South-East Asia Focus: Dealing with developing tax systems

Report
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
South East Asia Panel
Country developments
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Indonesian Scenario
Permana Adi Saputra
Taxand Indonesia
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Tax Challenges in an Age of Scrutiny
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Tax Challenges in an Age of Scrutiny
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Tax Avoidance, Tax Audit,
and Tax Incentives
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
How Tax Avoidance is Tackled
Transfer pricing
Regulation regarding the application of ALP (Per
43/PJ/2010 as amended by Per 32/PJ/2011)
Exchange of Information
Treaty shopping
Indonesia has signed 61 tax treaties, including the
new tax treaty with Hong Kong that will be
effective in Indonesia on 1 January 2013
DGT issued a DGT-form to provide certainty in
applying the tax treaty (Per 61/PJ/2009 and
amended with Per 24/PJ/2010)
Thin capitalization
Indonesian Tax Office has an authority to redetermine debt as capital
Controlled Foreign Company
Determination of dividend of an Indonesian tax
payer in relation to its shareholding in a foreign
company. (Article 18 par. 2 Income Tax law No.
36/2008 and Minister of Finance Regulation No.
256/PMK.03/2008)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Challenges and Issues in Audit Process
Tax audit is focused on certain
industries:
Mining, palm oil, mass media, chemical,
automotive, construction, wholesaler,
bank and insurance, real estate,
consultancy, processing industry
Individual tax payers are also the
focus of tax audit:
Tax consultant, lawyer, notary, and tax
payer who has relation with a company
which is being or has been audited
Tax audit can be made in the last 5
years, however the tax payer must
keep documentation for 10 years
Duration of audit process
Normal audit is 8 months, transfer
pricing is 24 months, and gathering /
examination of preliminary evidence for
a tax criminal case has practically no
time limit
Verification is the new audit
procedure in Indonesia
Tax revenue target for 2012 is
IDR13.30 trillion (US$1.46 billion)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Tax Incentives to Encourage Investment
Tax facility for certain industries
in certain locations
Accelerated depreciation
Loss compensation of not more than
10 years
10% dividend tax rate
Reduction in net income by 30% of the
investment value
Tax holiday for new capital investment
in pioneering industrial sectors
Industries: base metal, oil refinery and
base organic chemical, machinery,
renewable energy,
telecommunication equipment
Corporate income tax holiday for 5 to
10 years after the start of commercial
production; 50% income tax reduction
for two years after the end of the tax
holiday period; a maximum dividend
tax rate of 10%
If the taxpayer already has a tax facility,
the tax payer can not propose to get tax holiday
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Indonesia’s New
Transfer Pricing Regime
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9
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Authority in Making Adjustments
Article 18(3) of Income Tax Law No. 36/2008 regarding
related-party transactions states as follows:
The Director General of Taxes shall be authorized to re-determine the
amount of income and deduction as well as determine debts as
capital to calculate the amount of taxable income for Taxpayer
possessing special relationship with another Taxpayer, in
accordance with the Arm’s Length Principle by using the
Comparable Uncontrolled Price method, Resale Price Method, Cost
Plus Method or other methods
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Definition of Related Party
Based on Article 18 (4) part a, b, c of Income Tax Law No. 36/2008,
special relationship between tax payers exists under the following
circumstances:
Taxpayer has capital participation directly or indirectly, a
minimum of 25% (twenty five percent) at another Taxpayer (one
or more Taxpayers); or
Taxpayer controls another Taxpayer or two or more Taxpayers
are under the common control directly or indirectly; or
There is family relation both biologically and by marriage in
vertical and / or horizontal lineage of the first degree
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Related Party Transactions
The types of related party transaction to be
disclosed in the Corporate Income Tax Return consist of:
Transactions involving
Tangible Properties
Transactions involving
Capital Goods
Transfer / Utilization of
Intangible Properties
Loans
Transfer of Services
Transfer / Acquisition of
Financial Instruments
Cost Allocation
Others
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Related Party Transactions
Transfer Pricing Documentation is required for the following:
Transactions between a tax payer or Permanent Establishment in
Indonesia, and a taxpayer outside Indonesia
Transactions between two tax payers or Permanent Establishment in
Indonesia that are subject to different tax rates due to, among others:
Imposition of final and nonfinal income tax in certain
business sector
Imposition of sales tax on
luxury goods
Transactions conducted
with a taxpayer-contractor
under an Oil & Gas
Cooperation Contract
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Safe Harbor
Transfer Pricing Documentation is not required for related party
transactions with total value not exceeding IDR10 billion (approximately
US$1.1 million) in one fiscal year for each counterparty
Note: Transactions below the threshold limit
Must still be disclosed
in the Corporate
Income Tax Return
Must still comply with
the arm’s length
principle
May still be the
subject of a tax audit
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Selection of Transfer Pricing Methods
The hierarchical application of
Transfer Pricing methods has been
replaced with the ‘most
appropriate method’ approach
Transactional Net Margin Method
(TNMM) is no longer the last-resort
method and can be appropriately
applied if one of the transaction
parties performs either special
contribution or complex / closely
linked transactions
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Intangible Assets
Intangibles are assets which generally have long useful
life, have no physical form, are used in business operation,
and are not for resale
Intangible assets can be classified as:
Trade Intangibles
(e.g. patent, know-how)
Marketing Intangibles
(e.g. trademark, trade name)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Obligation to Submit TP Documentation
Submission of Transfer Pricing
No specific penalty shall apply in
Documentation along with the
case of failure to comply with the
Corporate Income Tax Return (four above
months after fiscal year-end with
two months extension) is required
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Transfer Pricing Penalties
No specific
Transfer Pricing
penalties
The following penalties apply in case of
non-payment of tax or tax
underpayment arising from Transfer
Pricing adjustments
Administrative sanction in the form of interest
at 2% per month for a maximum of 24
months on the amount of tax underpayment
in the Tax Assessment Letter (SKPKB)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Mutual Agreement Procedure (MAP)
The Indonesian Tax Authority
MAP application can be processed
issued in 2010 the regulation
simultaneously with the filing of
regarding procedure in applying for objection or appeal
a MAP
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Advance Pricing Agreement (APA)
The Indonesian Tax Authority issued in 2010 the regulation
regarding procedure in applying for an APA
Important provisions in the APA regulation:
Validity Period is three
(3) years
Submit of annual
compliance report is
required
Tax payer’s documents
and information during
the APA process shall
remain private and
confidential
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Thank you
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Philippines Scenario
Euney Marie J. Mata-Perez
Taxand Philippines
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
How Tax Avoidance
is Tackled
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Overview
Exchange of Information Regulations
No consolidated
rules on anti-tax
avoidance
Source of rules:
Legislation
Regulations
issued by the
Commissioner of
Internal Revenue
Court decisions
Revenue driven
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Access of Taxpayers Information
Exchange of Information Regulations
RA 10021: exchange of
Information Act of 2009
Prior to RA 10021:
authority of the CIR to
inquire into taxpayer’s
bank deposits is limited to
two grounds:
(1) determining estate of a
decedent, and
(2) when taxpayer files an
application for
compromise. (Exceptions
to Bank Secrecy Act)
New ground: a taxpayer
subject of request for
supply of tax information
from a foreign tax authority
pursuant to an
international convention or
agreement
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Prior Tax Treaty Relief Application
New Tax Treaty Relief Procedures
Filing of Tax Treaty Relief
Applications (TTRA) is
mandatory before a transaction
Before the occurrence of the
first taxable event
Failure of observe the period
shall have the effect of
disqualifying the TTRA
But the BIR does necessarily
act on the application, so doubt
on interpretation remains
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Additional Disclosure Requirements - FS
New Additional FS Disclosures
Disclosure on information on
taxes, duties and license fees
paid or accrued during the
year in the audited financial
statements (2010)
Some implications:
Entail additional administrative
burden
Premature or untimely
disclosure of assessments and
pending cases
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Additional Disclosure Requirements - ITR
Supplemental Information Return
Additional
attachment to ITRs
of individuals
Additional
disclosures to the
ITRS:
Requiring information on
passive and tax exempt
income
Includes final taxes
withheld on each type of
income
Basis for exemptions
clearly indicated
Difficult to comply
and implement
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Promulgation of Allocation Rules
Allocation of costs and expenses amongst
income earnings of banks and financial institutions
Rules on the allocation of
costs and expenses
among the income
earnings of banks and
financial institutions
Prescribed methods:
Specific identification
Allocation based on gross
income earnings
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Review/Reversal of Previous Interpretations
Upstream mergers
Refusal to issue rulings
that these are exempt
Further control in a taxexempt transfer to gain
control no longer tax exempt
VAT on tax-free transfers
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Taxpayer Monitoring
Requiring withholding agents to apply for TIN on behalf of
non-resident aliens not engaged in trade or business in the
Philippines
Benchmarking
Matching
Improvement of data capturing
Machine readable returns
Additional disclosures
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Challenges/Issues in
Audit Procedures
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Audit Challenges
Over-riding
New Interpretations on
Prescription
Persistent call for the
Commissioner of Internal
Technicalities on VAT
Revenue to meet increasing refunds (Aichi case)
targets
Failure to indicate details of
the transaction in the
required return is
tantamount to a non-filing of
return (10 years)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Audit Challenges
Authority to receive assessment notices
No case or regulations address the issue on the authority of a
corporation’s employee to receive assessment notices for purposes
of due process
Stricter rules on evidence
Due process
Assessment of tax-exempt entities who are making profits
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentives to
Encourage Investments
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Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentive Laws
Existing laws
No new laws
RA 7916, Special Economic Zone Act of
1995 (PEZA)
EO 226, Omnibus Investments Code (BOI)
RA 7227, Bases Conversion & Dev. Act
(BCDA)
Tourism Act
180 other laws
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
General Incentives
Income tax holiday
5% tax on gross income, in lieu of other taxes
Exemption from duties and taxes on importation of capital
equipment and raw materials
Exemption from local taxes except real property tax
Net operating loss carry-over
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Others
Amendment to the Negative List
Inclusion in the
Investments
Priorities Plan
Relaxation of nationality restriction
Generally, foreign ownership in all forms of
gambling is limited to 40%
2011 list added an exception: except those
covered by investment agreements with
PAGCOR operating in ecozones
administered by PEZA
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Recent Developments
Harmonization of Incentives
House Bill 4935
Creation of an Investment Promotion Action
Center at the Board of Investments
Various Senate Bills – for harmonization
DOF Version
Limited scope and period of incentives
Proposed
reduction of VAT
from 12% to 10%
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Thank you
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Thailand Scenario
Chinapat Visuttipat
Taxand Thailand
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
How Tax Avoidance
is Tackled
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Overview
No specific rules on anti-tax avoidance
Source of rules:
Tax
Legislations
Civil and
Commercial Code
Tax competition in the region
Court
Decisions
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Integrating System Among Three Tax Authorities
Integration with E-filing
The Revenue
Department
The Customs
Department
Bank transactions and records
Reconciliation via online data of tax filings
The Excise
Department
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Transactions in Focus of Tax Authorities
Cross-border
transactions among
related parties
Complicate and
unexplainable
transactions
Import of goods
with separation of
license
Royalties
transactions
Management and
consulting
services
Cost allocation and
reimbursable
expenses
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Anti-avoidance Tools Under Consideration
Transfer
pricing
Thin
capitalization
Controlled foreign
company
General antiavoidance rules
Treaty
shopping
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Challenges and Issues
in Audit Procedures
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Challenges in Audit Process
Time / cost and opportunity to play in the game of tax audit
When taxpayers are the
What if they lost the game
winner in game
Pizza Hut’s case (royalties
Nike’s case (customs issues taxed on marketing)
on license fee)
ABB’s case (withholding tax
Halliburton’s case (taxpoint
on subsidy fund)
on profit remittance)
SGS’s case (VAT 0% on
export of service)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Issues in Audit Process
Tax refund or not refund
Personnel in audit process: Put the right man on the
right job
Share premium is not a safe-habor
Oxychem’s case
(tax on deemed subsidy)
NEC’s case
(tax on deemed subsidy)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentives to Encourage
Investments
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentive Laws and Tax Privileges
Investment Promotion
(BOI): Tax and non-tax
3/5/8 years tax holiday
Land ownership
Foreign business restriction
Work permit and visa for
expat
Revenue Code
ROH / IPC
Entire business transfer /
Amalgamation
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Recent Developments
Corporate tax rate reduction from 30%
To 23% in 2012
To 20% in 2013 and 2014
Personal tax rate reduction from progressive tax rate
10-37% to 10-35% will be enacted in 2012
AEC full entry in 2015
Free flow of capital and labor
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Thank you
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
In-house perspective
Morrie Cheng
Sun Life Financial, Asia-Pacific Head of Tax
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Taxpayer’s perspective
• Protectionism:
• Triggered by economic circumstances
• Tax audits and assessments
• Emphasis on indirect tax
• Pendulum over swung?: e.g. indirect transfers of domestic shares
• Work in progress:
• Equilibrium: taxation and foreign direct investment
• Sustainability: forecasting, budgeting, measurement …
• Reasonableness: at least the opportunity to conclude or disagree
• Consistency and coordination among governmental functions?
Morrie Cheng 2012
• Surely, happy to dialogue!
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Internal outsourcing/offshoring
• Business transformation:
• Process improvement
• Technology
• Outsourcing/offshoring: external vs. internal (e.g. shared services
centres)
• Considerations on internal outsourcing/offshoring including:
• Strategy
• Costs including tax!
• Resources: e.g. infrastructure, talents
• Sustainability
• Benefits
Morrie Cheng 2012
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Tax considerations
• First and foremost, early involvement of tax department!
• Special regimes or special zones
• Business models: structuring, supply chain and functional analysis
• Transfer prices
• Taxation: personal taxation included?
• Tax modeling: investment, expansion/reinvestment, exit, etc.
• Treasury: thin capitalization, forex restrictions, etc.
• Indirect tax: VAT, GST, service tax and customs, etc.
• Withholding tax: dividends, royalties, service fees, etc.
Morrie Cheng 2012
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Common topics
• Start up costs
• Profit repatriation: formalities, withholding tax
• Software and hardware: customs and withholding tax
• Indirect tax: input, local consumption vs. export
• Transfer pricing “management”?
• Tax accounting and managerial performance: tax contingencies …
• Permanent establishments?
• “Sustainability of taxation”
• Staff mobility: mobile employees, assignees, etc.
• Structure maintenance and exit
Morrie Cheng 2012
• India, the Philippines, China or elsewhere?
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Doing Business in the Philippines:
Business Process Outsourcing (BPO)
Euney Marie Mata-Perez
Taxand Philippines
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Business Process Outsourcing (BPO)
BPO Background
Engineering
design
Data
transcription
Information and
communications
technology (ICT)
BPO
includes
ICT support
services
Software
development;
animation
Contact
centers
Business/
knowledge process
outsourcing
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background
Governing Law
Foreign Investments Act of 1991
General policy
No foreign equity restriction for export enterprises
Allows 100% foreign ownership in domestic market enterprise
(except those included in negative list)
BPO/IT business can be 100% foreign-owned as an export
enterprise
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background
Foreign Investments Act
of 1991
General Policy:
BPO/IT business can be 100%
foreign-owned as an export
enterprise
Common forms of
business presence
Branch
Subsidiary
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background
Volume
2011: US$11 Billion in
revenues in Philippines
638,000 or 22% more
employees in the
same period
24% higher in 2010;
21% growth in 2011
By the end of 2011
416,000 employees
US$7.4 billion in services to the world
Largest contact center hub in the world
Remained largest sector of Philippines
IT-BPO at 65% of total industry
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background
Growth Potential
By 2016 (according
to BPAP):
Philippine IT-BPO
could more than
double to US$25
billion
Equivalent to 10%
share of global
market
To meet goal,
industry must:
Accelerate its talent
development
initiatives
Obtain stronger
government support
If achieved, IT-BPO
industry could
employ up to
1.3 million Filipinos
and account of 9%
of GDP
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background
Competitive Advantages
Global leader in voice BPO (over 340,000 employees)
No. 2 destination for non-voice IT-BPO services (over 200,000
employees)
Low infrastructure and labor costs (up to 80% less than in developed
countries)
Large pool of college graduates each year (over 400,000 graduates)
Good English-speaking skills (over 70% of college graduates speak
English)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
BPO Background
Competitive Advantages
Young and fresh talent pool
Large developed Central Business Districts suitable for BPOs (2 million
square kilometers leased to BPOs)
Customer-centric, warm, and hospitable culture (positive customer
feedback)
Strong government and academe support (training and curriculum
support)
Various investment incentives
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentives
Source of Incentives
Omnibus Investments Code (EO 226)
Special Economic Zone Act of 1995 (PEZA Law)
Bases Conversion and Development Act of 1992 (BCDA Law)
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Incentives
BOI Incentives
2011 Investment Priorities Plan includes BPO activities, information
technology (IT), and IT-enabled services
IPP: minimum investment cost of USD2,500 per seat, for contact center
project
Covers cost of equipment, fixtures and fixed assets, except land
ICT Projects with project cost of USD5 million in the initial year qualifies
for pioneer status
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Current Issues
PEZA
BPO using e-commerce may be registered with PEZA for enjoyment of
incentives under the PEZA law
Must be located in an ECOZONE (including buildings)
At present, majority of the firms in the ICT industry are PEZA-registered
As of March 2012, there are 159 PEZA-registered IT Parks/Centers
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Current Issues
PEZA incentive of 5% on gross income
BIR has issued a ruling that royalties are not deductible from gross income
Allowable deductions: Direct salaries; production supervision salaries; raw
materials used in manufacture; goods in process; finished goods; supplies
and fuels used in production; depreciation of machinery and equipment;
rent and utility charges; financing charges associated with fixed assets
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Current Issues
Transfer pricing
BIR not yet so strict on transfer
pricing
Proposed transfer pricing
regulations not yet issued,
although the BIR adheres to
OECD transfer pricing guidelines
in principle
Local Governments
Since 5% tax on gross income is in
lieu of all other taxes, local
governments are reluctant to
endorse new PEZA buildings
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Thank you
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
South East Asia Panel
Presenter Profiles
www.taxand.com
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Presenter Profile
E. [email protected]
T. (632) 811-2498
Euney Marie J. Mata-Perez
Taxand Philippines
‘Euney’ Marie Mata-Perez is based in Taxand Philippines where she is a Partner
of Salvador & Associates. “Euney” has more than 19 years’ experience in tax
practice and commercial transactions. Euney specialises in tax and corporate
matters, and has extensive experience in mergers and acquisitions, infrastructure
projects, project finance and loan transactions, tax advisory work and advocacy
work involving refunds and assessments. She was previously a Senior Associate
in SyCip, Salazar, Hernandez & Gatmaitan, where she worked for more than 10
years. Euney graduated Salutatorian of her class from the Ateneo de Manila
University College of Law (1992), and summa cum laude in her undergraduate
course from the University of San Carlos, Cebu City. Euney is a Certified Public
Accountant, and worked as an auditor with SGV & Co. She has contributed to
several foreign and local publications, including CCH Doing Business in Asia, and
is a lecturer at the TAXAND Regional Junior School. At present, she is the
Executive Vice President of the Tax Management Association of the Philippines.
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Presenter Profile
E. [email protected]
T. +852 2918 3839
Morrie Cheng is Head of Tax, Asia of Sun Life Financial. He has responsibility for
Sun Life's tax function in Asia. Mr. Cheng joined Sun Life in 2008.
Morrie Cheng
Asia-Pacific Head of Tax
Sun Life Financial
Mr. Cheng has a wide range of international tax and insurance tax experience
including Associate Asia Tax Director at Swiss Re and Regional Head of Tax at
Henkel.
Mr. Cheng holds a Bachelor of Arts in Accountancy from City University of Hong
Kong and is a qualified chartered accountant.
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Presenter Profile
E. [email protected]
T. +62 21 835 6363
Permana Adi Saputra
Taxand Indonesia
Permana Adi Saputra is based in Taxand Indonesia where he serves as a
Transfer Pricing Partner with PB Taxand. Permana’s experience includes
assisting clients with the preparation of transfer pricing documentation,
representing clients in tax audit, tax objection and appeals related to transfer
pricing cases, and assisting clients in applying for Advance Pricing Agreements.
His expertise also includes supply chain management and price / profit
structuring. Permana actively participates in discussions with Tax Officers
regarding transfer pricing issues. Permana is also very active in conducting inhouse Transfer Pricing seminars and workshops in for businesses as well as
taking part in the local and international Transfer Pricing Summit. Permana started
his career in 1992 as a government auditor and worked for more than 6 years with
the Ministry of Finance - Republic of Indonesia. Permana then worked for Deloitte
before joining PB Taxand to establish the Transfer Pricing Division.
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
Presenter Profile
E. [email protected]
T. +66 (0) 2 632 1800
Chinapat Visuttipat
Taxand Thailand
Chinapat Visuttipat is based in Taxand Thailand where he is a Partner / Director
and the head of Tax Services at HNP Counsellors Ltd – Taxand Thailand.
Chinapat has more than 20 years of experience in tax and legal advising
multinationals on corporate and commercial contracts, cross-border transactions,
hotel and property, M&A and transactional tax, private equity fund, tax audit
supports as well as tax litigation including tax planning for inbound and outbound
investment. He is now a visiting lecturer for the master degrees tax program at
both state and private universities in Thailand and has presenting at several
public tax seminars and conferences. Chinapat has contributed to many
international and local publications on tax, including International Tax Review and
Bloomberg BusinessWeek Thailand. At present, Chinapat is a member of Tax
Committee under the Thai Chamber of Commerce and Board of Trade of Thailand
including Tax Mediator under the Central Tax Court.
Asia Tax Forum
May 9-10, 2012 – Raffles, Singapore
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Taxand is a global organisation of tax advisory firms. Each firm in each country is a separate and independent legal entity responsible for
delivering client services.
© Copyright Taxand Economic Interest Grouping 2011
Registered office: 1B Heienhaff, L-1736 Senningerberg – RCS Luxembourg C68

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