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SGATAR

About The 2004 SGATAR Seminar on Tax Treaties & Transfer Pricing

Date: 2004.9.7 – 2004.9.16
Instructors

 

Background

Recognizing that SGATAR was established with a view to the reform and development of overall tax policies through mutual exchange knowledge and experience in relation to tax administration and also to reinforce the unity among the thirteen members in the Asia-Pacific region, the Ministry of Finance Training Institute of Chinese Taipei (hereinafter referred to as MOFTI) has developed a training program entitled “2004 SGATAR Seminars on Tax Treaty & Transfer Pricing” in order to help further promote awareness of related tax issues in SGATAR economies. Chinese Taipei’s proposal in providing such training program received support and recognition at the 2nd Meeting of Heads of SGATAR Training Institutions on May 11-13, 2004 in Shanghai.


Objective

The aim of the “2004 SGATAR Seminars on Tax Treaty & Transfer Pricing” is to provide participants (tax administrators) of SGATAR economies with an effective channel to learn of the application of tax treaties and taxation on transfer pricing as well as a location in which to exchange views through face-to-face interaction.


Participants

Each SGATAR member may nominate two tax officers to participate in the 2004 Seminars on Tax Treaty & Transfer Pricing. Chinese Taipei will be providing approximately 12 participants.


Duration

The 10-day program is scheduled to progress from 7 September to 16 September, 2004.


Venue

The Training Institute, Ministry of Finance (MOFTI), Chinese Taipei.


Location

#11, Lane 142, Section 6, Roosevelt Road, Taipei.


Language

The courses will be conducted in English.


Methodology

The course will be conducted in the form of plenary sessions and group activities


Evaluation

Participants will be requested to evaluate the benefits received from the 10-day program. They are also welcome to make suggestions for future improvements. Each SGATAR economy is invited to select a representative from its participants to make an oral presentation in the Seminar for 15 minutes on the achievements and experiences in their economy concerning the incorporation of transfer pricing taxation and tax treaties into domestic laws and local regulatory system as well as issues related to their practical implementation. In case that the contents of the oral presentation are stored in an electronic file as in slide form, please send the file to the contact persons by e-mail.


Class Hours

Each class meets by 90- minute units from 9:10 a.m. to 4:20 p.m., from Monday to Friday. The lunch break is scheduled for one and a half hours.

 

Day

Time

Topic

Tuesday, 7 September (Day 1)

Morning

10:00-12:00

?

Registration

Afternoon

13:30-15:20

?

Welcome Ceremony/Orientation

Wednesday, 8 September (Day 2)

Morning

9:10-10:00

?

Overview of tax treaties

10:00-12:00

Permanent Establishments

Afternoon

13:30-15:20

Application of Permanent Establishment Definition in relation to e-commerce

Income Attributable to Permanent Establishments

Thursday, 9 September (Day 3)

Morning

10:10-12:00

Continuation of presentations and discussions on Income Attributable to Permanent Establishments Royalties:

Afternoon

13:30-16:20

?

Application of Tax Treaties to Trusts and Investment Funds

Friday, 10 September (Day 4)

Morning

9:10-12:00

Anti- Tax Avoidance & Application of Beneficial Ownership Requirements in Tax Treaties

Afternoon

13:30-

Study Tour

Saturday, 11 September (Day 5)

?

?

Study Tour

Sunday, 12 September (Day 6)

?

Study Tour to the National Palace Museum

Monday, 13 September (Day 7)

Morning

10:10-12:00

Overview of Transfer Pricing Issues

Afternoon

13:30-16:20

Functional Analysis and Comparability Analysis (theory and Application)

Tuesday, 14 September (Day 8)

Morning

10:10-12:00

Risk Assessment

Afternoon

13:30-16:20

Intra- group Services and Cost Sharing Arrangements

Wednesday, 15 September (Day 9)

Morning

9:10-12:00

Financial Instruments and Global Trading

Afternoon

13:30-16:20

Visit

Thursday, 16 September (Day 10)

Morning

10:10-12:00

Discussion and Experiences exchange

Afternoon

14:00-

Closing Ceremony