The Base Erosion and Profit Shift (“BEPS”) Project Lecture to be jointly co-held by the Daily National Tax Newspaper (“Daily NTN”) and Lee & Han International will begin from June 16, 2016 drawing the remarkable attentions from a number of multinational enterprises.
Even before BEPS Project has been newly introduced to the global community, multinational enterprises have prepared transfer pricing (TP) reports with a help of consulting firms and utilized the TP report at the time of tax audit as a patch-up defense tool.
The purpose of BEPS Project recently introduced, however, is to maintain the transparency of cross-border transactions and allocate the taxing rights among nations by legally mandating multinational enterprises to report information on their cross-border transactions to the nations where they are doing business. Accordingly, unlike the past practice, multinational enterprises need to manage cross-border transactions under a systematic method rather than the patch-up approach.
As tax authorities are going to scrutinize the details of cross-border transactions reported by multinational enterprises, multinational enterprises should make substantial efforts in order to avoid unnecessary challenges by tax authorities. Assuming that you do business in two nations, you have to consider two variables. However, you should consider six (1x2x3) variables when you do business in three nations.
That is, the more nations there to do business, the more variables there to consider. If the number of variables which one consider should increase, the probability that things can go wrong also increases.
Accordingly, multinational enterprises should fully understand what issues their cross-border transactions will raise to each tax authority and how to respond to the tax authority when issues become debatable.
The BEPS Project Lecture jointly held by the Daily NTN and Lee & Han International is going to focus on the abovementioned topics, so the lecture can be useful and productive.
Dr. Han (managing partner of Lee & Han International / Ph.D. in International Tax / Washington DC Attorney) has 30 years of international tax experience including the Korean National Tax Service (Mutual Agreement Procedure (MAP) & APA), PwC and E&Y, and is going to lead the BEPS Project lecture.
Dr. Han acquired his Ph.D. degree with the thesis of “Strategic Approach toward the Amendment of Korea-US Tax Treaty” in 2008, published the book “Translation & Explanation of OECD Model Tax Convention” under the translation copyright approved from OECD and the book “International Taxation Bible (1300 page)” in 2012.
He has also made a great contribution to the development of international taxation by having published his international law & tax theses through the International Law and Management Review and many writings through ‘SelectedWorks’ which is one of top famous scientific sites in the United States.
Dr. Han acquired a US lawyer license to broaden his business scope to the global community last year and has established his solid and broad academic base with endless efforts. Thus, he is being acknowledged as a leading-edge specialist in the Korean Tax Academic Circle.
The teaching material "BEPS Project Lecture" written by Dr. Han and published by the Daily NTN contains various international tax cases such as ‘Treaty Shopping’, ‘Intra-group Service Fee’, ‘Permanent Establishment’, ‘Transfer Pricing’, ‘Advance Pricing Agreement’, ‘Secondary Adjustment’, ‘Judgment of Residency’ and ‘Customs Valuation’. Dr. Han has written the cases while defending multinational enterprises against the tax authorities’ challenges. Over six hundred pages of actual cases contain the detailed legal, logical and statistical analysis on the above issues.
This BEPS Project Lecture is an education course which is to be performed the first time in Korea. Dr. Han has proactively prepared for the cases and the textbook in preparation for this kind of global circumstance for over 20 years. Those who want to participate in the BEPS Project Lecture can fill out the application form through Lee & Han International’s website (www.leeandhan.com).
