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Info Seminar 181114 : Taxation of Derivatives and Hybrid Financial Instruments

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www.dannydarussalam.com

SPEAKERS

Yusuf Wangko Ngantung
Senior Manager of International Tax / Transfer Pricing Services at DANNY DARUSSALAM Tax Center

He advises clients in various areas in transfer pricing and international taxation. Prior to joining DANNY DARUSSALAM Tax Center, he has worked for Horwath de Zeeuw & de Keizer, the Netherlands, where he was involved in international tax planning projects for both inbound and outbound investments, European VAT, and taxation on expatriates.

He received his Bachelor of Law degree (LL.B) in Tax Law (fiscal recht) from the Leiden University, in Leiden, the Netherlands and his Master Degree in International Taxation (LL.M. Int. Tax) at Vienna University of Economics and Business Administration – Austria, under full scholarship from DANNY DARUSSALAM Tax Center.

Yusuf Wangko Ngantung holds Advanced Diploma in International Taxation; Certificate in Principles of International Taxation; and Certificate of Principles of Corporate and International Taxation (Transfer Pricing) from the Chartered Institute of Taxation, UK.

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Ganda Christian Tobing
Senior Manager of International Tax Services at DANNY DARUSSALAM Tax Center

He was a senior specialist in Tax Compliance and Litigation Services and in charge in reviewing, designing, and controlling of tax compliance and litigation of Multinationals Companies. He has vast proven track records in settling tax litigation cases for companies including those engaged in garment industry and automotive parts manufacturing industry.

He received his Bachelor’s degree in Fiscal Administration from the University of Indonesia and his Master Degree in International Taxation (LL.M. Int. Tax) at Vienna University of Economics and Business Administration – Austria, under full scholarship from DANNY DARUSSALAM Tax Center.

He has passed Principles of International Taxation examination paper for Advance Diploma in International Taxation from the Chartered Institute of Taxation – UK, and therefore has been awarded Certificate in Principles of International Taxation.

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WHO SHOULD ATTEND:

The seminar is valuable for Corporate tax Adviser; International tax expert and executives; Tax professional and controller; Tax attorneys; Accountants; and Anyone else who have responsibilities on Taxation.

Seminar:

TAXATION OF DERIVATIVES AND HYBRID FINANCIAL INSTRUMENTS

Tuesday, 18 November 2014
Start from 09.00 am – 05.00 pm

Since the current financial and economic environment presents many challenges for most economic agents, financial transaction and their instruments are likely be one of those challenges. They serve to raising capital in a cost efficient manner, accommodating to the investors demands, hedging risks, uprising capital flows and investment opportunities, favouring investments that would not had been made otherwise. They also allow to monetize assets and, due to their flexibility, may be used to accommodate to the different regulation requirements of different countries taking advantage of the regulation differences.

The complexity of the matter derives from various reasons: diversity and flexible use of the instruments, different legal, accounting and regulatory frameworks, and cross border implications. On the other hand, the accounting system of these instruments and their outcomes greatly varies from country to country, with some important changes regarding the recognition, the characterization of derivative and the determination of the time of accrual or realization of the income. Relationship between accounting and tax treatment also vary from country to country.

The use of derivatives and hybrid financial instrument has gained significance in international finance and their tax treatment concerns need of accurate study and precision. Based on the issues described above, this seminar is designed to help participants know in-depth the tax treatment of derivative and hybrid financial instruments for corporate income tax purposes, not only for domestic context, but also in cross border context.

Topics Covered:

  • Introduction of the concept of derivative and hybrid financial instrument;
  • Characterization of derivative and hybrid transaction;
  • Hedging and speculation;
  • Gain or loss recognition;
  • Case law: fair value accounting vs realization principle in taxation;
  • The borderline between debt and equity in tax treaty law;
  • Previous remarks on tax treaty qualification;
  • OECD Model Tax Convention (MTC) for tax treaty qualification of hybrid financial instrument;
  • Relationship between article 10 and 11 of the OECD MTC and in tax treaties;
  • Dividend income classification of hybrid financial instruments under tax treaties;
  • Hybrid financial instruments income as interest income for treaty purposes;
  • Tax planning on derivatives and hybrid financial instruments;
  • Illustrations and case studies.

Location:

DDTC’s Training Center
Menara Satu Sentra Kelapa Gading
6th Floor, Unit #0601 – 0602
Jl. Boulevard Kelapa Gading LA3 No.1
Summarecon, Kelapa Gading
Jakarta Utara 14240

“Our seminars combine practices and recent developments with comparative studies.” 

Facilities:

Seminar kit, Updated hardcopy material, Certificates, Coffee break and meals, Library access, and others modern supporting facility.

Fees:

IDR 3.000.000 per person. Due to limited seating available (25 seats), we recommend that you register early to reserve your seat.

SAVE!
1. Early Bird Discount:
Register and pay before 7 November 2014 to achieve up to 15% SAVINGS on the standard rate.

2. Team Discount:
Register two (2) delegates and receive 20% discount off the standard rate.

All group registration must be from the same company, at the same time and for the same event.
Registrants must choose between the most advantageous discount option.
Only one discount is available at the time a registration is made.

More Info:

REGISTER HERE
or
Download the registration form here and send it to us
For further information and details, please contact:

Ms Eny Marliana

Mobile-phone : +62 815 898 0228
Phone            :  +62 21 2938 5758
eny@dannydarussalam.com

Ms Indah Kurnia

Mobile-phone: +62 856 192 6643
Phone            : +62 21 2938 5758
indah@dannydarussalam.com

——————————————————————–

DANNY DARUSSALAM Tax Center
Menara Satu Sentra Kelapa Gading
Unit #0501 & Unit #0601 – #0602
Jl. Bulevar Kelapa Gading LA3 No. 1, Summarecon,
Kelapa Gading, Jakarta Utara, 14240, Indonesia

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