Past Seminars / Events
Programme Code : 20190123
Event Date : 23 January 2019 (Wednesday)
Time : 6:45pm - 8:45pm (6:15pm registration)
Venue : PwC Executive Conference Centre, 21/F Edinburgh Tower, 15 Queen’s Road Central, Hong Kong View google map
Speakers : Mr Raymond Wong and Mr Parken Tai
Language : Cantonese
CPD Credit : 2 hrs
Proficiency Level : Intermediate Level
Fee : HK $ 250 for TIHK member / student
HK $ 350 for Non-member
HK $ 300 for members of organizations of CPD Alliance

International Tax Treaty Seminar Series: Lecture 2: Corporate Tax II

This is the second lecture of the International Tax Treaty Seminar Series organised by the Institute. The International Tax Treaty Seminar Series aims at helping the participants to understand the key international tax concepts and treaty articles, application of tax treaties and practical international tax planning with respect to cross-border transactions. It consists of the following four lectures:

Lecture 1: International Tax: Corporate Tax I (already held)
Lecture 2: International Tax: Corporate Tax II (to be held on 23 January 2019)
Lecture 3: International Tax: Individual Tax (coming soon)
Lecture 4: International Tax: Planning and Application (coming soon)

The second lecture will focus on treaty articles dealing with passive income, double tax relief and exchange of information.

Details of Lecture 2 – International Tax: Corporate Tax II

1.  Principal articles in a typical double taxation agreement – Lecture 2 will focus on the following articles:

  • Article 10: Dividends
  • Article 11: Interest
  • Article 12: Royalties
  • Article 13: Capital Gains
  • Article 21: Methods of Elimination of Double Taxation
  • Article 24: Exchange of Information

2.  The concept of beneficial ownership
3.  Case Studies
4.  Q & A


A glance of Lectures 3 and 4

Lecture 3 – International Tax: Individual Income Tax

1.  Principal articles in a typical double taxation agreement – Lecture 3 will focus primarily on the following areas which related to individual income arising from cross-border economic activities between 2 jurisdictions:
  Income from employment
 Director’s fees
  Artistes and sportsmen
  Methods for elimination of double taxation
2. Case Studies

3. Q & A

Lecture 4 – International Tax Planning and Application

1. International Tax Planning and Application: the Past
2. The latest development, covering:

  OECD Model Tax Convention
  Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
  Transfer Pricing Guidelines
 Convention on Mutual Administrative Assistance in Tax Matters
  Unilateral measures
 Tax incentives
3. Case Studies

4. Q & A

Speaker Profile Content :
1. Mr Raymond Wong, Director, National Tax Policy Services, PwC Hong Kong

Raymond Wong has more than thirty years of tax experience (including Hong Kong, China and cross-border investment). He is the National Tax Policy Services director of PricewaterhouseCoopers – Hong Kong.
Raymond graduated with distinction from the University of Alberta and is a member of the Canadian Institute of Chartered Accountants.

2. Mr Parken Tai, Senior Tax Director, Asia Pacific and China, TE Connectivity Limited

Parken has more than 25 years of tax experiences gained in the United States, Canada and Hong Kong. Parken is also the Chairman of the International Tax Committee of the Taxation Institute of Hong Kong.