|Programme Code :||20200208_29|
|Event Date :||29 February 2020 (Saturday)|
|Time :||09:30am-12:30pm (9 : 00 am registration)|
|Venue :||20/F Tai Yau Building, 181 Johnston Road, Wanchai, Hong Kong||View google map|
|Speakers :||Mr Philip Hung, Ms Karen Au and Mr Felix Tsang|
|CPD Credit :||3 hrs|
|Proficiency Level :||Intermediate Level|
|Document :||TIHK Intl Tax Law and Practice_Special Offer_Learning and Reading_Nov19-Feb20_v2.pdf|
|Fee :||N/A for TIHK member / student
N/A for Non-member
N/A for members of organizations of CPD Alliance
The courses is structured based on most recent IRD development in Tax Audit approach
The Hong Kong Inland Revenue Department’s (“IRD”) practice in conducting tax audits are constantly evolving. In particular, the officers’ views on offshore claims and cross-border related party transactions are tightening with the recent developments in global environment in BEPS and BEPS 2.0, combating double non-taxation. Which have impacted on the attitudes and tactics adopted by the officers when handling tax audits, particularly at the initial interviews. As such, newstrategies are required when handling tax audits nowadays. Special care has to be taken to avoid making unnecessary mistakes,which will be costly to both taxpayers and practitioners. In this course, our following speakers will use a practical step-by-step approach to demonstrate different strategies and ways to handle tax audits, and will take the participants through the journey from cradle to the final resolution.
1. Recent developments in tax audits.
2. Structure of the IRD’s tax audit team and its importance to a settlement.
3. How does IRD select files for review?
4. IRD review procedures, from initial interviews to settlement interviews.
5. How to prepare for an initial interview?
6. Mock interview
7. Things to note during an initial interview.
8. How to amend an initial interview note.
1. Explore different strategies to the tax audit case after interview.
2. Ways and methods to help taxpayers to substantiate their cases.
3. Points to note when providing additional information to IRD.
4. Common error in handling tax audit case
5. How IRD considers the penalty of a taxpayer.
6. IRD’s prosecution cases.
1. Explore different settlement strategies.
2. IRD’s approach in a settlement interview and how to prepare for it.
3. How to reach a settlement with IRD or otherwise.
4. Explore different ways to mitigate IRD penalty.
5. Explore how a particular tax audit case can be handled differently.
6. Explore different settlement negotiation tactics.
1. Case studies, covering issues such as :-
a. Offshore claims
b. Transfer pricing
d. Fund management
e. Evasion cases
f. Avoidance cases
2. Questions and answer
Philip has over 30 years' experience in Hong Kong taxation with six years in IRD. He is a well-known expert in the tax field and investigation specialty. After he left the IRD, Philip concentrated in assisting clients in handling tax investigation and field audit cases. He is the first to set up a specialized team to handle the IRD’s tax investigation and field audit cases for clients in the industry. His clients include fund managers, SME, listed companies and various MNC. He assisted in handling complicated cases such as worldwide onshore/offshore claim, disputes on contracting processing and import processing arrangements, offshore claim for Macao Offshore Company, IRD prosecution case and transfer pricing manipulation.
- Ms Karen Au, Partner, Tax Controversy Services, PwC Hong Kong
Ms. Karen Au has over 15 years professional experience in the taxation field and extensive experience in assisting clients to resolve tax disputes with the IRD and focusing on tax audit and investigation, with clients from multi-national and local companies, particularly those in the industries of apparel and electronic manufacturing, pharmaceutical, general trading, sourcing, financial services and asset management. She also assists corporates and individuals in dealing with pro-longed tax disputes and conducting various tax review such as group restructuring, inter-company fee arrangement and post implementation health check using tax audit methodology.
- Mr Felix Tsang, Senior Manager, Tax Controversy Services, PwC Hong Kong
Felix has over 15 years of experience in handling tax audits for multinational as well as local clients in different industries, including manufacturing, services and fund management, involving a diverse range of issues such as cross-border transactions, offshore claims, anti-avoidance and transfer pricing. Felix also has extensive experience on tax advisory projects including tax health check, defence file building, post-audit restructuring, fund set up, mergers and acquisitions.