Singapore

August 16, 2017

Nicole Fung
	PwC Singapore 8 Cross Street#17-00 PwC Building Singapore 048424 Tel: +65 6236 3618 Mobile: +65 9731 3433 Email: nicole.fung@sg.pwc.com Website: pwc.com/taxcontroversy Nicole Fung is a tax partner and leads the transfer pricing practice in PwC Singapore. She has more than 25 years of specialist international tax experience working in both Singapore and Canada. Nicole has worked with multinational corporations on structuring and implementing transfer pricing and supply chain transformation involving the restructuring of their customer service and other operations in the most tax efficient manner. This also includes discussions with government authorities on appropriate incentives in Singapore as well as other countries in the region. She has also been involved in cross-border transfer pricing resolution cases since 2003 and has advised on the successful conclusion of the first bilateral advance pricing agreements (APAs) between Singapore and Japan, China, Taiwan, Australia, the UK and Korea as well as being involved in bilateral APAs in Switzerland, Denmark and Indonesia. Her experience in dispute resolution also includes resolution of several mutual agreement procedures. Nicole has also been involved in conducting various trainings and workshops on transfer pricing for various clients across various levels in their chain of command. Her experience includes conducting training for tax authorities in Singapore and Vietnam. Nicole has bachelor degrees in law and economics and is admitted to the Bar in both Australia and Malaysia.

Nicole Fung

PwC Singapore

8 Cross Street#17-00 PwC Building

Singapore 048424

Tel: +65 6236 3618

Mobile: +65 9731 3433

Email: nicole.fung@sg.pwc.com

Website: pwc.com/taxcontroversy

Nicole Fung is a tax partner and leads the transfer pricing practice in PwC Singapore. She has more than 25 years of specialist international tax experience working in both Singapore and Canada.

Nicole has worked with multinational corporations on structuring and implementing transfer pricing and supply chain transformation involving the restructuring of their customer service and other operations in the most tax efficient manner. This also includes discussions with government authorities on appropriate incentives in Singapore as well as other countries in the region.

She has also been involved in cross-border transfer pricing resolution cases since 2003 and has advised on the successful conclusion of the first bilateral advance pricing agreements (APAs) between Singapore and Japan, China, Taiwan, Australia, the UK and Korea as well as being involved in bilateral APAs in Switzerland, Denmark and Indonesia. Her experience in dispute resolution also includes resolution of several mutual agreement procedures.

Nicole has also been involved in conducting various trainings and workshops on transfer pricing for various clients across various levels in their chain of command. Her experience includes conducting training for tax authorities in Singapore and Vietnam.

Nicole has bachelor degrees in law and economics and is admitted to the Bar in both Australia and Malaysia.

Daniel Ho
	Deloitte Singapore 6 Shenton Way OUE Downtown 2, #33-00 Singapore 068809 Tel: +65 6216 3189 Fax: +65 6538 6166 Email: danho@deloitte.com Website: www.deloitte.com/sg Daniel Ho, Deloitte Singapore, is a partner with more than 18 years of tax experience in serving local and listed companies in Singapore, as well as multinational companies in industries such as real estate, fund management, technology, consumer products, shipping, and energy and resources. He has extensive experience in Singapore and international tax consultancy in the areas of corporate restructuring, supply-chain optimisation, permanent establishment issues, and dispute resolution. Daniel has represented clients in various sectors such as real estate, engineering, and shipping sectors in tax controversy discussions with the Inland Revenue Authority of Singapore (IRAS). He is also involved in numerous mergers and acquisitions tax structuring, and due diligence assignments for corporates and private equity funds. He is well-versed in Singapore's tax incentive regimes including headquarter, trading, fund management, and shipping incentives, and has assisted clients in the application for such incentives. Daniel has authored an article on research and development tax incentives in Singapore, which was published in the 2015 International Fiscal Association (IFA) cahiers. Daniel was previously a facilitator at the Singapore Tax Academy. He is a faculty member of the Deloitte International Corporate Tax School and a former part-time lecturer for the subject 'Principles of Taxation' at the Nanyang Technological University. Daniel graduated from the Nanyang Technological University with a bachelor of accountancy (Hons) degree and has completed the CFA programme. He is a non-practising chartered accountant and an accredited tax adviser (income tax) with the Singapore Institute of Accredited Tax Professionals (SIATP). Daniel is also a member of the Tax Academy's curriculum and examination development (CED) committee and the Singapore Accountancy Commission's learning and assessment committee.

Daniel Ho

Deloitte Singapore

6 Shenton Way

OUE Downtown 2, #33-00

Singapore 068809

Tel: +65 6216 3189

Fax: +65 6538 6166

Email: danho@deloitte.com

Website: www.deloitte.com/sg

Daniel Ho, Deloitte Singapore, is a partner with more than 18 years of tax experience in serving local and listed companies in Singapore, as well as multinational companies in industries such as real estate, fund management, technology, consumer products, shipping, and energy and resources.

He has extensive experience in Singapore and international tax consultancy in the areas of corporate restructuring, supply-chain optimisation, permanent establishment issues, and dispute resolution. Daniel has represented clients in various sectors such as real estate, engineering, and shipping sectors in tax controversy discussions with the Inland Revenue Authority of Singapore (IRAS). He is also involved in numerous mergers and acquisitions tax structuring, and due diligence assignments for corporates and private equity funds. He is well-versed in Singapore's tax incentive regimes including headquarter, trading, fund management, and shipping incentives, and has assisted clients in the application for such incentives. Daniel has authored an article on research and development tax incentives in Singapore, which was published in the 2015 International Fiscal Association (IFA) cahiers.

Daniel was previously a facilitator at the Singapore Tax Academy. He is a faculty member of the Deloitte International Corporate Tax School and a former part-time lecturer for the subject 'Principles of Taxation' at the Nanyang Technological University.

Daniel graduated from the Nanyang Technological University with a bachelor of accountancy (Hons) degree and has completed the CFA programme. He is a non-practising chartered accountant and an accredited tax adviser (income tax) with the Singapore Institute of Accredited Tax Professionals (SIATP). Daniel is also a member of the Tax Academy's curriculum and examination development (CED) committee and the Singapore Accountancy Commission's learning and assessment committee.

Lee Tiong Heng
	Deloitte Singapore 6 Shenton Way #33-00 OUE Downtown 2 Singapore 068809 Tel: +65 6216 3262 Email: thlee@deloitte.com Website: www2.deloitte.com/sg Lee Tiong Heng, Deloitte Singapore, has more than 20 years of tax advisory and compliance experience serving local, multinational and listed companies, as well as private equity firms including four years with the Inland Revenue Authority of Singapore (IRAS). He has extensive experience in tax consultancy and planning services including tax M&A work, corporate restructuring, cross-border transactions, tax ruling requests, taxation negotiation with the IRAS and Singapore tax incentives and grant applications from the Singapore government authorities. Tiong Heng leads the Gi3 (R&D and government incentives) service line of Deloitte Singapore and Southeast Asia. He is also Deloitte Singapore's leader for technology, media and telecommunications (TMT), manufacturing, and the middle market/growth enterprise leader for tax. Tiong Heng has served clients in various industries including aviation and transportation, business services, consumer business, energy and resources, manufacturing, real estate and TMT. He is a fellow member of the Institute of Chartered Accountants of Singapore and he is also an accredited tax adviser with the Singapore Institute of Accredited Tax Professionals.

Lee Tiong Heng

Deloitte Singapore

6 Shenton Way #33-00

OUE Downtown 2

Singapore 068809

Tel: +65 6216 3262

Email: thlee@deloitte.com

Website: www2.deloitte.com/sg

Lee Tiong Heng, Deloitte Singapore, has more than 20 years of tax advisory and compliance experience serving local, multinational and listed companies, as well as private equity firms including four years with the Inland Revenue Authority of Singapore (IRAS).

He has extensive experience in tax consultancy and planning services including tax M&A work, corporate restructuring, cross-border transactions, tax ruling requests, taxation negotiation with the IRAS and Singapore tax incentives and grant applications from the Singapore government authorities.

Tiong Heng leads the Gi3 (R&D and government incentives) service line of Deloitte Singapore and Southeast Asia. He is also Deloitte Singapore's leader for technology, media and telecommunications (TMT), manufacturing, and the middle market/growth enterprise leader for tax.

Tiong Heng has served clients in various industries including aviation and transportation, business services, consumer business, energy and resources, manufacturing, real estate and TMT.

He is a fellow member of the Institute of Chartered Accountants of Singapore and he is also an accredited tax adviser with the Singapore Institute of Accredited Tax Professionals.

Low Hwee Chua
	Deloitte Singapore Deloitte & Touche LLP 6 Shenton Way, OUE Downtown 2 #33-00 Singapore 068809 Tel: +65 6216 3290 Email: hwlow@deloitte.com Website: www2.deloitte.com/sg Low Hwee Chua, Deloitte Singapore, is a tax partner and has more than 25 years of experience in taxation services including two years with the Inland Revenue Authority of Singapore. He is also the regional managing partner for the tax practice in Deloitte Singapore and Deloitte Southeast Asia. Hwee Chua specialises in corporate income tax and international tax, working with clients to confirm their businesses' tax affairs are managed efficiently and cost effectively. Hwee Chua has extensive experience in the areas of tax compliance and tax consultancy work for local and multinational enterprises. He has also been extensively involved in providing tax advice on a wide variety of corporate tax consulting projects including restructuring, mergers and acquisitions, tax due diligence, and structuring of inbound and outbound investments. Hwee Chua has also assisted various multinational enterprises to understand what tax incentives and grants are available and the qualification criteria. Hwee Chua is an accredited tax adviser (income tax) with the Singapore Institute of Accredited Tax Professionals (SIATP), an accreditation body for tax professionals in Singapore and is also a board member of the SIATP.

Low Hwee Chua

Deloitte Singapore

Deloitte & Touche LLP

6 Shenton Way, OUE Downtown 2

#33-00

Singapore 068809

Tel: +65 6216 3290

Email: hwlow@deloitte.com

Website: www2.deloitte.com/sg

Low Hwee Chua, Deloitte Singapore, is a tax partner and has more than 25 years of experience in taxation services including two years with the Inland Revenue Authority of Singapore. He is also the regional managing partner for the tax practice in Deloitte Singapore and Deloitte Southeast Asia.

Hwee Chua specialises in corporate income tax and international tax, working with clients to confirm their businesses' tax affairs are managed efficiently and cost effectively. Hwee Chua has extensive experience in the areas of tax compliance and tax consultancy work for local and multinational enterprises. He has also been extensively involved in providing tax advice on a wide variety of corporate tax consulting projects including restructuring, mergers and acquisitions, tax due diligence, and structuring of inbound and outbound investments. Hwee Chua has also assisted various multinational enterprises to understand what tax incentives and grants are available and the qualification criteria.

Hwee Chua is an accredited tax adviser (income tax) with the Singapore Institute of Accredited Tax Professionals (SIATP), an accreditation body for tax professionals in Singapore and is also a board member of the SIATP.

Shantini Ramachandra
	Deloitte Singapore 6 Shenton Way, OUE Downtown 2, #33-00 Singapore 068809 Tel: +65 6800 2295 Fax: +65 6538 6166 Email: sramachandra@deloitte.com Website: www.deloitte.com/sg Shantini Ramachandra, Deloitte Singapore, has a Bachelor of Laws degree from the National University of Singapore and a Master of Laws degree from the University of London, King's College. She has been admitted as an advocate and solicitor of the Supreme Court of Singapore and is also an accredited tax adviser (income tax) with the Singapore Institute of Accredited Tax Professionals Limited. Shantini practised law in the area of commercial and corporate law before joining a Big 4 firm and has about 18 years of international tax experience. Shantini has been involved in major consultancy projects relating to mergers and acquisitions, developing tax efficient investment structures (both inbound and outbound), restructuring of business operations, cross-border tax reviews, dispute resolution, trust structuring, wealth planning, cash pooling, incentive planning, stamp duty and transfer pricing. She has extensive experience negotiating and dealing with the government authorities to resolve challenging tax and stamp duty issues and to obtain tax incentives and grants. Shantini leads the law firm services practice and has assisted several top tier US, UK and Australian law firms with structuring and setting up their law firm practices in Singapore and advised extensively on tax issues and regulatory matters unique to foreign law firms in Singapore including issues arising on a merger/joint venture between a foreign law firm and a local law firm. Shantini is also the South East Asia tax leader for Deloitte Private that serves business owners, family groups, and high-net-worth individuals in areas including succession planning, international tax, estate planning and wealth preservation. Shantini is a regular speaker at global conferences and external seminars in Singapore, the US and UK. She also teaches international tax modules for the master of tax programme at one of the Singapore universities as well as international tax modules at the Tax Academy and has contributed articles to various international tax publications and journals.

Shantini Ramachandra

Deloitte Singapore

6 Shenton Way, OUE Downtown 2, #33-00

Singapore 068809

Tel: +65 6800 2295

Fax: +65 6538 6166

Email: sramachandra@deloitte.com

Website: www.deloitte.com/sg

Shantini Ramachandra, Deloitte Singapore, has a Bachelor of Laws degree from the National University of Singapore and a Master of Laws degree from the University of London, King's College. She has been admitted as an advocate and solicitor of the Supreme Court of Singapore and is also an accredited tax adviser (income tax) with the Singapore Institute of Accredited Tax Professionals Limited. Shantini practised law in the area of commercial and corporate law before joining a Big 4 firm and has about 18 years of international tax experience.

Shantini has been involved in major consultancy projects relating to mergers and acquisitions, developing tax efficient investment structures (both inbound and outbound), restructuring of business operations, cross-border tax reviews, dispute resolution, trust structuring, wealth planning, cash pooling, incentive planning, stamp duty and transfer pricing. She has extensive experience negotiating and dealing with the government authorities to resolve challenging tax and stamp duty issues and to obtain tax incentives and grants.

Shantini leads the law firm services practice and has assisted several top tier US, UK and Australian law firms with structuring and setting up their law firm practices in Singapore and advised extensively on tax issues and regulatory matters unique to foreign law firms in Singapore including issues arising on a merger/joint venture between a foreign law firm and a local law firm.

Shantini is also the South East Asia tax leader for Deloitte Private that serves business owners, family groups, and high-net-worth individuals in areas including succession planning, international tax, estate planning and wealth preservation.

Shantini is a regular speaker at global conferences and external seminars in Singapore, the US and UK. She also teaches international tax modules for the master of tax programme at one of the Singapore universities as well as international tax modules at the Tax Academy and has contributed articles to various international tax publications and journals.

See Jee Chang
	Deloitte Singapore 6 Shelton Way #33-00 OUE Downtown 2 Singapore, 068809 Tel: +65 6216 3181 Email: jcsee@deloitte.com Website: www2.deloitte.com/sg See Jee Chang, Deloitte Singapore, is a partner with more than 20 years of experience in taxation. Before joining Deloitte, Jee Chang worked for the Inland Revenue Authority of Singapore (IRAS) for more than 10 years. In his role as tax director of the tax policy and international tax division, he served as Singapore's competent authority, responsible for the negotiation of advance pricing agreements (APAs) and settlement of transfer pricing disputes, and conducted tax treaty negotiations. He was significantly involved in developing the Singapore transfer pricing guidelines issued in 2006, and served as the key technical IRAS resource with regard to transfer pricing matters. He was also responsible for issuing tax rulings and IRAS circulars, supporting tax policy formulation and drafting new tax legislation, as well as collaborating with various Singapore government economic agencies on tax incentive design and implementation. Jee Chang advises and serves major multinational clients, many of whom have Singapore-based regional headquarters. He has substantial experience advising his clients on international and Asia Pacific tax and transfer pricing planning, in and outbound investment, structuring, as well as supply chain and business model optimisation. He has also successfully helped his clients resolve complex tax and transfer pricing issues with the IRAS, and obtained favourable tax incentives from the Singapore government, as well as strategic tax rulings and APAs. Jee Chang earned a bachelor of accountancy degree from the Nanyang Technological University and a master of business administration (MBA) degree from INSEAD business school. He is a regular speaker at seminars and he lectures at the Singapore Tax Academy and the IRAS internal specialist training programmes. Jee Chang is a CPA with the Institute of Certified Public Accountants of Singapore, and an accredited tax adviser with the Singapore Institute of Accredited Tax Practitioners.

See Jee Chang

Deloitte Singapore

6 Shelton Way #33-00

OUE Downtown 2

Singapore, 068809

Tel: +65 6216 3181

Email: jcsee@deloitte.com

Website: www2.deloitte.com/sg

See Jee Chang, Deloitte Singapore, is a partner with more than 20 years of experience in taxation.

Before joining Deloitte, Jee Chang worked for the Inland Revenue Authority of Singapore (IRAS) for more than 10 years. In his role as tax director of the tax policy and international tax division, he served as Singapore's competent authority, responsible for the negotiation of advance pricing agreements (APAs) and settlement of transfer pricing disputes, and conducted tax treaty negotiations. He was significantly involved in developing the Singapore transfer pricing guidelines issued in 2006, and served as the key technical IRAS resource with regard to transfer pricing matters. He was also responsible for issuing tax rulings and IRAS circulars, supporting tax policy formulation and drafting new tax legislation, as well as collaborating with various Singapore government economic agencies on tax incentive design and implementation.

Jee Chang advises and serves major multinational clients, many of whom have Singapore-based regional headquarters. He has substantial experience advising his clients on international and Asia Pacific tax and transfer pricing planning, in and outbound investment, structuring, as well as supply chain and business model optimisation. He has also successfully helped his clients resolve complex tax and transfer pricing issues with the IRAS, and obtained favourable tax incentives from the Singapore government, as well as strategic tax rulings and APAs.

Jee Chang earned a bachelor of accountancy degree from the Nanyang Technological University and a master of business administration (MBA) degree from INSEAD business school. He is a regular speaker at seminars and he lectures at the Singapore Tax Academy and the IRAS internal specialist training programmes.

Jee Chang is a CPA with the Institute of Certified Public Accountants of Singapore, and an accredited tax adviser with the Singapore Institute of Accredited Tax Practitioners.

Michael Velten
	Deloitte Singapore 6 Shenton Way OUE Downtown 2, #33-00 Singapore 068809 Tel: +65 6531 5039 Email: mvelten@deloitte.com Website: www2.deloitte.com/sg Michael Velten, Deloitte Singapore, is a financial services tax partner and a financial services tax leader for Deloitte in Asia Pacific. Michael joined Deloitte Singapore in 2013 as the Southeast Asia financial services tax leader. He has more than 30 years of tax experience, 25 years of which have been spent working in Asia, based in Kuala Lumpur, Hong Kong and Singapore. Michael advises on all areas of Singapore financial services tax including indirect tax, information reporting and transfer pricing, and coordinates the delivery of Asia regional tax services for clients. Michael regularly assists with tax audits and disputes, both in Singapore and elsewhere in the region. He has conducted tax appeals in Hong Kong, India, South Korea and Taiwan. Prior to joining Deloitte Singapore, Michael was group head of tax at a leading brokerage and investment house, and before that, he headed the Asia ex-Japan tax department of a leading global investment bank. He was also a tax partner in a Big 4 firm in Singapore and a tax partner in the Singapore office of a leading international law firm. Michael commenced his career in tax practice in Melbourne and was a senior associate with a leading Australian law firm, with a focus on tax litigation in the Federal Court of Australia. Michael holds a bachelor's degree in commerce, Bachelor of Laws and Master of Taxation degrees from the University of Melbourne. He has a Master of Laws degree from the National University of Singapore and a Master of Business Administration degree from the University of New England. Michael is qualified as both a solicitor and CPA (Australia). He is an accredited tax adviser: income tax and GST (Singapore), a certified tax adviser (Hong Kong) and an associate of the Chartered Tax Institute of Malaysia. Michael has previously held appointments as an adjunct associate professor of law at the National University of Singapore and as a visiting fellow to the University of Melbourne.

Michael Velten

Deloitte Singapore

6 Shenton Way

OUE Downtown 2, #33-00

Singapore 068809

Tel: +65 6531 5039

Email: mvelten@deloitte.com

Website: www2.deloitte.com/sg

Michael Velten, Deloitte Singapore, is a financial services tax partner and a financial services tax leader for Deloitte in Asia Pacific.

Michael joined Deloitte Singapore in 2013 as the Southeast Asia financial services tax leader. He has more than 30 years of tax experience, 25 years of which have been spent working in Asia, based in Kuala Lumpur, Hong Kong and Singapore.

Michael advises on all areas of Singapore financial services tax including indirect tax, information reporting and transfer pricing, and coordinates the delivery of Asia regional tax services for clients. Michael regularly assists with tax audits and disputes, both in Singapore and elsewhere in the region. He has conducted tax appeals in Hong Kong, India, South Korea and Taiwan.

Prior to joining Deloitte Singapore, Michael was group head of tax at a leading brokerage and investment house, and before that, he headed the Asia ex-Japan tax department of a leading global investment bank. He was also a tax partner in a Big 4 firm in Singapore and a tax partner in the Singapore office of a leading international law firm. Michael commenced his career in tax practice in Melbourne and was a senior associate with a leading Australian law firm, with a focus on tax litigation in the Federal Court of Australia.

Michael holds a bachelor's degree in commerce, Bachelor of Laws and Master of Taxation degrees from the University of Melbourne. He has a Master of Laws degree from the National University of Singapore and a Master of Business Administration degree from the University of New England. Michael is qualified as both a solicitor and CPA (Australia). He is an accredited tax adviser: income tax and GST (Singapore), a certified tax adviser (Hong Kong) and an associate of the Chartered Tax Institute of Malaysia.

Michael has previously held appointments as an adjunct associate professor of law at the National University of Singapore and as a visiting fellow to the University of Melbourne.