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SMU-TA Centre for Excellence in Taxation Inaugural Conference 2015
Eric M. Zolt, UCLA School of Law September 17 and 18, 2015
Designing Effective Tax
Incentives: Maximizing the
Benefits and Minimizing the
Costs
Overview of Presentation
• Benefits and costs of tax incentives
• Political economy of tax incentives
• Design and administrative considerations
• Possible lessons from Singapore’s experience with tax
incentives
• Influence of tax systems in developed countries on the
effectiveness of tax incentives in developing countries
• How does the BEPS project change the tax environment
for tax incentives?
Tax Incentives: Key
Questions
• What are tax incentives?
• What role should government play in encouraging
investment?
• What are the benefits and costs of using tax incentives?
• What factors influence decisions on where to invest?
• What has changed in desirability of tax incentives?
Definition of Tax Incentives
• “Revenue losses attributable to provisions of the Federal
tax laws which allow special exclusion, exemption or
deduction from gross income or which provide special
credit, preferential rates of tax or a deferral of tax liability”
(Congressional Budget Act of 1974)
• “An exemption or relief which is not part of the essential
structure of the tax in question but has been introduced into
the tax code for some extraneous reason…”
Prevalence of Tax Incentives
By Region (James 2013)
Number of
Countries
Surveyed
Tax
holiday/Tax
exemption
Reduced
Tax rate
Investment
allowance/
Tax credit
VAT
exemption/
reduction
R&D Tax
Incentive
Super-
deductions
SEZ/Free
Zones/EPZ/
Free port
Discretionary
process
East Asia
and
Pacific
12 92% 92% 75% 75% 83% 8% 83% 25%
Eastern
Europe
and
Central
Asia
16 75% 31% 19% 94% 31% 0% 94% 38%
Latin
America
and the
Caribbean
24 75% 29% 46% 58% 13% 4% 75% 29%
Middle
East and
North
Africa
15 73% 40% 13% 60% 0% 0% 80% 27%
OECD 33 21% 30% 61% 79% 76% 18% 67% 27%
South
Asia 7 100% 43% 71% 100% 29% 57% 71% 14%
Sub-
Saharan
Africa
30 60% 63% 73% 73% 10% 23% 57% 47%
Benefits of Tax Incentives
• If properly designed and implemented, tax incentives can be a useful
tool in attracting investments that would not have been made without tax
benefits
• By increasing investment through reducing the after-tax cost of
investment, countries may realize:
• Increased capital transfers
• Transfers of know-how and technology
• Increased employment and improved workforce
• Assistance in improving conditions in less-developed areas
• Spillover and agglomeration effects
• Increased economic activity from related suppliers and consumers
• Bring together companies in related activities in a single
geographical area (for example, petrochemical or aerospace)
More purported benefits
• Symbolic
– Signal foreign investors that country is an
“investor-friendly” location
• Compensate for inadequate tax systems
– High rates
– Inadequate net operating loss and depreciation
provisions
• Compensate for other externalities
– Bad infrastructure
– Inadequate dispute resolution procedures, etc.
Estimating the Benefits of
Tax Incentives
• Estimate increase in direct economic activity from tax
incentives (key assumptions include amount of net new
investment; labor and capital displacement effects;
capital/labor/material ratios)
• Estimate increase in indirect economic activity (key
assumptions include amount of capital goods and material
inputs purchased from suppliers and whether purchased
domestically or imported)
• Estimate increase in induced economic impact on
households
• Determine revenue consequences of these changes
Costs of Tax Incentives
• Erosion of tax base
– Investments that would have taken place even without tax incentives
– Investors exploiting tax incentives to other activities or other types of
income (abuses and leakages)
• Efficiency and welfare costs
– Shifting tax burden to immobile tax bases (labor)
– Encouraging activity that is not economically viable with out
government subsidy
• Equity -- disadvantaging other investors (particularly foreign investors
who have made significant investments in the country)
• Complexity and compliance considerations
• Increase of tax burden on non-qualifying activities
• Lobbying and unproductive rent seeking activities
• Discretionary practices create opportunities for corruption
• Tax degradation (race to the bottom)
Estimates of Direct Costs of
Tax Incentives
• Tax expenditure budgeting (OECD 2015)
– Revenue foregone method
– Revenue gain method
– Outlay equivalent method
• Corporate micro-simulation models
– Data requirement (use of corporate-level tax return information)
– Determination of marginal effective tax rates and average
effective tax rates
• Sensitivity analysis -- How sensitive are the results to key
assumptions and data limitations?
What Has Changed in Recent
Years?
• Although tax incentives in many countries may have been ineffective in the past, this may no longer be true
– Tax incentives may be more generous than in past years
– Tax incentives may be better targeted and better designed
– Substantial trade liberalization and greater capital mobility
• As non-tax barriers decrease, the significance of taxes in investment decisions increase
– Businesses have changed
• Changes in organizational structure, production and distribution methods, and types of products being manufactured and sold
– Growth in common markets, custom unions and free-trade areas
Political Economy of Tax
Incentives
• Why do countries continue to use tax incentives in light of
the mostly negative economic evidence of their
effectiveness?
– “This time is different”
– Politicians need to do something to improve economic
growth—tax incentives are relatively easy to adopt and
costs are less transparent
– Capture theories
• Outside capture (economic elite seeking to minimize
tax liability)
• Inside capture (government agencies seeking to
maximize the level of new investments without major
concern for tax revenue)
Political Economy – Unanswered
Empirical Question
• Do countries with “better” institutions have better results
with either not adopting tax incentives or designing them in
a way that improves effectiveness?
– Greater transparency (necessary, not sufficient)
– Better decision-making structure on designing and
granting tax incentives
– Better ability to estimate the costs and benefits of tax
incentives
– Better ability to monitor for abuses of tax incentive
regimes
Tesla “Gigafactory”– the
Process
• Announces plans to build facilities to manufacture
“affordable” lithium-ion batteries at a cost of $5 billion and
generate 6,200 jobs
• Invites economic development officials from 7 states to visit
the Tesla factory
• Gives states 3 weeks to put together a proposal as to what
incentives they would provide (tax breaks, free land,
infrastructure improvements, and cash) and to complete
responses to questionnaire (90 questions)
• Tesla selects four states as “Gigafactory Location Finalists”
Tesla “Gigafactory” – the
Winning Bid
• Nevada offers a total package of $1.4 billion
– Free land, electricity discounts, and infrastructure
improvements ($113 million)
– Tax incentives
• Sales tax abatement on equipment and construction
material ($725 million)
• Property tax abatement ($350 million)
• Payroll tax abatement ($30 million)
– Transferable tax credits that Tesla could sell to other
companies ($195 million)
Largest US State Tax
Incentives
1. Washington: Boeing $8.7 billion
2. New York: Alcoa $5.6 billion
3. Washington: Boeing $3.2 billion
4. Oregon: Nike $2 billion
5. New Mexico: Intel $2 billion
6. Louisiana: Cheniere Energy $1.7 billion
7. Pennsylvania: Royal Dutch Shell $1.65 billion
8. Missouri: Cemer Corp. $1.64 billion
9. Mississippi: Nissan $1.25 billion
Design Considerations for
Tax Incentives
• Eligibility criteria
• Process for qualification
• Scope of benefits
• Reporting and monitoring requirements
• Recapture provisions
• Review and sunset provisions
Administrative
Considerations
• Which agency has responsibility for the design and administration of tax incentives?
– Development agencies vs. tax authority
• Criteria for qualification
– Subjective vs. objective tests for qualification
– Targeting of tax incentives
– Soliciting and recruiting potential investors
• Monitoring continued compliance
– Filing requirements
– Auditing requirements
• Penalty provisions for non-compliance and abuse
• Sunset provisions and recapture of tax benefits
Top 10 Abuses of Tax Incentive
Regimes
1. Existing firms transform into new entities to qualify for incentives
2. Domestic firms restructure as foreign investors
3. Transfer pricing schemes with related entities (sales, services, loans,
royalties, management contracts)
4. Churning or fictitious investments (lack of recapture rules)
5. Schemes to accelerate income (or defer deductions) at the end of a tax
holiday period
6. Overvaluation of assets for depreciation, tax credit, or other purposes.
7. Employment and training credits -- fictitious employees and phony
training programs
8. Export zones – leakages into domestic economy
9. Regional investment incentives and Enterprise Zones – diverting
activities to outside the region or zone
10. Disguising or burying non-qualifying activities into qualifying activities
Filing & Reporting
Requirements
• Reporting requirements
– Specialized tax forms for firms operating under tax
holidays
• Type of information required
– Investment information (to monitor compliance with
conditions of holidays)
– Earning information (to allow estimation of costs of tax
holiday provisions)
– Related party transactions (to assist in identifying certain
“abusive” transactions)
Tax Credit Accounts
• Description—grant investors a set amount of tax credits
and provide accounting for determining remaining balance
in an account (Tanzi & Zee)
• Advantages
– Compared to tax holidays, they are easier to target,
easier to control and costs are more transparent
– Requires investors to file regular tax returns—allows for
better auditing on use of tax credit
• Disadvantages
– Distortion towards short-term investments
– Same transfer-pricing concerns as tax holidays
Transparency
• Legal and regulatory dimension
– Explicit rationale for granting tax incentives
– Incentives should be part of tax law and not part of informal decrees or executive orders
– Sunset provisions
• Economic dimension
– Determine effective tax burden and “relief” provided by tax incentives
– Tax expenditure analysis—estimate revenue costs
– Periodic review of effectiveness of tax incentive programs
• Administrative dimension
– Qualifying criteria that are clear and objective
– Automatic vs. discretionary entitlement
– Reporting and filing requirements
OECD Draft Principles to Enhance the
Transparency and Governance of Tax Incentives
for Investment in Developing Countries
1. Make public a statement of all tax incentives for investments and their objectives
within the governing framework.
2. Provide tax incentives for investment through tax laws only.
3. Consolidate all tax incentives for investment under the authority of one government
body, where possible.
4. Ensure tax incentives for investments are ratified through the lawmaking body or
parliament.
5. Administer tax incentives for investment in a transparent manner
6. Calculate the amount of revenue forgone attributable to tax incentives for
investment and publicly release a statement of tax expenditures.
7. Carry out periodic review of the continuance of existing tax incentives by assessing
the extent to which they meet the stated objectives.
8. Highlight the largest beneficiaries of tax incentives for investment by specific
provision in a regular statement of tax expenditures, where possible.
9. Collect data systematically to underpin the statement of tax expenditures for
investment and to monitor the overall effects and effectiveness of individual tax
incentives.
10. Enhanced regional cooperation to avoid harmful tax competition.
Tax Incentive Review Project
1. Compile list of existing tax incentives in the country;
2. Review process of designing and granting tax incentives
among different government agencies;
3. Review any reporting requirements for taxpayers receiving
tax incentives, examine current efforts to monitor
compliance, and review penalties for non-compliance;
4. Review past and current efforts to evaluate effectiveness of
tax incentives;
5. Develop methodology for evaluating the effectiveness of
existing tax incentives; and
6. Develop methodology for evaluating the costs and benefits
of new tax incentives.
Singapore’s Experience with Tax
Incentives
• Different phases of Singapore’s economic
development strategy
• Overview of Singapore’s tax incentive review
process
• Administration of tax incentives
• Role of non-tax factors in attracting investment
• Key factors to the success of tax incentive provisions
Key Phases of Singapore’s
Economic Development
Key Issue Key Policy Objective Key Policy Response
1959 –
1965
• Rampant unemployment of
10%
• Demise of entrepôt trade in
primary commodities
• New opportunities in enlarged
domestic market in newly-
formed Malaysia in 1963
Import substitution
• To shift reliance on entrepôt trade
and provision of support to the British
troops to rapid industrialisation to
combat unemployment
• Enacted in 1959 the Pioneer
Industries (Relief from Income Tax)
Ordinance and the Industrial
Expansion (Relief from Income Tax)
Ordinance
• Tariffs and import quotas to help local
producers
1965 –
1973
• Loss of common market due to
separation from Malaysia in
1965
• Pullout of the British military by
1971
Export growth
• To continue to control unemployment
and to take an export-oriented path
to industrialisation
• To promote inward FDI by MNCs
• The two 1959 ordinances were
replaced by Economic Expansion
Incentives (Relief from Income Tax)
Act (EEIA) in 1967, reducing
corporate tax rate from 40% to 4% on
approved manufacturers’ export
profits for up to 15 years
• Tariffs phased out in favor of free
trade
1973 –
1984
• Oil crisis of 1973
• Lack of necessary skills and
capability to take on high-
technology manufacturing
Industrial restructuring
• To shift towards skill-based and
technologically advanced industries
• To wean investors from over-reliance
upon low-wage production
• To encourage investors to upgrade
to more sophisticated plant and
machinery to raise productivity
• Introduced the Investment Allowance
Scheme (IA) in 1979 to promote more
advanced sectors such as
petrochemicals, pharmaceuticals,
industrial and medical equipment,
engineering services and advanced
components for aircraft and marine
Source: Singapore MOF and EDB materials
Key Phases of Singapore’s
Economic Development (cont’d)
Key Issues Key Policy Objective Key Policy Response
1985 -
2000
• First post-independence
recession in 1985
• Need to satisfy the
demand for skilled
workers
• Rise in competition from
lower cost economies for
manufacturing projects
and export markets
Economic diversification
• To expand services activities
together with manufacturing as
“twin engines” of growth to
diversify from being merely a
production base
• To simulate economic growth
by improving the return on
capital
• To bring Singapore’s tax rate in
line with competing economies
• Gradual reduction in Corporate
income tax (CIT) rate from 40%
to 30%; personal income tax
was also reduced
• Pioneer incentive was offered to
the service sector; post-pioneer
incentive tightened via increased
eligibility criteria
2001-
2010
• Need to undertake further
structural reform to
promote growth and
development
• Opportunities in
technology development,
test-bedding,
commercialisation, and
international markets
Economic Transformation
• To engage MNCs in significant
operational business activities
• To reduce disincentives for
MNCs (e.g. tax compliance
costs and the need to manage
foreign tax credits for the sole
purpose of paying
franked/exempt dividends to
non-resident shareholders) to
use Singapore as a HQ and
operational hub
• CIT fell below 25% in 2002, to
20% in 2005 and finally to 17%
in 2010
• One-Tier corporate taxation was
fully implemented in 2008 to
exempt Singapore-sourced
dividends paid by a resident
company from Singapore tax
Source: Singapore MOF and EDB materials
Incentives: An Integral Part of
Overall Economic Strategies
1960-1985
• Industrial activities
1986 - 2000
• Manufacturing activities
• Service activities: •Pioneer services
•Headquarters activities
•Sector-specific activities: Shipping, Transport, Logistics & Trading (AOT, AIT), Financial (FTC), E-commerce (ACT)
2001 - 2010
• Manufacturing
• Service activities: • Financial services
• Logistics & Trading
• International Trading
• Transport & Logistics
• Healthcare services
• Legal services
• Tourism
2010s
• Growth and transformation across sectors: • Capabilities in
design-driven innovation
• Energy efficiency
• M&A
• Deeper partnership between larger and small companies
• Land use intensification
Economic
Committee, 1986:
- Low broad-based
corporate tax
regime
- Minimal selective
tax incentives
Economic
Restructuring
Committee, 2002:
- Attract new,
innovative
activities
- Streamlining &
rationalizing
incentives
Economic Strategies Committee, 2010:
- Technology development, test-
bedding, commercialisation, and in
scaling up into international markets
Activities promoted
Source: Singapore MOF and EDB materials
Singapore’s tax incentive review
process
• Ministry of Finance has primary responsibility for the evaluation
and review of tax incentive proposals
• MOF consults with multiple stakeholders (including other
Ministries, agencies and professional organizations) in designing
tax incentives
• Tax incentive proposals are accepted only if they further
Singapore’s economic objectives
• Tax incentive proposals are included in the annual Budget
submitted to Parliament
• After Parliament debates and approves the Budget, tax incentive
proposals are presented in draft legislation
• After Parliament approves the legislation, tax incentives proposals
become effective.
Source: Information from Singapore MOF and EDB materials
Accountability and Transparency
in Singapore
• Members of Parliament are provided information about the
benefits (e.g. economic impact and beneficiaries of proposals)
and revenue impact of tax incentive proposals and can raise
questions and objections about the desirability of specific tax
proposals. MPs may raise questions in Parliament on the
effectiveness of specific tax incentives. This approach increases
government accountability and provides transparency on the
benefits and costs of tax incentive proposals.
• The Auditor-General’s Office is charged with auditing the Ministry
of Finance and other government agencies to enhance public
accountability in the management and use of government funds
and resources to support tax incentive proposals.
Source: Information from Singapore MOF and EDB materials
Objective of Tax Incentives
Regimes
• The key objective in granting tax incentives is to stimulate real economic activities in Singapore.
• The design and administration of tax incentives achieves this objective by focusing on:
– Transitional support: Legislative cap to prevent providing evergreen support to recurring activities
– New activities: Incremental investment commitments are required for continued qualification for support to encourage growth in new areas that are in line with economic objectives. Government also works with industry/businesses to ensure sustainability of the sector (e.g. training to build up local talent pool and capabilities).
– Commensurate with economic substance: Eligibility criteria designed to encourage economic spin-offs and to stimulate activities critical to a knowledge-based economy
Source: Information from Singapore MOF and EDB materials
Tax Incentive Administration in
Singapore: Framework
• Ministry of Finance provides guidelines to the economic promotional
agencies for administering tax incentives:
– To ensure consistency across agencies administrating tax incentives
– To ensure accountability by requiring agencies to review and monitor
companies receiving tax incentives to ensure compliance with
economic commitments
– To ensure that agencies periodically review tax incentives programs
to ensure that they still meet the economic objectives.
• Tax incentives typically have sunset clauses (e.g. 5 years)
• Agencies are required to review tax incentives to determine
whether to renew the tax incentive program.
• The award of incentives is designed to be a stringent process.
Currently, less than 1% of all companies in Singapore are awarded tax
incentives.
Source: Information from Singapore MOF and EDB materials
Role of Economic Development Board
• The Economic Development Board (EDB), a part of the Ministry of Trade & Industry (MTI), serves
as the nation’s lead investment promotion agency.
• EDB plans and executes strategies to enhance Singapore’s position as a global business centre.
The EDB administers a number of incentive provisions under the Economic Expansion Incentives
(Relief from Income Tax) Act (EEIA) and the Income Tax Act (ITA).
• Eligible businesses with substantive plans to grow through conducting high value activities in
Singapore may apply to qualify for various incentives programs.
• Applicants are required to submit plans for new, substantive economic contributions, which must
include commitments for significant incremental capital expenditure, business spending and skilled
jobs in Singapore, as well as anchoring leading-edge technology, skills or activities in Singapore.
• Factors that the EDB will consider include the significance of the proposed investment to the
development of the industries in Singapore, contributions to the growth of research and
development and innovation capabilities, as well as potential spin-off to the rest of the economy.
• Successful applicants must satisfy rigorous requirements with respect to the scale and qualitative
aspects of the activities to be conducted in Singapore.
• EDB monitors performance and deliverables of recipients during the incentive period.
• EDB conducts post implementation review and evaluation of the tax incentive schemes to consider
if the schemes should be renewed.
• EDB regularly reports to MOF on the administering of the tax incentives (e.g. award of new
recipients and treatment of shortfall cases).
Source: Information from Singapore MOF and EDB materials
Non-Tax Factors Affecting
Investment Flows to Singapore
Non-tax factors play a major role in attracting foreign investment into Singapore. The
government recognizes that without these non-tax factors, tax incentives would likely
not be effective in attracting foreign investment.
• Educated workforce
– Trainable / Highly skilled and culturally adaptive talent pool
– Multi-national workforce
• Stability and Trust
– Political & economic stability
– Transparent & well-respected legal system, including world-class IP rights protection
– Zero tolerance against corruption
• Connectivity
– Extensive network of investment, trade and double taxation agreements
– World-class physical infrastructure
– Strong logistics capabilities
• Liveability
– High quality of life
– Efficient public transport, clean & green environment
Source: Information from Singapore MOF and EDB materials
Key Lessons from Singapore’s
Experience
• Tax incentives part of economic strategy
– Clearly defined strategy
– Clearly defined, measurable and sustainable deliverables
– Tax incentives just one tool
• Recognition that non-tax factors are the key to attracting
foreign investment
• Tax incentive regimes change over time to reflect changing
objectives
• Transparent process of evaluation and review of tax
incentive proposals
• Effective process for administering tax incentives and
reviewing effectiveness
Additional Considerations
• Focus on attracting real economic activity
• EDB is charged with identifying and contacting potential
investors that meet economic objectives rather than just
waiting for investors to apply for tax incentives
• Innovate or create new and more efficient global and regional
business models by bringing together companies in the same
or related activities through use of tax incentives
• Flexibility in tailoring tax incentives (and non-tax incentives) to
meet the specific needs of an investor while balancing against
economic objectives
• Flexibility in administering and renegotiating tax incentives to
reflect changing circumstances and economic conditions
Impact of Other Countries’ Tax
Regimes on Effectiveness of Tax
Incentives
• Globalization and increased mobility of capital and labor,
countries no longer able to design tax rules in isolation
– Need to consider tax regimes of countries of foreign
investors (tax sparing arrangements)
– Need to consider the tax regimes of other countries in the
region
• As potential investors
• As competitors for foreign investment
• As potential customers (particularly trade taxes)
Revenue Transfer from Developing
Countries to Developed Countries
• Simple model: foreign investor invests directly in a developing country either through a branch or through a foreign subsidiary that immediately repatriates any profits
• Tax regime of country of foreign investor
– Foreign investor is taxed on their world-wide income
– Foreign investor is allowed a credit for foreign income tax paid
• Foreign investor’s aggregate tax liability unchanged
– Little or no tax in developing country but increased tax in home country
– Tax incentives merely transfer tax revenues from poor countries to rich countries (UNCTAD 2000)
Revenue Transfer Argument Likely
Overstated
• Many developed countries tax residents under a “territorial” approach
• Other tax systems provide for no “current taxation” of income from foreign operations until income is repatriated
• Multinational corporations can structure activities to minimize tax liability
– Use of offshore entities
– Transfer pricing arrangements
– Thin-capitalization schemes
Continuum of Types of
International Tax Regimes
Full exclusion of active and passive foreign source income
Full exclusion of active income
Taxation of income that is not taxed at a sufficient rate
Territorial tax systems-------------------------------------World-wide tax systems
Provisions that facilitate base erosions and profit shifting
Deferral of active business income (but not passive income)
Full inclusion (no deferral on aggregate basis)
United States Tax Regime
• General rule: US taxes US multinationals on world-wide income
• Exception: No tax on active income of foreign subsidiaries until repatriated
• More complex model:
– Structure investment in developing countries through other countries (a large percentage of foreign investment in Africa goes through Mauritius, Netherlands Antilles, or Switzerland)
– Little repatriation of funds from investments in either developed or developing countries (about $2 trillion in un-repatriated profits)
– Blending of low-tax active income from developing countries with high-tax income from other countries
Possible Tax Reform in US May
Influence the Economic Benefits
of Tax Incentives to Investors
• Several reform proposals in the US eliminate deferral of active income of foreign subsidiaries and impose a “minimum” tax on foreign source income
• Politically “optimal” tax rate on foreign source income somewhere between zero and the regular corporate rate
• These changes may result in some economic benefits from tax incentives accruing to foreign governments rather than foreign investors
• If major developed countries adopt a minimum tax on foreign source income, this increases the likelihood that developing countries will compete for foreign investment through infrastructure improvements rather than tax incentives
Possible Consequences of BEPS
Project on Relative Tax Burdens
• Change relative tax burdens in countries for activities that qualify for tax incentives and those that do not
• Change relative tax burdens in doing business in developed and developing countries
• Provide additional tools to tax authorities in developing countries to better enforce their tax laws
– “best practices” for limiting base erosion and profit shifting
– increasing the quality (and not just the quantity) of information available to tax authorities
Concluding Questions and
Observations
• How can countries become or remain competitive in a
changing world?
• How can policy-makers better evaluate the costs of
benefits of tax incentives as compared to other government
actions?
• Are countries with better approaches to designing and
monitoring tax incentives and increased transparency more
effective in their use of tax incentives?
• What may change in a post-BEPs world?
– Increased role for non-tax incentives
– Increased competition among countries for improving the
business environment rather than tax incentives
SMU-TA Centre for Excellence in Taxation Inaugural Conference 2015
© SMU-TA CET 2015. All rights reserved. No part of these materials may be reproduced or transmitted in any form or by any means, including photocopying and recording, or storing in any medium by electronic means and whether or not transient or incidentally, without the written permission of the copyright holder. These materials are for exclusive use of the conference participants. They do not in any way represent the official views of the SMU-TA CET or any other person or authority. The authors and the SMU-TA CET are not responsible for the results of any actions or omissions taken on the basis of information in these materials, nor for any errors or omissions. The authors and the SMU-TA CET expressly disclaim any liability to any person, whether a conference participant or otherwise, in respect of anything done or omitted to be done by any such person in reliance on any part of the contents of these materials.
