Dispute Resolution How to avoid; How to settle

Dispute ResolutionHow to avoid; How to settle

9-10 May 2012

Chair: Mukesh Butani – Taxand IndiaPanellists:

Michael Palumbo, Asia Head of Tax – Baker Hughes Leon Kwong Wing – Taxand Singapore

1. Appeals mechanisms in Asia-Pacific; Are they working?

2. How to prepare if you are caught in a dispute

3. When a settlement is the best option

4. Tactics for jurisdictions where litigation is most likely

5. Lessons from key cases: Hong Kong cases of Li & Fung; CG Lighting and Nice Cheer Investment Limited; Singapore’s First Section 33 Case

6. Key Contacts

7. About Taxand

Contents

Appeals mechanisms; Are they working?31 Appeals mechanisms in Asia-Pacific; Are they working?

How to prepare if you are caught in a dispute42 How to prepare if you are caught in a dispute

When a settlement is the best option53 When a settlement is the best option

Tactics for jurisdictions where litigation is most likely64 Tactics for jurisdictions where litigation is most likely

Hong Kong cases of Li & Fung

CG Lighting and Nice Cheer Investment Limited

Singapore’s First Section 33 Case

...

Lessons from key cases75 Lessons from key cases

Key Contacts Key Contacts 86

Mukesh ButaniTaxand IndiaE. [email protected]. +91 124 339 5010  

Michael PalumboBaker HughesE. [email protected]. +65 9780 1615

Name TBCFirm nameE. [email protected]. + Direct line number

Leon Kwong WingTaxand SingaporeE. [email protected]. +65 6238 3018

Name TBCFirm nameE. [email protected]. + Direct line number

Name TBCFirm nameE. [email protected]. + Direct line number

Global CoverageAbout Taxand 97

Argentina India Poland

Australia Indonesia Portugal

Austria Ireland Puerto Rico

Belgium Italy Romania

Brazil Japan Russia

Canada Korea Singapore

Chile Luxembourg South Africa

China Malaysia Spain

Colombia Malta Sweden

Cyprus Mauritius Switzerland

Curacao Mexico Thailand

Denmark Netherlands Turkey

Finland Norway UK

France Pakistan Ukraine

Germany Panama USA

Greece Peru Venezuela

Hungary Philippines

Understanding and managing the tax consequences of cross-border tax transactions

Considering organisational (re)structuring options in full awareness of the tax implications

Realising tax, supply chain and overall operational efficiencies

Interpreting technical tax provisions

Lowering effective tax rates

Addressing and preventing tax leakages

Ensuring tax compliance

Managing relationships with tax authorities

Our Global Service Commitment107 About Taxand

Dedicated to tax

Independence advantage – conflict free, un-bureaucratic, best practice

Local knowledge, global view

Partner led from start to finish

Complex problems, customised advice

Passionate about working together

Practical advice, responsively delivered

Why Taxand?117 About Taxand

ABOUT TAXAND

Taxand provides high quality, integrated tax advice worldwide. Our tax professionals, nearly 400 tax partners and over 2,000 tax advisors in 50 countries - grasp both the fine points of tax and the broader strategic implications, helping you mitigate risk, manage your tax burden and drive the performance of your business.

We're passionate about tax. We collaborate and share knowledge, capitalising on our collective expertise to provide you with high quality, tailored advice that helps relieve the pressures associated with making complex tax decisions.

We're also independent—ensuring that you adhere both to best practice and to tax law and that we remain free from time-consuming audit-based conflict checks. This enables us to deliver practical advice, responsively.

Taxand is a global organisation of tax advisory firms. Each firm in each country is a separate and independent legal entity responsible for delivering client services.

© Copyright Taxand Economic Interest Grouping 2012Registered office: 1B Heienhaff, L-1736 Senningerberg – RCS Luxembourg C68

Event Speaker Guidelines

9-10 May 2012

Each presentation should:

be interesting for our key audiences – CFOs & Tax Directors of multinationals – ask your clients what they’d like to head about...

be topical, share Taxand opinion (Taxand’s Take) on the impact of the tax issue(s) for multinationals, forecasting future change

include at least 1 golden nugget/action for clients to take away

use case studies to add colour – co-presented with a client where possible

Content Development141 Speaker Guidelines

Each presentation should:

provide a global picture where possible to reflect our global capability

showcase our service lines capability

be different – eg consider conducting a survey across Taxanders to substantiate a view

Content Development151 Speaker Guidelines

Each presentation should have:

beginning – say what you are going to say – introduction

middle – say it – the detail

end – say it again – conclusions / action points

Appendices:

should not be presented but provided to add depth to the delegate pack, which includes the full presentation and additional materials

Structure161 Speaker Guidelines

Include biographies and contact details of speakers and relevant global Taxand teams

provide added value material eg full findings of surveys; additional case studies; details supporting the slides

see credentials on the Taxand Brand Centre: www.taxand.com/brandcentre for sample supporting slides

Structure171 Speaker Guidelines

Use the Taxand events presentation template at www.taxand.com/brandcentre to build your presentation

Every slide must contain 3 to 6 bullet points ONLY

Text should be a MINIMUM of 28 point font – Arial

Charts and objects should be clear

Use the Taxand colour palette and colour scheme objects provided

Format 181 Speaker Guidelines

Make sure you complete the black & blue title bar (see above) in this PowerPoint template with your section number and section title

For an hour’s presentation do no more than 30 slides (2 minutes per slide)

Don’t go overboard on bullets – use pictures to add interest

Keep sentences short – use clear language, highlight key points & summarise

Format191 Speaker Guidelines

To ensure quality presentations – plan ahead:

Draft structure of presentations

Arrange phone call or meeting of speakers to discuss presentation content & deadlines for drafts:

First full draft; Second full draft; Final draft

– Arrange timed speaker rehearsal by phone

– Leave time to correctly and consistently format slides so they are on Taxand brand

– Arrange on-site speaker rehearsal

Process201 Speaker Guidelines

You are representing Taxand to:

• Develop business opportunities for you, your firm and Taxand

• Raise your personal profile

• Raise our global brand awareness

So please:

• Introduce yourself as a Taxander

• Refer to your Taxand colleagues when you can by name

And Remember...211 Speaker Guidelines

• Promote our global capability, high quality and excellence

• Make sure your presentation gets sent to Lynne at [email protected] to be promoted on taxand.com

• Give it your all and go for it!

• Please refer any queries to global marketing at [email protected]

And Remember...221 Speaker Guidelines

Key Contacts Speaker Guidelines 231

Abbie TarrenE. [email protected]. + 44 207 715 5243M. +44 750 801 6931

Lynne SandlandE. [email protected]. + 44 207 072 3251M. +44 752 590 6259

ABOUT TAXAND

Taxand provides high quality, integrated tax advice worldwide. Our tax professionals, nearly 400 tax partners and over 2,000 tax advisors in 50 countries - grasp both the fine points of tax and the broader strategic implications, helping you mitigate risk, manage your tax burden and drive the performance of your business.

We're passionate about tax. We collaborate and share knowledge, capitalising on our collective expertise to provide you with high quality, tailored advice that helps relieve the pressures associated with making complex tax decisions.

We're also independent—ensuring that you adhere both to best practice and to tax law and that we remain free from time-consuming audit-based conflict checks. This enables us to deliver practical advice, responsively.

Taxand is a global organisation of tax advisory firms. Each firm in each country is a separate and independent legal entity responsible for delivering client services.

© Copyright Taxand Economic Interest Grouping 2012Registered office: 1B Heienhaff, L-1736 Senningerberg – RCS Luxembourg C68