Dispute Resolution How to avoid; How to settle 9-10 May 2012 Chair: Mukesh Butani – Taxand India Panellists: Michael Palumbo, Asia Head of Tax – Baker Hughes Leon Kwong Wing – Taxand Singapore

1.Appeals mechanisms in Asia-Pacific; Are they working? 2.How to prepare if you are caught in a dispute 3.When a settlement is the best option 4.Tactics for jurisdictions where litigation is most likely 5.Lessons from key cases: Hong Kong cases of Li & Fung; CG Lighting and Nice Cheer Investment Limited; Singapore’s First Section 33 Case 6.Key Contacts 7.About Taxand Contents

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This Bullet is 28 pt Sub-bullet is 26 pt Sub-sub-bullet is 24 pt This is 22 pt This is 20 pt This is 18 pt This is 16 pt This is 14 pt How to prepare if you are caught in a dispute 3 2

This Bullet is 28 pt Sub-bullet is 26 pt Sub-sub-bullet is 24 pt This is 22 pt This is 20 pt This is 18 pt This is 16 pt This is 14 pt When a settlement is the best option 4 3

This Bullet is 28 pt Sub-bullet is 26 pt Sub-sub-bullet is 24 pt This is 22 pt This is 20 pt This is 18 pt This is 16 pt This is 14 pt Tactics for jurisdictions where litigation is most likely 5 4

Hong Kong cases of Li & Fung CG Lighting and Nice Cheer Investment Limited Singapore’s First Section 33 Case... Lessons from key cases 6 5

Key Contacts 7 6 Mukesh Butani Taxand India E. T Michael Palumbo Baker Hughes E. T Name TBC Firm name E. T. + Direct line number Leon Kwong Wing Taxand Singapore E. T Name TBC Firm name E. T. + Direct line number Name TBC Firm name E. T. + Direct line number

Global Coverage About Taxand 8 7 ArgentinaIndiaPoland AustraliaIndonesiaPortugal AustriaIrelandPuerto Rico BelgiumItalyRomania BrazilJapanRussia CanadaKoreaSingapore ChileLuxembourgSouth Africa ChinaMalaysiaSpain ColombiaMalta Sweden CyprusMauritiusSwitzerland CuracaoMexicoThailand DenmarkNetherlandsTurkey FinlandNorwayUK FrancePakistanUkraine GermanyPanamaUSA GreecePeruVenezuela HungaryPhilippines

Understanding and managing the tax consequences of cross-border tax transactions Considering organisational (re)structuring options in full awareness of the tax implications Realising tax, supply chain and overall operational efficiencies Interpreting technical tax provisions Lowering effective tax rates Addressing and preventing tax leakages Ensuring tax compliance Managing relationships with tax authorities Our Global Service Commitment 9 7 About Taxand

Dedicated to tax Independence advantage – conflict free, un-bureaucratic, best practice Local knowledge, global view Partner led from start to finish Complex problems, customised advice Passionate about working together Practical advice, responsively delivered Why Taxand? 10 7 About Taxand

ABOUT TAXAND Taxand provides high quality, integrated tax advice worldwide. Our tax professionals, nearly 400 tax partners and over 2,000 tax advisors in 50 countries - grasp both the fine points of tax and the broader strategic implications, helping you mitigate risk, manage your tax burden and drive the performance of your business. We're passionate about tax. We collaborate and share knowledge, capitalising on our collective expertise to provide you with high quality, tailored advice that helps relieve the pressures associated with making complex tax decisions. We're also independent—ensuring that you adhere both to best practice and to tax law and that we remain free from time- consuming audit-based conflict checks. This enables us to deliver practical advice, responsively. Taxand is a global organisation of tax advisory firms. Each firm in each country is a separate and independent legal entity responsible for delivering client services. © Copyright Taxand Economic Interest Grouping 2012 Registered office: 1B Heienhaff, L-1736 Senningerberg – RCS Luxembourg C68

Event Speaker Guidelines 9-10 May 2012

Each presentation should: be interesting for our key audiences – CFOs & Tax Directors of multinationals – ask your clients what they’d like to head about... be topical, share Taxand opinion (Taxand’s Take) on the impact of the tax issue(s) for multinationals, forecasting future change include at least 1 golden nugget/action for clients to take away use case studies to add colour – co-presented with a client where possible Content Development 13 1 Speaker Guidelines

Each presentation should: provide a global picture where possible to reflect our global capability showcase our service lines capability be different – eg consider conducting a survey across Taxanders to substantiate a view Content Development 14 1 Speaker Guidelines

Each presentation should have: beginning – say what you are going to say – introduction middle – say it – the detail end – say it again – conclusions / action points Appendices: should not be presented but provided to add depth to the delegate pack, which includes the full presentation and additional materials Structure 15 1 Speaker Guidelines

Include biographies and contact details of speakers and relevant global Taxand teams provide added value material eg full findings of surveys; additional case studies; details supporting the slides see credentials on the Taxand Brand Centre: for sample supporting slides Structure 16 1 Speaker Guidelines

Use the Taxand events presentation template at to build your presentation Every slide must contain 3 to 6 bullet points ONLY Text should be a MINIMUM of 28 point font – Arial Charts and objects should be clear Use the Taxand colour palette and colour scheme objects provided Format 17 1 Speaker Guidelines

Make sure you complete the black & blue title bar (see above) in this PowerPoint template with your section number and section title For an hour’s presentation do no more than 30 slides (2 minutes per slide) Don’t go overboard on bullets – use pictures to add interest Keep sentences short – use clear language, highlight key points & summarise Format 18 1 Speaker Guidelines

To ensure quality presentations – plan ahead: Draft structure of presentations Arrange phone call or meeting of speakers to discuss presentation content & deadlines for drafts: First full draft; Second full draft; Final draft Arrange timed speaker rehearsal by phone Leave time to correctly and consistently format slides so they are on Taxand brand Arrange on-site speaker rehearsal Process 19 1 Speaker Guidelines

You are representing Taxand to: Develop business opportunities for you, your firm and Taxand Raise your personal profile Raise our global brand awareness So please: Introduce yourself as a Taxander Refer to your Taxand colleagues when you can by name And Remember Speaker Guidelines

Promote our global capability, high quality and excellence Make sure your presentation gets sent to Lynne at to be promoted on Give it your all and go for it! Please refer any queries to global marketing at And Remember Speaker Guidelines

Key Contacts Speaker Guidelines 22 1 Abbie Tarren E. T M Lynne Sandland E. T M

ABOUT TAXAND Taxand provides high quality, integrated tax advice worldwide. Our tax professionals, nearly 400 tax partners and over 2,000 tax advisors in 50 countries - grasp both the fine points of tax and the broader strategic implications, helping you mitigate risk, manage your tax burden and drive the performance of your business. We're passionate about tax. We collaborate and share knowledge, capitalising on our collective expertise to provide you with high quality, tailored advice that helps relieve the pressures associated with making complex tax decisions. We're also independent—ensuring that you adhere both to best practice and to tax law and that we remain free from time- consuming audit-based conflict checks. This enables us to deliver practical advice, responsively. Taxand is a global organisation of tax advisory firms. Each firm in each country is a separate and independent legal entity responsible for delivering client services. © Copyright Taxand Economic Interest Grouping 2012 Registered office: 1B Heienhaff, L-1736 Senningerberg – RCS Luxembourg C68