ordinance.

At a time when an increasing trend in the number of tax disputes and double taxation cases is observed due to changing tax and economic environment, MAP and APA can offer reliable solutions. MAP provides a mechanism to resolve disputes regarding the application of double taxation arrangements, while APA allows taxpayers to obtain tax certainty for future (and historical) years.

Join us on 9 February when tax experts from PwC Kenneth Wong – Partner, Tax Controversy Services, Tiffany Wu – Partner, Transfer Pricing and Horace Wan – Senior Manager, Tax Controversy Services will share their insights and observations on the development of MAP and APA in Hong Kong.

Highlights of the seminar

• What are 'MAP' and 'APA' and their significance
• Latest development of MAP and APA in Hong Kong
• Key to a successful MAP and APA
• Practical challenges to MAP and APA
• Case sharing

For participants attending online, please refer to the following:

- Upon successful registration of the event, a unique webinar link will be sent to your registered email (attendee email) 2 working days before the event. Please refer to the troubleshooting guide here should you experience any issues in locating the webinar link.
- Instructions on downloading Zoom and joining a webinar can be found here. We suggest that you familiarize yourself with the software in advance of the webinar.
- Please log in 15 minutes (at 15:45) before the event begins, through the link that will be sent to your registered email.

For participants attending in-person, please refer to the following:

- Seats are limited and available on a first come first served basis.
- Pre-registration for in-person attendance is required and the Chamber reserves the right to decline such an application.
- Attendees should wear a mask at all times.
- Attendees, who feel unwell are advised against in-person attendance at the Chamber. If attendees are required to undergo compulsory testing, please kindly bring along a negative PCR or RAT test result when attending physically.
- Food and beverages will not be provided.

DISCLAIMER
Speakers' presentations at this event are intended for educational purposes only and do not replace independent professional judgment. Statements of fact and opinions expressed during this event are those of the speakers and participants and, unless expressly stated to the contrary, are not the opinion or position of the Hong Kong General Chamber of Commerce, its members, or its committees. The Chamber does not endorse or approve, and assumes no responsibility for, the content, accuracy or completeness of the information presented. Attendees should note that, with the approval of speakers, this event may be recorded, and possibly published on the Chamber's website in audio and/or video formats without further notice.

Recording, duplication or distribution of the contents of the online event is prohibited without prior written permission from the Chamber.

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Speaker(s)

Kenneth Wong

Partner, Tax Controversy Services, PwC

Mr Wong has over 20 years of experience in tax consulting, specialising in complex tax controversial issues with the Hong Kong Inland Revenue Department (IRD). His clients include global MNCs, Hong Kong listed companies and Chinese enterprises mainly in the consumer and industrial products, retailing and technology industries as well as NGOs.

Mr Wong has significant HK TCS experience and successfully helped many multinational and listed companies settle tax disputes and Board of Review cases with different Technical Units within the IRD, including Appeals, Field Audit & Investigation, Tax Treaty, on various technical issues like exemption claims, offshore claims, tax anti-avoidance, complex cross-border tax issues involving tax treaties between the IRD and overseas tax authorities.

Tiffany Wu

Partner, Transfer Pricing, PwC

Ms Wu specialises in providing TP services for over 15 years for multinational corporations in various industries including chemicals, biotech, consumer goods, real estate, logistics and transportation, information and communications technology, which includes 10 years of service in Mainland China office.

She has been actively assisting clients in value chain transformation, regional TP model set up, global and regional TP documentation, TP audit defense support, Advance Pricing Arrangement (APA) and Mutual Agreement Procedure (MAP).

Ms Wu has extensive experience in handling TP dispute resolution cases and has assisted in concluding the first Cost Sharing Arrangement (CSA) APA in Mainland China regarding intellectual property for a Fortune 500 company. She has also assisted clients in Mainland China and Hong Kong in concluding and negotiating APA/MAP cases.

Horace Wan

Senior Manager, Tax Controversy Services, PwC

Mr Wan has 15 years of experience in providing tax consulting and compliance services to local, regional, multi-national and listed companies mainly in the e-commerce, travelling, real estate, hotel and retailing industries.

Mr Wan has extensive experience in assisting clients in handling profits tax challenges raised by the Inland Revenue Department (“IRD”) as well as assisting clients with tax planning and commercial substance build-up.

Mr Wan graduated from the Hong Kong Polytechnic University with a bachelor degree in accountancy and is a Member of the Hong Kong Institute of Certified Public Accountants.

Language

English

Date and Time

2023/02/09 16:00 to 17:30

Venue

Chamber Theatre, 22/F United Centre

Media

Closed to media

Enquiries

Gillian Tam
Tel: 28231246
Email: gillian@chamber.org.hk

Fee

HK$ 120 for Members / HK$ 240 for Non-Members (Online Via Zoom)
HK$ 120 for Members / HK$ 240 for Non-Members (In-person at Chamber)

+$50 for booking offline
Members enjoy 30% discount with BOC HKGCC VISA Card

Notes

- Bookings are only confirmed upon receipt of payment, on a first come first served basis.
- Booking transfer is allowed for corporate members with advanced notice, walk-ins are normally not accepted.
- The Chamber reserves the right to decline any booking or cancel the event. In such case, a full refund of the participation fee will be issued.
- No refund will be made for last minute cancellations or no-shows. If the booking is cancelled at least 3 days before the event, and in such cases the refund will be subjected to a 10% administration fee, or HK$100 deduction, whichever is higher.
- Members paying with their BOC HKGCC Visa Card will enjoy a 30% discount on their reservation. The discount is only applicable to the card holder, and does not extend to their guests. The discount cannot be used in conjunction with Chamber Coupons.
- A $50 handling fee per person will be charged for all offline bookings (e.g. fax, e-mail, post) for all Chamber events. Go online today by downloading our app or registering on the HKGCC website to save the environment and money.
- Priority is given to corporate members. The decision to accept or decline any booking shall be at sole discretion of the Chamber.

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