PRC M&A and IPO tax structuring - Workshop 2018

Identifier: 80005153

Duration: 2 hours

Language: Cantonese

Cost:

Action

Overview

In recent years, State Administration of Taxation (“SAT”) provided more clarifications on the equity transfer rule which has impacts to the M&A and IPO markets. In October 2017, the SAT provides more guidance on the timing of withholding for equity transfer. It brings many impacts to the foreign investors when they consider to transfer/dispose their PRC investments.

In addition, China SAT recently issued Public Notice 9 to give clearer guidance for the determination of “Beneficial Ownership” and updated the interpretation of a few tax treaty articles under the double taxation agreements concluded by China by issuing Public Notice 11.

In this workshop, gain an understanding on the recent PRC tax anti-avoidance enforcement environment as well as some insights on how to review and improve investment structures from PRC tax perspective.


Key topics covered:

  • New Circulars recently issued in relation to equity transfer in the China including indirect transfer rule and new Rules on Corporate Income Tax for Non-TREs Bringing Significant Changes in the Timing of Withholding
  • Impact in deal negotiations, key issues and solutions arising from PN 7
  • New Circulars recently issued in relation to Beneficial Ownership and new interpretation of a few tax treaty articles under the double taxation agreements concluded by China
  • Local practice and interaction with the PRC tax authorities
  • Real life cases sharing


Trainer profile:

Jeremy Ngai, China South Tax Leader and China/Hong Kong M&A Tax Leader, PwC

Jeremy has extensive experience in advising foreign investors in their inbound investment and M&A strategies into China. With more than 20 years of experience in PRC tax and business advisory, Jeremy has been assisting clients to devise, plan and implement tax efficient holding and operational structures for traditional and alternative (private equity, hedge, real estate, infrastructure etc) funds with their expansion in China. He is also a frequent speaker in various seminars and conferences in China tax, regulatory and M&A topics held in China, Hong Kong, Singapore, and Europe.

Objectives

  • Gain an understanding on the recent PRC tax anti-avoidance enforcement environment as well as some
  • Discover insights on how to review and improve the current and/or contemplated investment structure from PRC tax perspective

Audience

This workshop is suitable for commercial accountants, auditors and tax professionals.

Course Structure

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