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20240422 Mutual Agreement Procedure and Advance Pricing Arrangement Developments in Hong Kong SAR

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Programme Code:
20240422
Date:
22 四月 2024 (Monday)
Time:
6:30 pm - 8:00 pm
Speakers:

Ms Cecilia Lee, Partner, Transfer Pricing Services, PwC Hong Kong

Ms Tiffany Wu, Partner, Transfer Pricing Services, PwC Hong Kong

Language:
Cantonese
Venue:
Live webinar
Proficiency Level:
Advanced Level
Fee:
$150 – $200
CPD Hours:
1.5
Seat:
100
Event Categories:
,
Application Form:
20240422 enrolment form

Description

Under the current challenging tax and economic environment, there has been a growing number and size of tax disputes between multinational enterprises (MNEs) and tax authorities globally in recent periods. As a dispute resolution mechanism, Mutual Agreement Procedure (MAP) has been proven to be an effective mean in resolving cross-border double taxation issues in tax disputes. Recently, we have assisted an MNE client in the conclusion of the first Hong Kong SAR (Hong Kong) – Chinese Mainland MAP case in Hong Kong relating to Transfer Pricing (TP) dispute since the release of MAP guidance by the Hong Kong Inland Revenue Department (HKIRD). We have achieved a corresponding adjustment and obtained a substantial tax refund from the HKIRD, which is a very encouraging outcome to all taxpayers.

Meanwhile, Advance Pricing Arrangement (APA) provides a mechanism for taxpayers to obtain tax certainty for future (and historical) years, which could also reduce the incidence of double taxation and costs associated with audit defence in tax controversies.

In this seminar, we will share our insights and experience in dealing with MAP and APA cases in Hong Kong and Chinese Mainland. Particularly, we will cover the recent success story of our MNE client in MAP application in Hong Kong, the benefits of engaging in MAP, and the key considerations in the application process:

Highlights of the seminar

  • Latest development of MAP in Hong Kong
  • MAP application – our success story
  • Key considerations to a successful MAP application
  • How APA can help manage TP risk and obtain tax certainty

Speaker Profile

Ms Cecilia Lee, Partner, Transfer Pricing Services, PwC Hong Kong

Cecilia Lee is a transfer pricing partner at PwC China/HK and currently leads the Hong Kong transfer pricing practice. She has over 25 years of transfer pricing experience, including over 11 years in the US prior to her joining the PwC China/HK TP practice.  Cecilia is the Asia Pacific Champion Partner for the Global Coordinated Documentation committee within PwC.  She has also been deeply involved in providing advocacy to the HK Inland Revenue during the codification of the Hong Kong Transfer Pricing legislation Inland Revenue (Amendment) (No. 6) Ordinance and all subsequent guidance.

She currently advises clients on transfer pricing value chain restructuring and intangible property valuation matters from the China, Hong Kong and Asia Pacific regional perspectives. She has successfully assisted in concluding China’s first APA on Cost Sharing Arrangement for a multinational company.  She has assisted in dispute resolution matters with the Chinese Tax Authorities covering cases in Beijing, Guangzhou, Shenzhen and Yangzhou.  She also advises clients with ongoing transfer pricing disputes with the Hong Kong Inland Revenue Department.

Cecilia has served clients in various industries including technology (semiconductor, software, electronics, telecommunications), consumer products, services, real estate and manufacturing.  Cecilia’s experience includes BEPS related restructuring and CbCR risk assessment where she supports MNCs in their pursuit to risk manage their tax structures in light of heightened transparency.

During early 2000, Cecilia completed a tour of duty in the San Jose, California office of the PwC US firm where she advised clients from the technology sector on intangible property structuring.

Cecilia is a frequent speaker at tax seminars with clients, professional organizations and tax authorities, and has contributed to professional publications.  She is a taxation faculty of the China Tax Support Group of HKICPA.

Ms Tiffany Wu, Partner, Transfer Pricing Services, PwC Hong Kong

Tiffany is a Partner at PwC Hong Kong specialising in providing transfer pricing services for multinational clients for over 15 years.

​​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), etc. ​

Tiffany has served a broad spectrum of multinational corporations in various industries including chemicals, TMT, electronics, new energy, consumer goods, logistics and transportation, etc. ​

Tiffany has extensive experience in handling TP dispute resolution, APA and MAP in Hong Kong and Chinese Mainland. She has assisted in concluding the first Cost Sharing Arrangement (CSA) APA in Chinese Mainland for a Fortune 500 company and assisted to conclude the first TP MAP between Hong Kong and Chinese Mainland.​

Tiffany is a frequent speaker at tax seminars with clients, professional organizations and chambers, and has contributed to professional publications.

​​Tiffany is a member of Hong Kong Institute of Certified Public Accountant. She holds a master degree in Economics and a bachelor degree in Finance.

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