2018 financial services taxation conference...the tax institute - 2018 financial services taxation...

14 CPD hours

2018 Financial Services Taxation Conference

7–9 February 2018 | QT Gold Coast

2 - THE TAX INSTITUTE - 2018 Financial Services Taxation Conference

Welcome2018 Financial Services Taxation Conference

On behalf of The Tax Institute and the 2018 Financial Services Taxation Conference Organising Committee, it gives me great pleasure to invite you to Australia’s leading financial services tax conference. In 2018, the conference will be held at the QT Gold Coast over three days, from 7 to 9 February.

The Organising Committee has created a diverse and engaging program that covers the key tax issues currently affecting the financial services industry. Emerging issues including residency, the taxation of stapled structures and the diverted profits tax will be covered along with core updates from new cases and rulings and an ATO briefing on their focus areas.

The program also includes a number of sessions on reforms such as the mandatory disclosure regime and tax transparency measures. A wide range of breakout sessions are also offered including transfer pricing, GST, life insurance and super, corporate restructures and foreign investments by Australian funds.

I trust that you will enjoy the 2018 Financial Services Taxation Conference and look forward to seeing you there.

Matthew Hartshorn, CTA Chair, Conference Organising Committee

Thank you

The Tax Institute gratefully acknowledges the generous assistance of members of the Conference Organising Committee:

Matthew Hartshorn, CTA, Macquarie (Chair, Conference Organising Committee)

Patrick Broughan, CTA, Deloitte

Rob Colquhoun, AFMA

Kos Dimitriou, CTA, MLC

Joanne Dunne, CTA, PwC

Andrew Hirst, CTA, Greenwoods & Herbert Smith Freehills

Monica Jordan, FTI, ANZ Banking Group

Ian Kellock, CTA, Ashurst

James Loughhead, CTA, Westpac

Matt Osmond, PwC

Grant Peters, CTA, Ernst & Young

Natalie Raju, CTA, KPMG

Marcus Ryan, Australian Taxation Office

David Wood, CTA, King & Wood Mallesons

Proudly supported by:

THE TAX INSTITUTE - 2018 Financial Services Taxation Conference - 3

Technical programEvent summary

Day 1 – Wednesday, 7 February 2018Time Session Presenter

12.00–1.00pm Registration and lunch on arrival

1.00–2.00pm Session 1: Mandatory disclosure regime The Board of Taxation has consulted on the introduction of a mandatory disclosure regime (MDR) in Australia. An MDR regime would require taxpayers and advisers to report details of transactions and clients to the ATO. This session will consider:

� The pros and cons of an MDR � How an MDR would work practically (in conjunction with the reportable tax position schedule, or some other disclosure)

� What design options have been considered (including the UK’s DOTAS regime and the OECD’s work on BEPS Action 12)

� What is the best design for an MDR in Australia, and � The broader regime context that is relevant for this purpose.

Karen Payne, CTABoard of Taxation

2.00–3.00pm Session 2: The ATO’s approach to significant financial services tax issuesThis session will provide an update on financial services tax issues the ATO is considering.

Jeremy Hirschhorn, CTAAustralian Taxation Office

3.00–3.30pm Afternoon tea

3.30–4.30pm Session 3: Residence – Central management and controlThe panel of speakers will lead a practical discussion on a variety of residence issues, including:

� The impact of the Hua Wang Bank and Bywater decisions � Draft TR 2017/D2 and any differences from TR 2004/15 � Practical Compliance Guidelines – a discussion of the examples and what they may mean, and

� A practical focus on what the new approach may mean for groups operating in multiple jurisdictions and foreign investment vehicles with Australian based managers.

Stuart DallPitcher Partners

Prof Robert (Bob) Deutsch, CTAThe Tax Institute

Richard Evans, CTAMacquarie

4.30–5.30pm Session 4: M&A in financial servicesThis session will outline recent M&A activity in financial services and key drivers and trends in the Australian market, including regulatory changes, portfolio rebalancing, the emergence of private equity and fintech.

It will also cover key M&A tax deal issues, including:

� Managing tax risk through diligence, clear exit and tax warranties and indemnities � Transferring and utilising losses � Corporate structuring � Financing, including thin capitalisation, diverted profits tax, transfer pricing and hybrid mismatch rules

� Stamp duty � FIRB tax conditions � Tax consolidation exit and entry.

Paul AbbeyPwC

David Wood, CTAKing & Wood Mallesons

5.30–7.00pm Welcome drinks reception, QT Gold Coast



Day 2 – Thursday, 8 February 2018Time Session Presenter

8.00–8.45am Registration and light breakfast

8.45–9.45am Session 5: Keynote presentationIn 2017, a number of legislative and administrative changes were proposed or enacted which impact upon the financial sector (among others). These included the diverted profits tax, hybrid mismatch rules, the bank levy, the South Australian version of the bank levy, the Corporate Collective Investment Vehicle (CCIV) regime proposals, transparency proposals and mandatory disclosure regime proposals.

In this session the speaker will discuss the benefits of taxation reform.

The Hon. Anna Bligh AC Australian Bankers’ Association

9.45–10.45am Session 6: Macro economic outlook and implications for taxationObservations on the latest economic trends impacting the sector.

Shane OliverAMP Capital

10.45–11.00am Morning tea

11.00am–12.00pm Session 7A: The diverted profits taxIn 2017, the diverted profits tax (DPT) was enacted as part of Australia’s Part IVA anti-avoidance provisions. This session will address:

� The object and operation of the DPT � Example scenarios where the DPT might apply in the context of the financial sector � Practical issues arising from the DPT � ATO guidance on the DPT.

Alia Lum, CTAKPMG

Julian RobertsAustralian Taxation Office

OR Session 7B: Practical issues for interest withholding tax and section 128FThe session will focus on practical interest withholding tax issues using examples/case studies. Examples to be addressed will include, in respect of section 128F:

� Satisfying the public offer test for syndicated facility agreements including highlighting differences compared with the requirements for notes

� Genuineness of offers in various scenarios � Arranger/underwriter scenarios, and � Relying on earlier offers for new issues (eg tap issues under an existing program)

The session will also discuss the Treaty exemptions for interest withholding tax.

Ian Kellock, CTAAshurst

Bronwyn Kirkwood, CTAAshurst

12.00–1.00pm Session 8A: BEPS – Action item 2 – HybridsThis session will provide an outline of the latest developments in relation to BEPS Action Item 2, including the latest OECD developments and the government’s response.

The session will cover any draft legislation to implement the Item 2 recommendations in Australia, together with a consideration of practical examples that are likely to impact Australian financial services organisations.

Paul Korganow, ATIAustralian Taxation Office

Manu Sriskantharajah, FTIDeloitte



Time Session Presenter

OR Session 8B: Life and superannuation accounting updateAASB 17 will be the Australian version of an international accounting standard covering all insurance contracts. It will replace current accounting standards in Australia, AASB 4 (Insurance Contracts), AASB 1023 (General Insurance Contracts), and AASB 1038 (Life Insurance Contracts). It will represent the most significant change to Australian insurance accounting requirements in 20 years including:

� Significant implications for profit recognition and ROE measurement � KPIs and business performance measures will change � Product and business strategy will require re-assessment, and � Significant change to finance systems and processes.

It will require a significant implementation program, addressing not only finance and actuarial people, process and systems, but also upstream source administration and related processes, and performance measurement and communication processes dependent on financial information (eg incentives and investor communications). The session will also address AASB 9 and superannuation fund accounting, AASB 1056 – implementation reflections on the adoption of the standard, and future challenges.

Kieren Cummings EY

Matina MoffittEY

1.00–2.00pm Lunch

2.00–3.00pm Session 9A: Australian tax treatment of foreign investments by australian collective investment vehiclesThe ever-increasing exposure to foreign investment structures has presented Australian investors with many challenges in determining the Australian taxation treatment on returns.

This session will provide an overview of the current tax technical and practical challenges for Australian collective investment vehicles and foreign investments, including:

� Classifying foreign investment vehicles under Australian tax law � Taxation of investment returns � Entitlements to foreign income tax offsets (FITOs) and the impact of foreign tax reclaims � Issues arising upon divestment � The impact of double tax agreements � Current and emerging ATO guidance.

Brad Ivens, ATIEY

Jessica Hall, ATIEY

Session 9B: Restructures, turnarounds and insolvencyThis session will cover current issues in restructures, turnarounds and insolvency, including a number of recent transactions as practical examples. Issues covered will include:

� Overview of the main forms of external administration – administration, receivership and liquidation

� The professional administrator’s perspective – key concerns and how tax factors in � Key tax issues for borrowers and creditors, including: � debt restructures and forgiveness � impact of administration and receivership, including deeds of company arrangement � tax obligations under external administration � priority of creditors and ATO’s ability to collect tax � common traps

Julian Pinson, FTIGreenwoods & Herbert Smith Freehills

Christopher HillPPB Advisory

3.00–3.30pm Afternoon tea

3.30–4.30pm Session 10: Black economy taskforce Michael Andrew, AOBoard of Taxation

4.30–5.30pm Session 11: Case updateThis session will consider tax case law which has been determined in the Federal Court, Full Federal Court and High Court between January and December 2017, including an analysis of the win–loss percentage. It will also consider significant case law from other Commonwealth jurisdictions that will be potentially persuasive in Australia.

Joanne Dunne, CTAPwC

7.00–10.00pm Conference dinner – Skypoint

Day 2 – Thursday, 8 February 2018 (continued)



Day 3 – Friday, 9 February 2018Time Session Presenter

9.00–9.15am Senior tax counsel policy update Prof Robert (Bob) Deutsch, CTA The Tax Institute

9.15–10.15am Session 12: Stapled groupsThis session will explore a number of issues in relation to stapled groups, including:

� the background to stapled groups and some of the policy levers influencing any potential changes in law

� an update on the consultation process (including the latest Government announcements) � the future of stapled groups, and � the ATO approach to stapled groups.

Andrew Hirst, CTAGreenwoods & Herbert Smith Freehills

Fiona KnightAustralian Taxation Office

10.15–10.45am Morning tea

10.45–11.45am Session 13A: Transfer pricing post ChevronIn April 2017 the Full Federal Court issued its judgment in the Chevron case. The matter was later resolved between the parties and Chevron abandoned its application for special leave to appeal to the High Court. In May 2017 the ATO issued PCG 2017/D4.

In this session the speakers will consider:

� the holdings in Chevron and whether the Full Court’s judgment resolves all of the points at issue

� the meaning of the case for taxpayers and practitioners when complying with the transfer pricing provisions, including its meaning in the context of Division 815-B and Division 815-C, and outside of the context of intra-group debt

� the ATO’s approach in PCG 2017/D4 including; – the risk assessment and reporting purpose of PCG 2017/D4 and – the extent to which it reflects the current law post Chevron

� the current transfer pricing landscape including areas of ATO concern and activity and how taxpayers should respond.

Julian Humphrey, CTAKPMG

Tim KeelingKPMG

OR Session 13B: GST and financial servicesThe ATO is currently devoting significant resources to examining a range of GST issues in the financial services industry. This session will examine some of the most contentious of these issues, including:

� The interpretation of “creditable purpose” for expenses incurred by financial institutions (for example, in relation to credit card operations)

� The characterisation of expenses as reduced input tax credits (RITCs), particularly for outsourced IT services

� The impact of the B2B cross-border amendments on reverse charge liabilities.

Amelia O’RourkeDeloitte

11.45am–12.45pm Session 14: Tax transparency initiativesAustralia has instituted a number of significant transparency initiatives including the Corporate Tax Transparency Code and the ATO’s annual Report of Entity Tax Information. There have been other proposals made by various political parties in Australia - including a register of beneficial ownership, and transparency in respect of tax settlements. International initiatives which have been enacted such as the common reporting standard and country-by-country reporting also impact upon Australian entities.

In this session the speakers will outline the tax transparency developments in Australia, highlighting recent developments (for example, the Appendix to the Corporate Tax Transparency Code comprising Draft AASB Guidance). The speakers will also place the Australian initiatives in the context of transparency initiatives overseas - including in the US, and the European Union.

Chris Vanderkley, CTAPwC

Helen KellyAustralian Taxation Office

12.45–1.00pm Conference close


Presenter profilesAn overview of our experts

Paul Abbey is a Partner in the Corporate Tax group of PwC in Melbourne and has over 25 years’ experience advising local and international clients on income tax issues. Paul has significant experience in relation to tax due diligence, acquisition structuring, capital raisings and IPOs.

Michael Andrew, AO was Chairman and CEO, KPMG International from May 2011 to July 2014, and Chairman of KPMG Asia-Pacific and Chairman, KPMG Australia from 2007 until 2011. Michael is a former member of the Business Council of Australia and the International Business Council of the World Economic Forum, and was the Chair of the Australian B20 Working Group on Anti-Corruption and Transparency. Michael was appointed as the Chairman of the Board of Taxation in January 2015.

The Hon. Anna Bligh AC is the Chief Executive Officer of the Australian Bankers’ Association, working to strengthen the culture in banking and improve customer experience. Anna has had a long and distinguished career in politics. She was Premier of Queensland for almost five years and led the response and recovery effort to devastating floods in January 2011. Prior to joining the ABA, Anna was the CEO of YWCA NSW, a not-for-profit organisation striving to build a safer world for women and children with services dedicated to ending domestic violence. Anna received a Companion in the General Division of the Order of Australia award in the 2017 Australia Day Honours list, in recognition of her eminent service to the Parliament of Queensland, to the not-for-profit sector and the role of women in public life.

Kieren Cummings is an insurance partner with Ernst & Young with over 20 years’ experience in the insurance industry in both commercial roles and professional services. Kieren leads EY’s IFRS 17 activities in Oceania, and is a member of their Global IFRS 17 technical panel. Originally from Australia, he was based in Korea supporting Ernst & Young’s multi-national and domestic insurance clients for three years from 2007 for their adoption of IFRS. In 2010 he transferred to Hong Kong where he served EY’s multinational and regional insurance clients, in both an audit and advisory capacity. He returned to Australia in 2015 and continues to work with EY’s insurance teams and clients across the region.

Stuart Dall, ATI, is a partner at Pitcher Partners and practices in corporate and international tax, with a particular focus on matters involving capital management and funding, mergers and acquisitions, cross-border investment, profit repatriation, and liaison with tax authorities. He joined Pitcher Partners Melbourne in 2015 having previously practiced as a corporate tax partner at Big 4 firm in Australia. Stuart’s clients have included both public and private organisations across a wide range of industry sectors, including financial services, property and infrastructure. His transaction experience has involved some of the largest matters in corporate Australia, where he has led the delivery of tax services in supporting clients and their other advisors with due diligence, contract negotiation, acquisition structures, funding, commercial and accounting considerations, liaison with tax authorities, and other post-completion support.

Prof Robert (Bob) Deutsch, CTA, is Senior Tax Counsel at The Tax Institute. Bob was until very recently the Deputy President of the Administrative Appeals Tribunal (AAT), and for over 20 years was a Professor in Taxation Law with the University of New South Wales. Bob specialises in taxation matters, with a special emphasis on international tax. His time with the AAT required extensive involvement in corporate law, social security and immigration matters. He also has experience as a solicitor with a major national law firm, as an independent barrister and as a director with a major accounting firm. He has written widely in his fields of specialisation as well as in the area of financial statements, and is an ongoing contributor to the highly successful Thomson Reuters Australian Tax Handbook. Bob has deep expertise in both tax practice and tax education, developed over many years at the highest levels. This gives him a unique perspective that enables him to represent The Tax Institute with authority and integrity.

Joanne Dunne, CTA, is a Director at PwC, Melbourne. She was formerly a tax partner at law firms in both Australia and New Zealand. She has more than 20 years’ tax experience in general income tax, GST, international tax and tax controversy. Joanne is a member of a wide range of professional organisations, including The Tax Institute’s Tax Disputes Committee (of which she is co-chair), and she represents The Tax Institute on the ATO’s Dispute Resolution Working Group.

Richard Evans CTA, is an Associate Director in Macquarie Group’s group tax team with a broad experience of income tax matters impacting the financial services industry. Richard has over 15 years’ experience in providing taxation advice, advising in both external and in house roles as well as in the UK and Australia. His responsibilities in his time at Macquarie have focused on supporting the investment banking, retail banking and asset management businesses within Macquarie as well as group matters such as funding and thin capitalisation.

Jessica Hall, ATI, is a Senior Manager in EY’s Financial Services tax practice and works extensively with clients across the financial services industry in Melbourne, Sydney and globally. Jessica has a specialised focus on taxation in the large superannuation and managed funds industry, including investment structuring and risk governance with a strong interest in property and infrastructure investments both onshore and offshore in the context of asset class portfolio management and investment strategies of large superannuation funds. Jessica has over ten years of experience working closely with Australia’s large industry and retail superannuation funds, banking and managed investment groups. Jessica has been actively involved with the recent superannuation tax reforms including Treasury consultation processes and making submissions on behalf of the industry.

Christopher Hill has over 20 years’ experience in the restructuring and advisory sector, across a wide variety of industries and leads PPB Advisory’s Institutional Restructuring offering. In recent times, Chris’ primary roles have been in advising on or managing complex distressed situations with multiple stakeholders, particularly in the Mining, Property,



Infrastructure and Private Public Partnership (PPP) sector, with clients ranging from domestic and offshore banks, hedge funds, state governments and private companies.

Jeremy Hirschhorn, CTA, joined the ATO in August 2014, and since March 2015 has been the Deputy Commissioner for Public Groups in the Public Groups and International Business line. In this role he is responsible for overseeing tax administration and compliance for all public entities. Before taking on this role, he was the ATO’s Chief Tax Counsel with responsibility for the Tax Counsel Network. Prior to joining the ATO, Jeremy was a senior partner in KPMG’s Tax practice.

Andrew Hirst, CTA, is a Director and Head of Financial Services at Greenwoods & Herbert Smith Freehills Pty Limited. Andrew advises on a wide range of corporate and banking-related tax issues with a particular focus on financial and international transactions. Andrew has been extensively in the consultations with Treasury in relation to stapled groups.

Julian Humphrey, CTA is a Partner of KPMG’s Banking and Finance practice with over 20 years’ experience. He works primarily with international banks and financial services companies operating in Australia, providing corporate income tax and more recently transfer pricing services. Julian’s areas of expertise include the taxation of banks and bank branches, the taxation of financial arrangements and retail financial products as well as Australia’s offshore banking regime. He has advised on a number of major M&A transactions in the financial services sector in recent years. He is currently heavily involved in the base erosion and profit shifting debate, working with clients to implement country-by-country reporting. He is a regular participant in consultation with the government on Australia’s tax reform proposals affecting Australian financial institutions.

Brad Ivens, ATI, is an Executive Director in EY’s Financial Services tax practice, who works with Melbourne and Sydney-based clients across the financial services industry. In particular, Brad has over 19 years’ experience in providing tax compliance and advisory services for the superannuation industry, covering matters such as investment due diligence, capital gains tax planning, unit pricing/crediting rate reviews, custodian tax reporting, fund administration, tax effect accounting and ATO reviews/audits. His clients have ranged from some of Australia’s largest industry and employer-sponsored funds, through to public sector and self-managed funds. Brad has also been an active contributor to the government and the ATO in relation to the current superannuation tax reforms.

Tim Keeling is a Director in KPMG’s international tax advisory practice. He has over 12 years’ of transfer pricing experience including in financial services and financial transactions. During Tim’s transfer pricing career, Tim has worked for both the Australian Taxation Office and professional advisory firms.

Ian Kellock, CTA, is a Tax Partner at Ashurst and has extensive experience in Australian corporate and international tax, advising Australian and foreign-owned banking and financial services

groups. Ian’s practice primarily focuses on due diligence and structuring for mergers, acquisitions and divestments, financing transactions and group reorganisations. Ian has significant recent experience advising on all income tax aspects of financing and refinancing transactions and asset and debt reconstruction projects.

Helen Kelly, is an Assistant Commissioner at the Australian Taxation Office. She has over 25 years’ experience in taxation law and currently works in the Tax Counsel Network with a focus on resolving high risk and complex tax technical issues in the clearest and most effective way whilst making tax fair, simple and understood. She is a member of Tax Counsel Network’s Internationals Focus Group with a lead role on tax transparency and is also a member Tax Counsel Network’s Energy & Resources Focus Group. Previously Helen was the Senior Assistant Commissioner responsible for all of the Centres of Expertise, and she has worked in the Large Business & International, Indirect Taxes and Litigation areas of the ATO. Helen has recently led the Tax Counsel Network team responsible for providing advice on recently enacted transparency initiatives including Country by Country Reporting and General Purpose Financial Statements.

Bronwyn Kirkwood, CTA, is a senior associate at Ashurst in Melbourne. Bronwyn’s practice is in direct tax, with an emphasis on financial services and general corporate tax issues. Bronwyn’s experience covers a broad range of matters including providing income tax advice for structured financing arrangements, securitisations, PPPs and mergers and acquisitions. She has significant experience in advising on exemptions to the application of interest withholding tax.

Fiona Knight, CTA, is an Assistant Commissioner at the Australian Taxation Office. She has 20 years’ experience in taxation law and currently works in the Tax Counsel Network providing advice on the most complex tax technical issues with a focus on anti-avoidance provisions. She is a member of the ATO’s General Anti-Avoidance Rules (GAAR) Panel. Previously she has worked in the Large Business & International and Litigation areas of the ATO. Fiona holds a Bachelor of Laws (Hons), a Bachelor of Commerce and an Executive Masters of Public Administration from the University of Melbourne. She also holds a Masters of Taxation from the University of NSW. Fiona is admitted to practice as a Barrister and Solicitor in Victoria.

Paul Korganow ATI, is the ATO Assistant Commissioner for the International Tax Structuring/BEPS Practice, Public Groups and International. Paul leads an International Tax Structuring team based in Melbourne and Sydney. He is also involved in strategy development and contribution to domestic and multilateral law reform around BEPS. Paul is the ATO Project Lead for BEPS Action 2, the Australian ATO representative at OECD Working Party 11 and represented the ATO on the Board of Taxation Working Group looking at the domestic implementation of the OECD Anti-Hybrid Rules. Paul was previously a Partner at two Big 4 firms in their International Tax and M&A groups.



Alia Lum, CTA, is a partner in KPMG’s corporate tax practice. She has over 17 years’ experience predominately in financial services and international tax both in Sydney and London. In 2017, Alia completed a long term secondment to the Revenue Group in the Federal Treasury and the Board of Tax Secretariat.

Matina Moffit, is an Executive Director, Financial Services – Superannuation at Ernst & Young. Matina has over 30 years’ experience in audit, with the last 28 specialising in audit and accounting for superannuation funds. Her clients include employer sponsored and public offer superannuation funds. She also has extensive experience in auditing funds with custodians as well as funds with direct investments. Matina’s experience in the superannuation industry includes assurance advisory services, including development of risk management frameworks, corporate governance reviews for superannuation trustees and reviews of processes and procedures designed to ensure compliance with relevant legislation and corporate policies.

Shane Oliver, joined AMP in 1984, becoming Chief Economist in 1994 and is now Chief Economist and Head of Investment Strategy. Shane has extensive experience analysing economic and investment cycles and what current positioning means for the return potential for different asset classes such as shares, bonds, property and infrastructure. Shane is a regular media commentator on economic and investment market issues and engages regularly with investors at public events and forums.Shane is Co-Head of the Investment Strategy and Dynamic Markets team, responsible for the provision of economic and macro investment analysis and more importantly the management of the Dynamic Markets Fund and the determination of AMP Capital’s asset allocation policy which is applied across more than $65 billion invested in multi-asset funds.

Amelia O’Rourke is a Director in Deloitte’s Indirect Tax practice, with over 16 years’ experience advising on GST with a specialist focus on financial services. Before her consulting roles, Amelia worked for five years in indirect tax advisory roles at Macquarie Group and Westpac. In the public sector, Amelia worked in the ATO and Treasury for 10 years, including as a member of the original team that designed and drafted Australia’s GST law. She performed the role of Assistant Commissioner responsible for liaison between the ATO, Treasury and the Parliament, and has also worked in the Assistant Treasurer’s office and the Indirect Tax policy group in Treasury.

Karen Payne, CTA, was appointed as the inaugural Chief Executive Officer of the Board of Taxation, effective 31 March 2016. She is also a member of the Board of Taxation, appointed in May 2015. She chaired the Board’s working group that advised on the implementation of the OECD hybrid mismatch rules – both generally and specifically in relation to regulatory capital. Karen was a member of the Board of Taxation advisory panel and assisted with the reviews of tax arrangements for managed investment trusts, venture capital limited partnerships, collective investment vehicles, the investment manager regime and the arm’s-length debt test. Karen was previously a Partner at MinterEllison focusing on international and corporate taxes

for the financial services industry, and mining, energy and utilities sectors. Karen has assisted domestic and international corporates and funds (equity, infrastructure, property, private equity and venture capital) with advice on structure, M&A and taxation due diligence.

Julian Pinson, FTI, is a Director at Greenwoods & Herbert Smith Freehills Pty Limited. Julian advises on a wide range of tax matters, with a focus on the banking and financial services, property and funds management industries. Julian has particular expertise in cross-border finance, TOFA, OBUs, corporate restructures, debt and equity raisings, property transactions and mergers and acquisitions.

Julian Roberts, is an Assistant Commissioner at the ATO. He works in the Tax Counsel Network providing technical leadership on strategic and high-risk international tax matters. He previously worked as a technical specialist in Public Groups and International. Prior to joining the ATO in 2014, Julian was a senior associate in the tax group of a national law firm where he advised clients on tax disputes and litigation.

Manu Sriskantharajah, FTI is a Partner in Deloitte’s International Tax Group with over 15 years’ experience advising on the corporate and international tax aspects of inbound and outbound investment in Australia. Manu’s expertise lies in cross-border M&A, group re-organisations, financing arrangements and intellectual property licencing, particularly in light of the OECD’s proposed Base Erosion and Profit Shifting measures. Manu is a regular speaker at tax seminars, client forums, Deloitte’s Asia-Pacific Dbriefs and consults with the Australian Government on international tax reform. Manu holds Bachelor of Commerce, Bachelor of Laws and Master of Laws degrees from the University of Melbourne and is an Australian Legal Practitioner.

Chris Vanderkley, CTA recently joined PwC as Special Counsel specialising in Tax Governance/Transparency and Controversy matters for Corporate Taxpayers. Prior to that, Chris worked at GE for 20 plus years in numerous roles including Chairman of all GE Boards, CFO and Asia Pacific Head of Tax. Chris was a member of the CTA Executive Committee for eight years and continues to act as an adviser to the Board of Tax.

David Wood, CTA, is a Tax Partner in the Melbourne office of King & Wood Mallesons. He has more than 34 years’ experience in providing tax advice and conducts a varied practice which covers all aspects of revenue law. David has particular experience in advising on financial services and financial transactions, including innovative financial products, derivatives, securitisations and infrastructure projects. David also advises on mergers and acquisitions, international taxation, tax audits, the conduct of tax litigation, stamp duty and GST.


Online registration

Delegates are encouraged to register online at taxinstitute.com.au/FS

Registration inclusions

Conference registration includes participation in the full technical program, electronic access to all technical papers and presentations, attendance at the welcome reception, conference dinner and all lunches and refreshments during conference hours. Registration fees do not include travel, accommodation, hotel breakfasts or hotel incidentals.

Discounts

Early bird registrationAll full conference registrations received and paid for on or before Friday 24 November 2017 will be entitled to an early bird discount.

Group discountsPurchase four full conference registrations and receive the fifth registration free. All attendees must be from the same firm and all must register at the same time.

Delegate list

A delegate list will be included in The Tax Institute CPD app to assist with networking. Please indicate on the registration form if you do not want your details included on the list.

Confirmation of registration

A confirmation will be sent via email. Please note you will receive two separate emails in the form of a confirmation email and tax invoice.

CPD accreditation

Attendance at the conference counts for 14 hours of Continuing Professional Development Accreditation (CPD) with The Tax Institute.

Paperless option

To assist in reducing the environmental impact, the standard registration option will only provide electronic access to materials.

The Tax Institute CPD app

The Tax Institute CPD app will be accessible for delegates to download available technical materials in the days prior to the event commencement. The app will contain session and speaker information, the delegate list and available technical materials. Delegates will receive instructions via email detailing how to download and access materials.

Dress code

Smart casual attire is suitable for the duration of the conference program, including the conference dinner.

Alteration and cancellation policy

The Tax Institute reserves the right to alter, amend or cancel all or any of the arrangements contained in the program. It is a condition of acceptance of registration that an administration fee of 20% of the registration fee will be charged for cancellation. No refund will be given for cancellations received within five working days of the event. A replacement may be nominated however, the replacement is only valid for the 2018 Financial Services Taxation Conference. If the replacement is not a member, the non-member registration fee will apply. CPD hours will be allocated to the designated attendee. The Tax Institute cannot accept responsibility for delegates’ late transport arrivals or non-arrivals due to delays.

Event informationWhat, when and how to


Venue and accommodation

Setting a new standard of designer Surfers Paradise accommodation, QT Gold Coast hotel is deliberately intended to inspire conversation and arrest the senses. Guests to this Gold Coast accommodation can indulge in the vibrant beachside location and the unique Gold Coast spirit.

Favourable room rates have been negotiated and secured at the QT Gold Coast. All accommodation bookings can be made through our accommodation and travel provider, ConferenceNational 2018 for the Financial Services Taxation Conference or by following the link on our website taxinstitute.com.au/FS.

Please note that as per hotel booking conditions, all accommodation booked is non-refundable. All additional hotel incidentals, including breakfast, remain the responsibility of delegates, and individuals will be responsible for payment of the balance of their account when checking out of the hotel. Please note that extra charges may be incurred for additional guests, and will be charged to individual room accounts upon checkout.

Welcome drinks – Wednesday

A welcome drinks reception will be held directly following the last session from 5.30pm at the Calypso Terrace. The welcome drinks reception is included in the conference registration fee for delegates. Additional tickets are available to purchase for accompanying persons at a cost of $55. Please indicate your requirements, including dietary requirements, on the registration form.

Conference dinner – Thursday

The conference dinner will be held at Skypoint in Surfers Paradise on Thursday evening from 7pm. Additional conference dinner tickets are available to purchase for accompanying persons at a cost of $150. Please indicate your requirements, including any dietary requirements, on the registration form. For those

delegates attending the dinner, transfers will be arranged to and from the dinner venue. Please ensure you indicate whether you will be attending the dinner for catering and transportation purposes.

Getting there

The QT Gold Coast is located 23 kilometres north of Gold Coast Airport, an approximate 35-minute drive. For those travelling from Brisbane, it is 86 kilometres, an approximate 1¼ hour drive.

ParkingThe QT Gold Coast offers complimentary guest parking (space is limited and subject to availability).

Transfers from Gold Coast and Brisbane airportsFor delegates wishing to fly into Gold Coast or Brisbane airports, The Tax Institute has negotiated a favourable rate with transport provider Con-x-ion. A 20% discount will be offered to conference delegates for transfers between the airports and the resort. Should your flight be delayed, you will be placed on the next available shuttle service. Simply go to www.con-x-ion.com/Bookings/Airport-Transfers and enter the conference code FST2018. The discount is applied once your service has been selected.

For further information regarding this event, please contact the National Events Team on 1300 733 842 or email [email protected]

For registration enquiries, please contact [email protected]

Event informationWhat, when and how to

The Chartered Tax Adviser Program

Developed to enhance the performance of all tax professionals, the Chartered Tax Adviser Program is the industry’s choice for innovative tax education and training. The Institute offers three formal education courses to support tax professionals throughout their career – CTA1 Foundations, CTA2 Advanced and CTA3 Advisory. Visit taxinstitute.com.au/education for more information or call us to discuss your firm’s training needs on 02 8223 0032.

Member benefits include:

– Taxation in Australia journal

– TaxVine e-newsletter

– TaxLine Research Service (free to members)

– CPD event discounts

– Publications and tax product discounts

– Business Alliance Partner discounts.

Join today at membership.taxinstitute.com.au/join or call 02 8223 0000.

There is no time like the present to join Australia’s premier tax body and take advantage of the special new member introductory offer.For an additional $320 on the member registration fee you will receive membership until June 2019.

Become a member

Lead the way in tax

A tax invoice and confirmation letter will be sent on receipt of your registration. Please photocopy for additional delegates and retain original copy for your records. All prices quoted are in Australian dollars and include GST where applicable. ABN 45 008 392 372.

PERF

Date of issue: Sept 2017

2018 Financial Services Taxation Conference 1180202 | WD

1 Registration (Please see page 8 for registration inclusions.)

Individual registration Please register me for the full conference. The registration fee includes catering, welcome drinks, conference dinner and electronic access to materials.

Early bird registration Received on or before 24 November 2017

Standard registration Received after 24 November 2017

Member $2,095 $2,295

New member* $2,415 $2,615

Non-member $2,495 $2,695

2 Delegate contact details

Title: Mr Mrs Miss Ms Other (please specify) Date of birth: D D / M M / Y Y Y Y

First name: Last name:

Position: Company:

Address:

Suburb: State: Postcode:

Telephone: Fax:

Mobile: Email:

Please tick this box if you do not wish your name to be included on the delegate list provided to all attendees for networking purposes.

Member no.: If your member details are up-to-date, you can skip this section.

*EVENT AND MEMBERSHIP OFFERThere is no better time than right now for non-members to take up membership! Register at the Member rate + add on $320 for Membership and receive member benefits through to 30 June 2019. All new members are eligible to ‘upgrade’ their membership level at no additional cost by providing the appropriate documentation when applying within the initial membership subscription period.I hereby apply for membership of The Tax Institute and declare that I am a person of good fame, integrity and character and agree to be bound by the Constitution of The Tax Institute. Further information available at taxinstitute.com.au Signature:

Date of signature:

D D / M M / Y Y Y Y

3 Breakout session selection

11.00am–12.00pm Session 7A Session 7B

Thursday 8 February (choose one selection only) Friday 9 February

10.45–11.45am Session 13A Session 13B

12.00–1.00pm Session 8A Session 8B2.00–3.00pm Session 9A Session 9B

Group registrationPurchase four full conference registrations and receive the fifth registration free.†

Email [email protected] with your attendee names. Please note: A Tax Institute member will be the fifth qualifying free ticket.† All attendees must be from the same firm and all must register at the same time.

I acknowledge that I will receive electronic access to the available papers and presentations through The Tax Institute CPD app.

Promotional code:

Dietary requirements:

Session 8B: Managed Funds – CCIV 2.00pm–3.00pm

Session 9A: Australian Tax Treatment of Foreign Investments by Australian Collective Investment Vehicles

Session 9B: Restructures, Turnarounds and Insolvency

2018 Financial Services Taxation Conference Registration form

Collection notice

The Tax Institute (TTI) complies with its obligations under the Privacy Act 1988 (Cth) with respect to how it handles personal information. TTI collects, uses, holds and discloses your personal information (including sensitive information, such as health information) for a range of purposes, such as administrative purposes relating to membership of TTI and TTI’s courses (including assessment of eligibility and providing courses), compliance with Government and statutory requirements, provision of information relating to TTI’s services and member benefits and to conduct market research. If you do not provide the personal information requested by TTI, it may not be able to provide its services to you, such as assessment of your course enrolment application. TTI does not disclose criminal record information to third parties. TTI usually discloses your personal information to entities such as your sponsoring employer (with respect to your course records and results), The Tax Practitioners Board, TTI’s business partners for marketing purposes, IT companies and other companies who provide administrative and other services to TTI and government bodies, such as the Tertiary Education and Quality Standards Agency. TTI may disclose personal information to overseas recipients in countries such as the United States of America and India. For further information on how TTI collects, uses, holds and discloses personal information, please see its privacy policy at www.taxinstitute.com.au. The Privacy Policy also contains information on how to request access to or correction of your personal information and how to make a complaint about a breach of privacy. By submitting your application to TTI, you confirm that you have read TTIs Privacy Policy and you consent to your personal information being collected, used and held by TTI and disclosed to third parties as set out in this notice and in accordance with TTI’s Privacy Policy. If you do not want your personal information to be used by TTI or disclosed to third parties, for the purpose of direct marketing, please contact us in writing at [email protected].

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4 Welcome drinks

The welcome drinks reception is INCLUDED in the registration fee for delegates.

Wednesday 7 February: QT Hotel – Calypso Terrace

Yes, I WILL be attending the welcome drinks reception OR

No, I WILL NOT be attending the welcome drinks reception

Additional tickets^

Yes, I require additional tickets for the welcome drinks reception at $55 per person

No. tickets at $55 each: $

^Please supply names of attendees and any dietary requirements as a separate attachment.

5 Conference dinner

^Please supply names of attendees and any dietary requirements as a separate attachment.

The conference dinner is INCLUDED in the registration fee for delegates.

Thursday 8 February: Skypoint, Surfers Paradise

Yes, I WILL be attending the conference dinner OR

No, I WILL NOT be attending the conference dinner

Additional tickets^

Yes, I require additional tickets for the conference dinner at $150 per person

No. tickets at $150 each: $

6 Payment summary

Registration fee $

Additional conference welcome drinks tickets $

Additional conference dinner tickets $

Total payable $

Please note: The Tax Institute cannot accept responsibility for delegates’ late flight arrivals. Transfer costs are non-refundable and non-transferable.

ReplacementsPlease note: Registrations for the event are not interchangeable but replacements are acceptable. Please notify us at least two days prior if you intend on sending a replacement. CPD hours will be allocated to the designated attendee. If the replacement is not a member, the non-member registration fee will apply.

Cancellations

The Tax Institute must receive cancellations in writing five working days prior to the conference. No refund will be given for cancellations received within five working days of the event. A replacement may be nominated. Further details on The Tax Institute’s cancellation policy can be found at taxinstitute.com.au.

Membership and education program promotion

I am interested in becoming a member of The Tax Institute. Please send me further details.

I am interested in learning more about The Tax Institute’s education program. Please contact me.

Marketing and business alliance partner exclusions

I no longer wish to provide my contact details to The Tax Institute’s contracted business partners.

I no longer wish to receive marketing correspondence from The Tax Institute.

We take your privacy seriously, and our policy can be viewed at taxinstitute.com.au/go/footer/privacy.

7 Payment method

Cheque payable to The Tax Institute (in Australian dollars)

Credit card $ Card type: AMEX Visa MasterCard Diners Expiry date: M M/ Y Y

Name on card:

Card no.: Cardholder’s signature:

TO REGISTER

Online taxinstitute.com.au/fs Mail GPO Box 1694 Sydney, NSW 2001

Email [email protected]

Fax 02 8223 0077

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Level 10, 175 Pitt Street Sydney, NSW 2000

ABN 45 008 392 372

Tel 02 8223 0000 Fax 02 8223 0077 Email [email protected]

Cover photo by Jordan Gellie

2018 financial services taxation conference...the tax institute - 2018 financial services taxation...

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