Session F: The fifth M of 4M management

To optimise profit, the industrial sector focusses on the 4M, manpower, machinery, money, and methods. Today, the fifth ‘M’ has emerged that cannot be ignored by industrial enterprises: mandatory laws and regulations and their interpretations.

Challenges from this fifth M will continue to grow, and the number inspections by authorities is expected to jump dramatically. Because of this, we’ll focus on the fifth M’s impacts on the 4M that have high exposure to penalties. We’ll also explore common pitfalls and potential solutions for defending your 4M decisions in the event of an inspection.

The main topics will be the misuse of machinery under Board of Investment promoted projects – a common mistake made by majority foreign-owned businesses – and typical manpower issues under employment laws.

For more information

Please call +66 (0) 2344 1000 and speak to

Khun Kanphassorn ext. 4206; Khun Kanoknok ext. 4203;Khun Sariya ext. 4239; or Khun Supattra ext. 4207

Event Details:

Date: 27 October 2015

Venue: Shangri-La Hotel

Who should attend:

Chief Financial Officer; Finance & Accounting Director; Tax Director; Financial Controller; Human Resources Director; Tax Lawyer

Language: All sessions will be conducted in Thai.

Dress code: Business

© 2015 PricewaterhouseCoopers Legal & Tax Consultants Ltd. All rights reserved. 'PricewaterhouseCoopers' and/or 'PwC' refers to the individual members of the PricewaterhouseCoopers organisation in Thailand, each of which is a separate and independent legal entity. Please see www.pwc.com/structure for further details.

Session E: How to Manage Transfer Pricing Risk: A Continuing Process

One of the notable changes if the recently approved draft transfer pricing regulations by the Cabinet was passed into law is the mandatory requirement to make transfer pricing disclosure at the time of tax filing. When information on related party transactions are disclosed, the companies' existing transfer pricing risks would be uncovered. Transfer pricing documentation is one of the tools used to mitigate the risks. But transfer pricing documentation is at the end of a continuing process for managing transfer pricing risks. It is now more crucial than ever before for people involved in the tax function to have the holistic picture of transfer risk management process. This will enable you to be in a better position to spot and assess transfer pricing risks that may exist and take necessary corrective actions to improve your company’s transfer pricing compliance early on.

During the session, we will walk you through the process for managing transfer pricing risk. We will also go through recent transfer pricing investigation cases to demonstrate challenges made by the Revenue Department on transfer pricing issues to give you a feel of what to look for when assessing the level of your transfer pricing compliance.

October 2015

Shangri-La Hotel

www.pwc.com/th

17th Annual Conference

Maximise Shareholder Value 2016

27

Preparing yourself for a compliance review by the authorities

Remark: This seminar can count towards CPD hours for both accountants and CPA (subject to confirmation by the relevant authorities)

PwC Tax Panel

Our panel of tax partners will discuss the potential impacts on business, provide insights on what can be expected during times of changes, and examine the tools you will need as a business leader to manage the challenges and opportunities that companies may face.

Session C: Are you using the correct VAT documentation?

There are many pitfalls when it comes to preparing and maintaining VAT documentation. And the tax authority is becoming increasingly aggressive when it comes to tax collection and tax audits. The VAT law strictly requires various documents to be prepared and issued.

All too often taxpayers don’t pay proper attention to documents or, their accounting system just isn’t flexible enough to generate the documents required by law. This can cause some unpleasant surprises if detected by revenue officers. And solving issues relating to VAT compliance following any misunderstanding or lack of knowledge of the tax regulations can be time-consuming and costly.

What’s needed is a clear understanding of the tax regulations and how to comply. This session will introduce you to the required VAT documentation and key information necessary for the taxpayer to understand the correct tax treatment. For example, the correct VAT rate to use - is it 0% or 7%? And there are other issues relating to things such as tax invoices, credit/debit notes, and unclaimed input tax.

We’ll share our experiences and explain the most common issues and challenges raised by the Revenue Department. Because we believe getting your tax compliance right is of prime importance to you. And it’ll allow you to reduce the burden on your operation when dealing with the revenue officers, leaving you more time to spend on effective, strategic tax planning.

Synopsis Session A: International payments – easing the compliance burden for companies

Thailand subsidiaries of multinational companies frequently make payments to related parties. These may be in the form of management fees, shared costs for services such as research and development, royalties, IT support payments etc.

Cross-border payments to related parties are a favourite target of the Revenue Department during tax audits. The deductibility of such payments for corporate income tax will be challenged. Compliance with withholding tax and VAT requirements will also be scrutinised.

The surge in offshore investments by Thai companies also gives rise to similar challenges. Costs recharged to overseas subsidiaries may be subject to similar scrutiny by the tax authorities in those jurisdictions. There is also the question of how to manage recovery of withholding tax imposed in another jurisdiction.

Addressing these issues, particularly in a tax audit environment, can result in large scale investment of time and resources. Forward planning and the implementation of robust systems can substantially reduce the potential costs.

In this session, we will focus on:• Documentation and other requirements for safeguarding tax deductions.• Characterisation of payments and their withholding tax and VAT treatment.• Recovery of foreign tax credits and tax planning around double taxation relief.

Each participant has the choice of attending depending on their specific interest. Our topic experts will be in the following sessions to share their experience.

It’s your choice

The reduction in tax rates and a sluggish economy are the main reasons for the Revenue Department missing its tax collection target. Given the grim business outlook for Thailand, the Revenue Department will be facing a big challenge to meet its tax collection target for the next fiscal year. So, it’s inevitable that the frequency of tax audits will increase.

More than ever before, businesses need to understand their tax risks and must adopt the right strategies to manage their tax costs. Only by doing this will they be able to find their way effectively through the uncertain times ahead.

During this event, our subject matter experts will examine these developments and share their views on them. We believe that you’ll gain a better understanding of how the tax environment is likely to change in the coming years, and will learn how to deliver workable strategies to achieve future prosperity.

We hope you’ll find our MSV conference invaluable, and we look forward to seeing you there.

Session B: Structuring your mobility programme to embrace tax law changes in Thailand

Deploying your employees in the right locations has been critical to developing talent and growing your business, but a rapidly evolving environment in fast-growing Asian regions could pose a challenge for many employers. Recent changes such as tax developments in Thailand could impact how and where companies deploy their employees. Companies must observe these changes in order to take advantage of any incentive policies, and minimise any impact on the cost of deploying talent and related compliance risk exposure.

In this session, we’ll: - update you on the recent changes in tax, immigration, provident fund and social security regulations and practices in Thailand that

affect internationally mobile employees, and explain their impact on individual taxpayers - outline the current trend of multinational companies of transferring their internationally mobile employees under service and non-

service arrangements - highlight possible planning strategies that may help you embrace these opportunities and challenges, and- elaborate on how to structure and claim foreign tax credits in Thailand, and overcome some of the difficulties that may be faced.

Session D: Preparing for changes to the customs, excise and international trade environment – what you need to do

There have been several changes to the customs, excise and trade related regulations this year. In May, the Cabinet approved the principal of a new Excise Act, consolidating the various existing excise related laws and regulations and changing the excise tax base. In July, the Cabinet approved the amendment of Customs Act (B.E. 2469), which is the first major revision of the Act since 1929. It includes significant changes relating to statutory penalties and fines, bribes and rewards, post audit practices, and advance ruling systems, etc.

The Thai Government has also decided to (re)start its efforts and initiatives on implementing rules related to export control on dual-use items that will affect companies in various industries such as automotive, chemicals, pharmaceuticals, steel, and electronics. Feedback from the recent implementation of the Facilitation Act in July this year has been mixed. Both the private and public sectors are questioning whether or not the Act is actually ‘facilitating’ business or simply adding more work for companies and relevant government officers.

This session will give you an insight into these key changes and how they could impact your company’s operations in the short and long terms. And we’ll show you how you can best prepare for these changes to minimise their impact.

Tuesday 27 October 2015

08:00 – 08:30 Registration

08:30 – 08:50 Welcome note & Opening speech

08:50 – 09:20 Keynote speech by Revenue Department

09:20 – 10:30 PwC Tax Panel

10:30 – 11:00 Coffee Break

11:00 – 11:30 Update new laws & regulations

11:30 – 12:00 Accounting Ethics

12:00 – 13:15 Lunch

13:15 – 14:15 Breakout session 1 (Select one of these sessions)A: International payments – easing the compliance burden for companiesB: Structuring your mobility programme to embrace tax law changes in Thailand

14:30 – 15:30 Breakout session 2 (Select one of these sessions)C: Are you using the correct VAT documentation?D: Preparing for changes to the customs, excise and international trade environment – what you need to do

15:30 – 16:00 Coffee break

16:00 – 17:00 Breakout session 3 (Select one of these sessions)E: How to Manage Transfer Pricing Risk: A Continuing ProcessF: The fifth M of 4M management

AgendaAll sessions will be conducted in Thai.

Remark: This seminar can count towards CPD hours for both accountants and CPA (subject to confirmation by the relevant authorities)

PwC Tax Panel

Our panel of tax partners will discuss the potential impacts on business, provide insights on what can be expected during times of changes, and examine the tools you will need as a business leader to manage the challenges and opportunities that companies may face.

Session C: Are you using the correct VAT documentation?

There are many pitfalls when it comes to preparing and maintaining VAT documentation. And the tax authority is becoming increasingly aggressive when it comes to tax collection and tax audits. The VAT law strictly requires various documents to be prepared and issued.

All too often taxpayers don’t pay proper attention to documents or, their accounting system just isn’t flexible enough to generate the documents required by law. This can cause some unpleasant surprises if detected by revenue officers. And solving issues relating to VAT compliance following any misunderstanding or lack of knowledge of the tax regulations can be time-consuming and costly.

What’s needed is a clear understanding of the tax regulations and how to comply. This session will introduce you to the required VAT documentation and key information necessary for the taxpayer to understand the correct tax treatment. For example, the correct VAT rate to use - is it 0% or 7%? And there are other issues relating to things such as tax invoices, credit/debit notes, and unclaimed input tax.

We’ll share our experiences and explain the most common issues and challenges raised by the Revenue Department. Because we believe getting your tax compliance right is of prime importance to you. And it’ll allow you to reduce the burden on your operation when dealing with the revenue officers, leaving you more time to spend on effective, strategic tax planning.

Synopsis Session A: International payments – easing the compliance burden for companies

Thailand subsidiaries of multinational companies frequently make payments to related parties. These may be in the form of management fees, shared costs for services such as research and development, royalties, IT support payments etc.

Cross-border payments to related parties are a favourite target of the Revenue Department during tax audits. The deductibility of such payments for corporate income tax will be challenged. Compliance with withholding tax and VAT requirements will also be scrutinised.

The surge in offshore investments by Thai companies also gives rise to similar challenges. Costs recharged to overseas subsidiaries may be subject to similar scrutiny by the tax authorities in those jurisdictions. There is also the question of how to manage recovery of withholding tax imposed in another jurisdiction.

Addressing these issues, particularly in a tax audit environment, can result in large scale investment of time and resources. Forward planning and the implementation of robust systems can substantially reduce the potential costs.

In this session, we will focus on:• Documentation and other requirements for safeguarding tax deductions.• Characterisation of payments and their withholding tax and VAT treatment.• Recovery of foreign tax credits and tax planning around double taxation relief.

Each participant has the choice of attending depending on their specific interest. Our topic experts will be in the following sessions to share their experience.

It’s your choice

The reduction in tax rates and a sluggish economy are the main reasons for the Revenue Department missing its tax collection target. Given the grim business outlook for Thailand, the Revenue Department will be facing a big challenge to meet its tax collection target for the next fiscal year. So, it’s inevitable that the frequency of tax audits will increase.

More than ever before, businesses need to understand their tax risks and must adopt the right strategies to manage their tax costs. Only by doing this will they be able to find their way effectively through the uncertain times ahead.

During this event, our subject matter experts will examine these developments and share their views on them. We believe that you’ll gain a better understanding of how the tax environment is likely to change in the coming years, and will learn how to deliver workable strategies to achieve future prosperity.

We hope you’ll find our MSV conference invaluable, and we look forward to seeing you there.

Session B: Structuring your mobility programme to embrace tax law changes in Thailand

Deploying your employees in the right locations has been critical to developing talent and growing your business, but a rapidly evolving environment in fast-growing Asian regions could pose a challenge for many employers. Recent changes such as tax developments in Thailand could impact how and where companies deploy their employees. Companies must observe these changes in order to take advantage of any incentive policies, and minimise any impact on the cost of deploying talent and related compliance risk exposure.

In this session, we’ll: - update you on the recent changes in tax, immigration, provident fund and social security regulations and practices in Thailand that

affect internationally mobile employees, and explain their impact on individual taxpayers - outline the current trend of multinational companies of transferring their internationally mobile employees under service and non-

service arrangements - highlight possible planning strategies that may help you embrace these opportunities and challenges, and- elaborate on how to structure and claim foreign tax credits in Thailand, and overcome some of the difficulties that may be faced.

Session D: Preparing for changes to the customs, excise and international trade environment – what you need to do

There have been several changes to the customs, excise and trade related regulations this year. In May, the Cabinet approved the principal of a new Excise Act, consolidating the various existing excise related laws and regulations and changing the excise tax base. In July, the Cabinet approved the amendment of Customs Act (B.E. 2469), which is the first major revision of the Act since 1929. It includes significant changes relating to statutory penalties and fines, bribes and rewards, post audit practices, and advance ruling systems, etc.

The Thai Government has also decided to (re)start its efforts and initiatives on implementing rules related to export control on dual-use items that will affect companies in various industries such as automotive, chemicals, pharmaceuticals, steel, and electronics. Feedback from the recent implementation of the Facilitation Act in July this year has been mixed. Both the private and public sectors are questioning whether or not the Act is actually ‘facilitating’ business or simply adding more work for companies and relevant government officers.

This session will give you an insight into these key changes and how they could impact your company’s operations in the short and long terms. And we’ll show you how you can best prepare for these changes to minimise their impact.

Tuesday 27 October 2015

08:00 – 08:30 Registration

08:30 – 08:50 Welcome note & Opening speech

08:50 – 09:20 Keynote speech by Revenue Department

09:20 – 10:30 PwC Tax Panel

10:30 – 11:00 Coffee Break

11:00 – 11:30 Update new laws & regulations

11:30 – 12:00 Accounting Ethics

12:00 – 13:15 Lunch

13:15 – 14:15 Breakout session 1 (Select one of these sessions)A: International payments – easing the compliance burden for companiesB: Structuring your mobility programme to embrace tax law changes in Thailand

14:30 – 15:30 Breakout session 2 (Select one of these sessions)C: Are you using the correct VAT documentation?D: Preparing for changes to the customs, excise and international trade environment – what you need to do

15:30 – 16:00 Coffee break

16:00 – 17:00 Breakout session 3 (Select one of these sessions)E: How to Manage Transfer Pricing Risk: A Continuing ProcessF: The fifth M of 4M management

AgendaAll sessions will be conducted in Thai.

Session F: The fifth M of 4M management

To optimise profit, the industrial sector focusses on the 4M, manpower, machinery, money, and methods. Today, the fifth ‘M’ has emerged that cannot be ignored by industrial enterprises: mandatory laws and regulations and their interpretations.

Challenges from this fifth M will continue to grow, and the number inspections by authorities is expected to jump dramatically. Because of this, we’ll focus on the fifth M’s impacts on the 4M that have high exposure to penalties. We’ll also explore common pitfalls and potential solutions for defending your 4M decisions in the event of an inspection.

The main topics will be the misuse of machinery under Board of Investment promoted projects – a common mistake made by majority foreign-owned businesses – and typical manpower issues under employment laws.

For more information

Please call +66 (0) 2344 1000 and speak to

Khun Kanphassorn ext. 4206; Khun Kanoknok ext. 4203;Khun Sariya ext. 4239; or Khun Supattra ext. 4207

Event Details:

Date: 27 October 2015

Venue: Shangri-La Hotel

Who should attend:

Chief Financial Officer; Finance & Accounting Director; Tax Director; Financial Controller; Human Resources Director; Tax Lawyer

Language: All sessions will be conducted in Thai.

Dress code: Business

© 2015 PricewaterhouseCoopers Legal & Tax Consultants Ltd. All rights reserved. 'PricewaterhouseCoopers' and/or 'PwC' refers to the individual members of the PricewaterhouseCoopers organisation in Thailand, each of which is a separate and independent legal entity. Please see www.pwc.com/structure for further details.

Session E: How to Manage Transfer Pricing Risk: A Continuing Process

One of the notable changes if the recently approved draft transfer pricing regulations by the Cabinet was passed into law is the mandatory requirement to make transfer pricing disclosure at the time of tax filing. When information on related party transactions are disclosed, the companies' existing transfer pricing risks would be uncovered. Transfer pricing documentation is one of the tools used to mitigate the risks. But transfer pricing documentation is at the end of a continuing process for managing transfer pricing risks. It is now more crucial than ever before for people involved in the tax function to have the holistic picture of transfer risk management process. This will enable you to be in a better position to spot and assess transfer pricing risks that may exist and take necessary corrective actions to improve your company’s transfer pricing compliance early on.

During the session, we will walk you through the process for managing transfer pricing risk. We will also go through recent transfer pricing investigation cases to demonstrate challenges made by the Revenue Department on transfer pricing issues to give you a feel of what to look for when assessing the level of your transfer pricing compliance.

October 2015

Shangri-La Hotel

www.pwc.com/th

17th Annual Conference

Maximise Shareholder Value 2016

27

Preparing yourself for a compliance review by the authorities