19:00 - 20:30


Wan Chai

Course Fee


CPD Hour


During the second half of 2018, Mainland China outbound mergers and acquisitions ("M&A") deal volume declined by over 30%, and this is all due to on-going uncertainties around the US-China trade discussions, and heightened global geo-political risk which undoubtedly affects deal making. In a 2018 CEO global survey, most CEOs pointed to uncertainty as the top reason for holding back on making investments in China and overseas. Apart from deal sourcing and preparing for opportunities in a volatile market what As base erosion and profit shifting ("BEPS") Actions 8-10 require multinational enterprises ("MNE") to identify where and how value is created in the business operations, it is important to demonstrate that the tax structure reflects the commercial realities, i.e., correct alignment of the value drivers in the value chain and their locations.

In this seminar, the speaker will talk about:
• the value creation story behind the Organization for Economic Co-operation and Development ("OECD") Transfer Pricing Guidelines ("TPG")
• identification of misalignment along the value chain and factors that should be considered in deciding what changes to make in your business models to minimize tax risk
• application of the Transactional Profit Split Method – the Revised Guidance (the Revised Guidance is aimed at clarifying and expanding the OECD TPG in the context of global value chains)


Speaker : Enoch Hsu

CPA Credit Hour : 1.50 Hours

Fee : Taxation Faculty Member: HK$120 | HKICPA member or student: HK$150 | IA/HKIAAT member or student: HK$150 | Non-member: HK$330

Application Deadline : 20 March 2019 

More Info :