Registration Form - CCH Malaysia

Withholding Tax & Cross Border Transactions
Practical Issues & Planning Approaches Explained
9 & 10 September 2009 • 9.00am – 5.00pm • Traders Hotel, Penang
16 & 17 September 2009 • 9.00am – 5.00pm • Prince Hotel, Kuala Lumpur
HRDF-SBL
CLAIMABLE
The tax issues connected to transactions on a cross
border basis can be complicated and tedious.
These range from withholding tax implications to
tax treatment of “foreign source income” and the
connected expenses as well as the consequences
of sales of assets between controlled parties, to
name a few. CCH Executive Events presents a
2-day workshop to help you navigate through the
maze of withholding tax and cross border
transactions. It will also examine in detail
important areas to be considered in order to
ensure that the tax affairs of the relevant parties
engaged in cross border transactions are
adequately managed. Illustrated with numerous
case studies, you will walk away with a sound
understanding of key issues and learn how to apply
the tax laws to practical scenarios in your business.
Programme Outline
HIGHLIGHTS
Interactive Discussions
Practical Examples
Case Studies
Who Should Attend
Chief Executive Officers/Chief Financial
Officers
Regional Tax Directors/Managers
Financial Controllers/Managers, Accountants
Compliance Officers
Workshop Leader
Harvindar Singh,
Managing Partner, Harvey & Associates
Havinder has 15 years of experience in taxation
gained at two of the largest accountancy firms in
the world, PricewaterhouseCoopers and Ernst &
Young. His professional experience ranges from
advising on the tax implications of cross border
transactions (inbound and outbound investments),
international tax planning and structuring, tax
audits and investigations, tax incentives
applications, tax due diligence reviews, financing
transactions including Islamic financing schemes,
advising on transfer pricing issues, corporate and
personal tax planning, Sarbanes-Oxley tax
documentation review as well as tax compliance
matters.
CCH Reference Material
Effective tax planning can be achieved by
understanding the tax compliance
environment including taxation laws, transfer
pricing issues as well as tax planning
strategies as a whole. CCH provides you an
informative range of resources which help
you and your organisations in making
decisions in tax compliance issues.
• Essential Tax Planning Strategies in
Malaysia
• Asia Tax Planning and Compliance
• Asia Transfer Pricing
To find out more about these products and
CCH’s resource offerings, kindly email you
request to mktg@cch.com.my
Day 1: Fundamentals Explained
Income tax rules on withholding tax for payments made to
Non-Residents
The determination of tax residence status of companies and
individuals
Types of income subject to withholding tax
Special classes of income under Section 4A of the Income Tax
Act, 1967
Interest payments
Royalties
Contract payments
Payment of dividends by Real Estate Investment Trusts
The application of Section 109B of the Income Tax Act, 1967
vs Section 107A of the Income Tax Act, 1967 for payments
made to Non-Residents by Malaysian residents– the
difference between the two and how it is applied in practice
Derivation rules on various types of income – Malaysian
sourced vs foreign sourced income
Cross Border investments
Inbound investments
Branch / incorporated companies
Regulatory approvals
Outbound investments
Legal entity – branch / incorporated company
Holding structures 2
Determination of Permanent Establishments and the income
tax implications Case studies
Day 2: Advanced Aspects
Withholding Tax and Permanent Establishments - A detailed
discussion
Double Tax Agreements and Bilateral Tax Credits / Double
Taxation Relief
Tax treatment for cross border sale / purchase of assets
Offshore holding companies and tax optimum structures
Transfer Pricing and cross border transactions
Introduction of Advance Pricing Arrangements
Withholding tax on Section 4(f) income - commissions,
guarantee fees, loan arrangement fees
Thin Capitalisation Rules
Case studies