Singapore

PwC Singapore

8 Cross Street #17-00

PWC Building

Singapore 048424

Singapore

Tel: +65 6236 3758

Email: sui.fun.chai@sg.pwc.com

Website: www.pwc.com/taxcontroversy

Sui Fun Chai is a partner with global structuring at PwC Singapore. She joined PwC Singapore in July 2013. Sui Fun focuses on the transfer pricing practice of the firm and plays a leading role in the tax controversy and dispute resolution space.

Sui Fun has 30 years of tax experience as a senior tax administrator, external tax adviser and in-house global tax director.

Before joining PwC Singapore, Sui Fun was the assistant commissioner for tax policy and international tax at the Inland Revenue Authority of Singapore and served as a Competent Authority of Singapore. In this role, Sui Fun actively supported the Singapore's Ministry of Finance and worked closely with economic agencies such as the Singapore Economic Development Board and IE Singapore to formulate and implement tax policies, tax changes and tax-related economic and social programs. She was responsible for interpreting and clarifying the application of tax laws for taxpayers, including corporates. In her capacity as Competent Authority of Singapore, Sui Fun represented the Singapore government in tax treaty negotiations/ other international tax matters. She also helped lead and successfully resolve more than 40 bilateral/multilateral advance pricing arrangements (APAs) and mutual agreement procedure (MAP) cases, which provided significant tax certainty and relief from double taxation for the multinational enterprises concerned. These include bilateral APAs and double taxation cases between Singapore and Japan, Australia, China, UK and several other jurisdictions.

Sui Fun has extensive experience in supporting multinational enterprises in managing complex cross-border tax controversies and mitigating the related tax exposures. Since joining PwC Singapore, she has worked closely with several multinational clients on addressing business transformation (including transfer pricing) issues and establishing robust transfer pricing policies/documentation practices. She has also advised them on tax defence strategies for both domestic and cross-border tax matters and assisted multinational groups to secure tax certainty through APAs and relief from double taxation through the MAP process. Together with her tax administration and in-house tax experience, Sui Fun is able to provide a balanced and pragmatic perspective to clients in managing their tax exposures.

Sui Fun has a master's degree in public administration/international tax programme from Harvard University and a bachelor's degree in accountancy, with honours, from the National University of Singapore.

Deloitte Singapore

Deloitte & Touche LLP

6 Shenton Way, OUE Downtown 2

#33-00

Singapore 068809

Singapore

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 20 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.

PwC Singapore

8 Cross Street#17-00 PwC Building

Singapore 048424

Singapore

Tel: +65 6236 3618

Email: nicole.fung@sg.pwc.com

Website: www.pwc.com/taxcontroversy

Nicole Fung is a tax partner and has led the transfer pricing practice in PwC Singapore for 12 years. She has over 25 years of experience advising on international tax and transfer pricing. In addition, she has been the regional relationship partner for European multinationals, responsible for all their tax matters in the Asia-Pacific region and working closely with the PwC network to ensure alignment and consistency in any advice provided.

She has led major transfer pricing strategy and dispute resolution projects for multinational enterprises and negotiations with government authorities both in Singapore as well as other countries in the region. In this respect, Nicole has been involved in cross-border transfer pricing resolution cases since 2003 and has been involved in the bilateral APAs between Singapore and Japan, China, Taiwan, Australia, UK, South Korea, Denmark, Switzerland and France, many of which are first bilateral agreements between the countries.

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

Nicole is a frequent speaker on transfer pricing related topics and has spoken at several workshops and seminars for clients across various levels and tax authorities in Singapore and Vietnam.

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

Deloitte Singapore

6 Shenton Way

OUE Downtown 2, #33-00

Singapore 068809

Singapore

Tel: +65 6216 3189

Fax: +65 6538 6166

Email: danho@deloitte.com

Website: www2.deloitte.com/sg

Daniel Ho, Deloitte Singapore, is a partner with more than 17 years of tax experience in serving local and listed companies in Singapore, as well as multinational enterprises 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 and planning in the areas of corporate restructuring, supply-chain planning, 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 written an article on R&D 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 Nanyang Technological University with a bachelor's degree, with honours, in accountancy 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 Shipping Association tax sub-committee.

Deloitte Singapore

6 Shenton Way #33-00

OUE Downtown 2

Singapore 068809

Singapore

Tel: +65 6216 3262

Email: thlee@deloitte.com

Website: www2.deloitte.com/sg

Lee Tiong Heng, Deloitte Singapore, has more than 19 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 grants applications from the Singapore government authorities.

Tiong Heng leads the RDGI (development, 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.

Deloitte Singapore

6 Shelton Way #33-00

OUE Downtown 2

Singapore, 068809

Singapore

Tel: +65 6216 3181

Email: jcsee@deloitte.com

Website: www2.deloitte.com/sg

See Jee Chang, Deloitte Singapore, is a partner with more than 18 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 head- quarters. 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.

Deloitte Singapore

6 Shenton Way

OUE Downtown 2, #33-00, Singapore 068809

Singapore

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 over 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 bachelors 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.