2020 Queensland Tax Forum - 21-22 May 2020 | Stamford Plaza, Brisbane 13 CPD hours
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Welcome Managing Tax in a Transparent World Thank you The Tax Institute gratefully acknowledges the generous assistance of the 2020 Queensland Tax Forum Organising The exponential creation and use of data have forever changed the management of tax. Businesses must improve their Committee: analysis and interpretation of data to remain competitive. Data has changed the expectations for tax practitioners, in-house tax functions and regulators alike. The tax community has already experienced the first wave of significant legislative and Evan Last, CTA, Deloitte administrative reform resulting from the G20’s response to the OECD’s BEPS project, and now faces the second wave of (Chair, 2020 Queensland Tax Forum Organising Committee) data-driven tax disruption. This program is designed to provide an in-depth understanding of the changing landscape and to SME Stream Committee: equip tax professionals with the necessary technical skills and practical knowledge to manage tax in a transparent world. Angie Hicks, CTA, KPMG (Chair) The 2020 Organising Committee is delighted to welcome John Dardo, who will set the scene by providing insight into the Adam Hijazi, Deloitte Legal ATO’s access to and use of data, including the ATO’s ongoing digital transformation under his role as Chief Digital Officer. Claire Roberts, ATI, Hoffman Kelly We also look forward to a lively and thought provoking discussion with our expert commentators Mark Robertson QC, CTA, Linda Tapiolas, CTA and Grant Wardell-Johnson, CTA on the design and effectiveness of the CGT rollovers following the Joanne Casburn, FTI, Australian Taxation Office Board of Taxation’s review. We’re confident this debate will continue at the networking drinks on Thursday evening and we Katherine Patel, FTI, HLB Mann Judd look forward to bringing together the SME, Corporate, and Young Tax Professionals streams – who knows, you might meet Leisa Rafter, CTA, BDO your future employer/employee or next client engagement! Melinda Peters, CTA, McCullough Robertson The 2020 program has been unapologetically designed to focus on expert-led technical sessions that provide participants Corporate Stream Committee: with the practical insights and skills to navigate the changing tax architecture in a transparent world. With sessions covering topical issues surrounding tax consolidation, Div 100A, superannuation, M&A, capital management, and GST, and a plenary Peter Dunn, EY (Chair) session delivered by Jeremy Geale, CTA and Ali Noroozi, FTI on the evolution of taxpayer engagement with the ATO, Abhi Aggarwal, PwC the Queensland Tax Forum will set the scene for the next decade of tax. Alison Feather, CTA, Aurizon On behalf of the stream chairs, Angie Hicks, CTA, Peter Dunn and Dominic Moon, ATI, and the 2020 Organising Committee, Dritton Xhemajlaj, ATI, Rio Tinto I commend this program to you and look forward to seeing you in May at the 2020 Queensland Tax Forum. Elliott Cunningham, CTA, QIC Rhiain Garrihy, CTA, Suncorp Young Tax Professionals Committee: Dominic Moon, ATI, Deloitte Legal (Chair) Evan Last, CTA, Deloitte Adam Hijazi, Deloitte Legal Chair, 2020 Queensland Tax Forum Organising Committee Tom Polkinghorne, Grant Thornton Tom Walrut, FTI, Merthyr Law Early bird offer Register on or before Friday, 17 April 2020 to save! 2 THE TAX INSTITUTE – 2020 Queensland Tax Forum
Technical program Day 1 – Thursday, 21 May 2020 Time Plenary 8.00 – 8.30am Registration 8.30 – 8.45am President’s welcome Speaker: Peter Godber, CTA, President – The Tax Institute 8.45 – 9.00am Opening address Speaker: Evan Last, CTA, Chair, 2020 Queensland Tax Forum Organising Committee 9.00 –10.00am Session 1: Keynote: Data sharing Speaker: John Dardo, Chief Digital Officer & Deputy Commissioner, Australian Taxation Office Have you ever wondered what the ATO knows about you or your business? This is your chance to find out: — What data the ATO has access to, including from international sources — How the ATO uses this data to encourage voluntary compliance and to improve the client experience — The future of the ATO’s digital transformation. 10.00 –10.20am Morning tea Time SME stream Corporate stream 10.20 –11.20am Session 2A: Road testing common tax strategies Session 2B: BEPS 2.0 – A whole new architecture for international tax? Speaker: Tom Delany, CTA, Tax Partner Pty Ltd Facilitator: John Bland, Deloitte Tax professionals use an abundance of strategies designed to deliver optimum Panellists: Jasmine Leonard, ATI, Rio Tinto; Tom Andersen, Dominos; commercial and tax outcomes for their corporate and SME clients. However, with the Karen Young, Flight Centre expansion of the ATO Tax Avoidance Taskforce and increased use of data analytics tools This session will consider the new OECD thinking on international tax and the to identify tax risks, it is appropriate to “road test” some of those strategies. This session digitalisation of the global economy. It will include a presentation and panel discussion, will provide a critical evaluation of common tax strategies and identify where they can go and cover the following issues: wrong and how, in areas including: — I am not in a digital business, so this doesn’t apply to me, right? — Managing Div 7A loans — The existing approaches are 100 years old; why change them? — Accessing small business CGT concessions — Revision of the current nexus and profit allocation approaches – how will this — Trust distributions happen? — Dividend access shares — Global anti-base erosion approach — Business structuring — Discussion of industry-specific impacts from the panel – E&R, retail. — Recent developments. 2020 Queensland Tax Forum taxinstitute.com.au 3
Technical program Day 1 – Thursday, 21 May 2020 continued Time SME stream Corporate stream Young Tax Professionals stream 11.00 –11.20am Registration for Young Tax Professionals Stream 11.20am –12.20pm Session 3A: Trusts – 100A reimbursement Session 3B: Hybrids – Lessons Learnt and Session 3C: Optimising Outcomes by Effective agreements; identifying and reducing taxpayer risks Responses Negotiation Speaker: Michael McLaughlin, West Garbutt Pty Ltd Speaker: Michael Chang, CTA, EY Speakers: Scott Wedgwood, Barry Nilsson Lawyers Reimbursement agreements have been an ongoing The hybrid mismatch rules of Division 832 of the Negotiation is inevitable in professional practice, regardless area of focus for the ATO for many years. The highly ITAA 1997 are now well and truly with us. By now of your specific role, industry or organisation. Unfortunately, anticipated draft ruling is expected to issue in 2020. This most corporate taxpayers will have (or should have) many of us engage in this most complex area of human session will focus on discussing the current ATO view considered the potential relevance of the rules to their interaction without formal training or proven strategies and also proactively managing and mitigating any risks structure. This session will: to achieve success. As our client’s affairs become more in relation to reimbursement agreements. In particular transparent, developing skills to manage complex disputes — Briefly recap on the broad strokes of the rules; the session will cover: and maximise negotiated outcomes is a minimum — Consider issues that have emerged as taxpayers expectation of our clients. — The current ATO position – where has the draft ruling have grappled with their application; and landed and what is the current compliance activity? — Consider the question as to what a taxpayer This session will feature a series of real-world scenarios and — When will s 100A apply and what are the should do where it is identified that the rules have skill-building exercises to: consequences? application. — Identify and influence hidden drivers in negotiations — What steps can taxpayers take to reduce any — Successfully negotiate through a range of circumstances identified risks, including documenting positions and — Effectively and strategically prepare for negotiations. gathering evidence, particularly about ordinary family or commercial dealings? — Looking to the future and identifying tax planning strategies going forward. Young Tax Professionals stream The Young Tax Professionals (YTP) stream has been designed for those progressing through their tax careers, The specialised stream offers: inclusive of advisers at an intermediate to senior level. — 3 technical sessions The three technical sessions focus on building practical skills by addressing tips, traps and technical landmines, through — 4.5 CPD hours case studies and practical examples. — Opportunity to network with industry professionals The sessions have been designed to allow attendees to engage in discussion and ask questions to gain greater awareness — Attendance at Session 6 of how to address relevant and important issues in relation to these areas. — Affordable price Register for the Young Tax Professionals stream by completing the Individual Registration Form on page 19. 4 THE TAX INSTITUTE – 2020 Queensland Tax Forum
Day 1 – Thursday, 21 May 2020 continued Time SME stream Corporate stream Young Tax Professionals stream 12.20 –1.20pm Lunch 1.20 – 2.20pm Session 4A: Transparency when dealing with the ATO Session 4B: Topical issues affecting cross-border Session 4C: Objections and Audit Paper Responses – Speakers: Fletch Heinemann, CTA, Cooper Grace Ward; capital management Drafting to Win! Sarah Lancaster, Cooper Grace Ward Speakers: Kevin Griffiths, EY; Kim Christy, CTA, EY Speakers: Florence Chen – Barrister In an increasingly transparent tax landscape, the sharing of This session will provide a technical summary of key With the marked increase in transparency and access to information between taxpayers and the ATO is becoming topical tax issues affecting capital structures, including information, disputes with revenue authorities are becoming commonplace. However, there are many factors advisers perspectives on current approaches and future trends more commonplace for many professional tax practitioners. should consider when receiving a request for information. in responding to these issues. Specific matters to be Whether you are responding to an ATO audit position paper This session will focus on providing practical strategies in considered include: or lodging a formal objection, there are a number of key managing ATO reviews and audits. Topics covered include: steps and processes to be followed, to ensure you are best — Thin capitalisation developments placed to achieve your client’s goals. Through a series of — Tips for the effective management of reviews from the — Re-characterisation of debt and equity instruments drafting tips and traps, this session will take a deep dive outset through operation of transfer pricing rules into: — Responding to information gathering requests (including — Other relevant income tax and transfer pricing matters. formal requests for information, documents and — Key preparatory steps to undertake before you interviews) commence drafting — Practical considerations in managing claims for — Understanding your client’s position and that of the accountants’ concession and legal professional revenue authority privilege. — Drafting strategies to maximise value and get your client the best possible result. 2.20 – 3.20pm Session 5A: Corporate Tax Residency — A sensible Session 5B: GST justified trust Session 5C: Managing Clients as the Trusted Advisor Approach? Speakers: Tony Windle, ATI, Grant Thornton; Speakers: Paul Banister, CTA, Grant Thornton Speakers: Adele Townsend, CTA, BDO Alison Feather, CTA, Aurizon When it comes to your role as an advisor, it can be Taxpayers have faced ongoing change and uncertainty With the justified trust program for income tax being well dangerous to assume that everything is clear and that since the Bywater decision and ATO response through progressed, the ATO has turned its attention to GST, your client is on the same page regarding expectations. TR2018/5 and PCG2018/9. This has impacted aiming to review approximately 320 large public and Now, with regulatory scrutiny on the rise, it is essential commercial enterprise and increased red tape and multinational businesses over four years. This session that advisors develop skills to manage expectations and compliance particularly for start-ups and SMEs. Will will cover: improve relationships with their clients to help them through the Board of Taxation review trigger clear, practical the many uncertainties faced in today’s transparent world. — An overview of the GST SAR program and sensible reform? This session will analyse the This session will draw on real experiences with clients — Analytics being undertaken by the ATO in respect of ramifications for SMEs of the reforms proposed by the and cover: GST, including the GST analytical tool (GAT) Board of Taxation review, including: — Common technical positions arising as part of the — Setting and effectively managing client expectations — Corporate tax residence redefined GST SAR program. — Strategies for dealing with a range of clients in complex — Interaction with other domestic income tax rules situations — Comparison with international tax reform including — Handling difficult conversations and communicating with tax treaties and other jurisdictions. impact. 3.20 – 3.40pm Afternoon tea 2020 Queensland Tax Forum taxinstitute.com.au 5
Technical program Lead the way in tax Day 1 – Thursday, 21 May 2020 continued Time Plenary There is no time like the present to 3.40 – 5.10pm Session 6: CGT Rollovers: Policy, Practice and Points of Contention join Australia’s premier tax body Facilitator: John Ioannou, CTA, Deloitte Legal and take advantage of the special Speakers: Grant Wardell-Johnson, CTA, KPMG; Mark Robertson, QC, CTA, Queensland Bar, Linda Tapiolas, new member introductory offer. CTA, Cooper Grace Ward Lawyers The Board of Taxation’s review into CGT rollovers is a prompt to consider policy, practice and disputes. As private For an additional $340 on the member advisers move to consulting from compliance the growing use of provisions historically aimed at widely held registration fee you will receive membership enterprise by closely held enterprise is met head on by a narrowing of applicable circumstances. through to June the following year. Consequently, each speaker has in-depth experience respectively in policy, practice and disputes with a view to the three being brought together to allow delegates to gain a whole of picture understanding of the issues at play. Member benefits include: The session will cover the growing day to day issues with use of the rollovers, current policy, what new law should – Taxation in Australia journal look like and areas of contention to be aware of for those utilising the provisions in the current climate. – TaxVine e-newsletter – CPD event discounts 5.10 – 6.30pm Networking drinks and canapés – Publications and tax product discounts – Business Alliance Partner discounts. Become a member See registration form or visit Join the conversation taxinstitute.com.au/events for a list of upcoming events. facebook.com/thetaxinstitute twitter.com/taxinstituteoz blog.taxinstitute.com.au linkedin.com/company/the-tax-institute 6 THE TAX INSTITUTE – 2020 Queensland Tax Forum
Day 2 – Friday, 22 May 2020 Time Plenary 8.00 – 8.30am Registration 8.30 –10.00am Session 7: ATO engagement – Then, now and tomorrow Speakers: Jeremy Geale, CTA, Deputy Commissioner, Australian Taxation Office; Ali Noroozi, FTI, PwC The focus of the session is a balanced discussion around the evolution of taxpayer engagement with the ATO – what have we learnt from the past?, the current state of play and where do we want to get to in the future? It will include: — Brief overview on the topic — Facilitated question and answer session with the audience. Time SME stream Corporate stream 10.00 –11.00am Session 8A: Superannuation – Top five mistakes trustees and accountants are Session 8B: Managing information reporting obligations in a transparent making environment Speaker: Sharlene Anderson, Veritas Audit Speaker: Stephanie Lam, PwC SMSFs hold more wealth than ever before and often hold unique assets. This session This session will provide an overview and practical experiences of the different looks at some common errors both accountants and trustees are making, which information reporting obligations and regimes regulated by the ATO that currently exist jeopardise the wealth that has been accumulated. With an increasingly transparent for Australian taxpayers. These obligations and regimes are relevant for both financial compliance and audit environment, this session will provide case studies and practical institutions and non-financial institutions (including in respect of any accounts or guidance on how to avoid making these mistakes. Areas covered in this session will investments held by such taxpayers in financial institutions). The session will cover: include: — Foreign Account Tax Compliance Act and Common Reporting Standard — Market valuation of assets — Third-party reporting — Tax residency of an SMSF — Annual investment income reporting — Non-arm’s length income and expenses — Tax Transparency Code and public reporting of tax information — In-house assets — Other cross-border initiatives on information sharing and multilateral conventions. — Liability for accountants and auditors. 11.00 –11.20am Morning tea 2020 Queensland Tax Forum taxinstitute.com.au 7
Technical program Day 2 – Friday, 22 May 2020 continued Time SME stream Corporate stream 11.20am –12.20pm Session 9A: Recruiting and retaining top talent Session 9B: Managing uncertainty in a transparent environment Speakers: Melinda Peters, CTA, McCullough Robertson; Aaron Dahl, McCullough Speakers: Abhi Aggarwal, PwC; Rohan Porter, Flight Centre Robertson This session will provide an overview of recent taxpayer alerts, draft tax determinations, With the war for talent across a range of industries, and employees increasingly looking ATO public guidance and consultation papers, and various tax law amendments to participate in the company they work for, many private companies are looking to proposed or announced by Treasury. Despite best intentions, the existence of such incentivise their staff via the use of equity incentives. There is no “one-size-fits-all” materials creates some uncertainty and can make it challenging for taxpayers to comply approach to incentive plans and there are a number of factors to be weighed in ensuring with the requirements of the tax law and with their tax risk governance framework. The that the plan operates as an effective incentive. session will cover: This session will take a practical look at the key issues which arise when employee — Examples of relevant positions and scenarios that can create uncertainty equity incentive arrangements are implemented by private companies – in particular: — Practical strategies to identify and manage tax risk in such uncertainty — Considerations when designing an appropriate incentive scheme and current — Reporting of positions taken in the reportable tax position schedule. market trends — Structuring alternatives and the current tax landscape — Managing Corporations Act and reporting obligations — Effective management of employee incentives in M&A transactions. 12.20 –1.20pm Lunch 1.20 – 2.20pm Session 10A: The Future of Artificial Intelligence in Taxation Session 10B: Corporate M&A at the outset of the 2020s Speaker: Alex Ferguson, REDD Digital Speakers: Evan Last, CTA, Deloitte; Nick Allen-Waters, Deloitte The window for competitive differentiation in AI is closing and organizations which “Hindsight is 20/20” can be an uncomfortable reflection for organisations at the end are not investing stand to fall behind in terms of their share of the estimated $3.9T of of a complex M&A transaction process. This session will provide an update of topical business value Gartner predicts will be created by 2022. One key concern is how to issues relevant to corporates engaging in M&A transactions as we enter a new decade build the competitive business advantages which Artificial Intelligence can offer and and draw on practical examples of managing related opportunities and risks during a recognising that Taxation is an industry that is prime for disruption. In this presentation transaction process. Topics will include: we address: — Placing value on tax losses and the challenges posed by organisations with uneven — The future of Artificial Intelligence share structures — Artificial Intelligence and its applicability to managing tax affairs — Financing, including the growing complexity in obtaining certainty with respect to — Defining an AI expert in Tax Law and ITAA 1997 interest deductibility — A rise in Chatbots and Virtual Assistants for Tax — Implications on diligence and transaction processes of the ATO’s continued roll-out — Case study: H&R Block an IBM Watson for Tax Preparation of the justified trust program and other measures. — Case study: Regulation as a Platform by CSIRO-Data61 2.20 – 2.40pm Afternoon tea 8 THE TAX INSTITUTE – 2020 Queensland Tax Forum
Day 2 – Friday, 22 May 2020 continued Time SME stream Corporate stream 2.40 – 3.40pm Session 11A: What happens where the intended use of property changes? Session 11B: Accounting standard and interpretation changes: what is the tax Speaker: Sian Sinclair, CTA, Grant Thornton impact? Real estate has traditionally been an accessible and versatile investment for SME’s and Speakers: Ben Seumahu, KPMG; Michael Robbins, KPMG high net worth individuals. Practitioners and advisors are often being asked to advise Australian companies are in the midst of significant changes in accounting standards, taxpayers on the taxation implications arising from a change in the intended use of their impacting both measurement and disclosure in financial statements. Failure to fully property over their ownership period. This session explores both direct and indirect tax understand accounting profit can mean incorrect tax adjustments, incorrect financial consequences arising from the change of intention, including: statement disclosures and, ultimately, an incorrect income tax return. This session will update you on accounting standards and interpretation changes impacting tax, — Income tax consequences arising from change of purpose: starting and ceasing to including: hold property as trading stock — Capital Gains Tax outcomes when intended use changes — Disclosure of uncertain tax positions — GST consequences, adjustments and applicability of the GST Margin Scheme — The impact of new accounting standards such as AASB 16 (leases) and AASB 15 (customer revenue) — Deferred tax accounting for intangible assets – expected IFRIC decision on the dual tax base approach for intangible assets. 3.40 – 4.40pm Session 12A: Tax consolidation Session 12B: Outbound investment issues Speaker: Dominic Moon, ATI, Deloitte Legal Speaker: Paul Mills, Paul Mills Consulting Pty Ltd Tax consolidation continues to grow in popularity for many SME groups and, in some The OECD’s action plan with respect to base erosion and profit shifting (BEPS), and cases, may become a practical necessity. Although the regime is often associated with particularly Australia’s legislative responses to the recommendations, have pushed structuring of large corporations, there are many tax and commercial benefits in an the focus of corporates and advisers to new developments such as our multinational SME context. Consolidation also provides an opportunity for SME groups to alleviate anti-avoidance laws (MAAL), diverted profits tax (DPT) and anti-hybrid measures. structural pressures on compliance, which is relevant in light of numerous measures Understanding these measures is imperative in an international tax landscape. Core being introduced to increase transparency of tax information in Australia. international tax matters remain important. When it comes to outbound investment, key considerations are: This session is based on a practical worked example and will cover: — Tax residency for foreign subsidiaries — The lifecycle of SME structures — Controlled foreign company (CFC) rules — Common pressure points and solutions for outdated structures — Repatriation – taxation of dividends, conduit foreign income, withholding taxes — Why consolidate in an SME context and who can do it? — Foreign hybrid and anti-hybrid rules — Membership rules and mixed entity groups (companies and trusts) – what’s in and what’s out? — Disposal – active foreign business assets percentage (AFBAP). — When the rules can change – bringing in or exiting subsidiaries and acquiring other consolidated groups. 4.40 – 5.30pm Forum close drinks 2020 Queensland Tax Forum taxinstitute.com.au 9
Presenter profiles Abhi Aggarwal is a Partner in PwC’s corporate and indirect taxes, revenue 22 years and brings almost 35 years tax the financial services industry, advising on corporate tax practice in Queensland. He authority audits, and tax related financial experience to his role. Prior to working at a range of matters including tax efficient focuses on providing taxation advice to reporting disclosures. Deloitte he served 10 years in the ATO in structuring of domestic and foreign local and multinational organisations and Brisbane. John has wide experience across investments. She has been involved in collective investment vehicles in relation Sharlene Anderson is the principal the gamut of transfer pricing technical the tax aspects of a number of significant to domestic and international mergers, of Veritas Forensics which provides issues, but has had a focus on energy and capital raisings, including both initial and acquisitions, divestments, refinancing specialist audit services, litigation support resources transfer pricing matters including subsequent equity raisings for listed arrangements and other transactions. and business valuation services. Highly commodity trading, financing and supply and unlisted entities. Kimberley also has In particular, Abhi specialises in providing regarded in her field of expertise, Sharlene chain issues. broad experience advising clients in their such advice to the financial services and has significant experience auditing across interactions with the Australian Taxation infrastructure industries. various legislative frameworks, and is known Michael Chang, CTA is a partner with Office and has assisted clients with both for her practical approach. Sharlene is a EY Brisbane with 18 years’ experience. standard ATO programs such as top 1000 Nick Allen-Waters, is a Director at Deloitte Registered Company Auditor, Approved During his career he has worked in various reviews and continuous engagement with over 11 years experience advising SMSF Auditor and a Forensic Accountant. areas of corporate and international taxation processes, as well as the strategic aspects on transactions and other corporate tax in Australia. Michael works within the Paul Banister, CTA is a Chartered of managing disputes. matters. He regularly advises institutional Transaction Tax group, focussing on M&A investors, private equity funds, government Accountant and a Partner at Grant transactions. Michael also leads the EY Oil Aaron Dahl has extensive advisory and and other domestic and foreign-owned Thornton, leading their tax division in & Gas industry tax focus in Queensland and transactional experience in a broad range groups in connection with M&A transactions, Brisbane. He has over 30 years’ experience is the head of EY Brisbane’s China Business of corporate and commercial matters. projects and restructures across a variety of working with clients to help them navigate Group. Aaron’s experience includes mergers industries including infrastructure, financial through complex and potentially risky and acquisitions, recapitalisations, public services and consumer sectors. Nick is a tax and commercial issues. His expertise Florence Chen is a barrister at Level 27 and private capital raising and general member of Chartered Accountants Australia includes domestic and international tax Chambers and was named as a Doyle’s commercial advisory in the resources and New Zealand. planning, transaction advisory and support, Guide Leading Tax Barrister Queensland and renewables, health, pharmaceutical superannuation structuring and advice, (Recommended) in 2019. She has had a technology and not for profit sectors. Tom Andersen, is the Group Tax Manager succession planning and estate planning. wide range of experience in both State and for Domino’s Pizza Enterprises Ltd. He Aaron is often engaged by clients to provide Paul has presented at many professional Federal tax and has advised and appeared guidance on corporate governance issues has over 12 years of experience working and business forums, both in Australia and in matters involving Payroll Tax, Land Tax, in a variety of industries and roles with and advice regarding directors’ duties. internationally. He is a contributing author Stamp Duty, Part IVC Proceedings, Income the majority being tax focused. As the to Thomson Reuter’s Financial Planning Tax, and Superannuation. Florence is also In providing advice, Aaron draws on the Group Tax Manager for an Australian Handbook. Paul is also the recipient of a proactive member of the legal community knowledge of his clients’ industries to ensure headquartered company with subsidiaries in The Tax Institute’s SME Tax Adviser of the and currently sits on the Bar Association he offers commercial and practical solutions. 9 countries he is responsible for ensuring the Year Award for 2016. of Queensland Bar Council and is a former Aaron is well versed and has a particular group’s tax affairs are in order. Before this he President of the Queensland Young Lawyers. interest in structuring and advising on worked on the Australian and New Zealand John Bland is a tax Principal (retired employee incentive arrangements and acts tax of a Swiss based multinational. He Partner) with the national transfer pricing Kimberley Christy, CTA is a Director at for a number of large offshore companies has experience with foreign and domestic team of Deloitte Australia. Based in EY with 15 years’ income tax experience. in relation to their Australian incentive acquisitions, restructures, transfer pricing, Brisbane, he has been with Deloitte for Kimberley specialises in income tax for programs. 10 THE TAX INSTITUTE – 2020 Queensland Tax Forum
John Dardo, is the ATO’s Chief Digital tax experience, working in both professional Kevin Griffiths is the Lead Partner of succession and asset protection planning. Officer and is responsible for setting services for PwC and as an in-house tax EY’s Transfer Pricing Group in Queensland John has a Bachelor of Arts, Bachelor of the ATO’s digital agenda, designing the advisor for Aurizon. Alison is responsible and also the Leader of the broader EY Tax Laws and a Master of Law. He is Chair end-to-end digital experience and delivery for managing all of Aurizon’s tax matters, Division in Queensland. With over 25 years of the Tax Institute’s Queensland’s State of key components of the digital agenda, including tax aspects of infrastructure of experience in corporate and international Council in addition to being a State including digital identity, authentication and projects. tax, Kevin has spent the last 20 years Councillor. authorisation services, ATO digital interfaces, working with clients to design, structure SBR platforms, Application Programme Alex Ferguson is the Director of Digital and implement defendable transfer pricing Stephanie Lam is a director in PwC’s Interfaces, and the establishment of the Projects at REDD Digital and is a degree arrangements. During that time, Kevin has financial services tax practice in Brisbane. Digital Partnership Office. qualified aerospace engineer, executive also led the successful management and She has over 11 years’ experience in MBA, and a passionate and effective leader. resolution of significant transfer pricing advising clients in the funds management, John has worked as a senior executive He enjoys helping people and organisations disputes and advance pricing agreement superannuation, banking, insurance, managing a range of ATO functions including implement business-improving solutions negotiations across multiple jurisdictions. property and infrastructure industries. contact centres, digital transformation, compliance and business registries. During using Digital Best Practice. As a Registered Kevin is a Chartered Accountant both in Stephanie’s experience includes advising on this time, he has delivered numerous Project Manager (MAIPM, CPPM) he Australia and the UK, is a member of the the taxation of trusts and superannuation innovations such as the introduction of voice has experience across a broad range of Australian Institute of Company Directors funds, domestic and international biometrics for over 5 million ATO clients, infrastructure, buildings and mission critical and also sits as a Director on the Board of investment structures, tax compliance, myGov capability for 9.6 million clients and systems with experience delivering Data the Brisbane Powerhouse. and tax information reporting (including new authentication techniques to retire Intelligence including Machine Learning and FATCA and CRS). Stephanie is a member Fletch Heinemann, CTA is a partner in of Chartered Accountants Australia and AUSkey. Artificial Intelligence solutions for small to Cooper Grace Ward Lawyers’ tax team. New Zealand. medium enterprise. Tom Delany, CTA is the principal of Tax Fletch specialises in tax and customs Partner Pty Ltd, which provides tax training, Jeremy Geale, CTA is the Deputy disputes. His experience includes helping Sarah Lancaster is a special counsel in the and tax consultancy services to accounting Commissioner for Review and Dispute clients with private rulings, audits, objections tax team at Cooper Grace Ward Lawyers. and legal firms including a wide range of and litigation. He also assists clients Sarah assists clients in all stages of a Resolution, an independent area within tax advisory services such as high-level tax by providing tax advice across a range dispute with Australian revenue authorities. the ATO responsible for the ATO’s planning in addition to preparing tax advices, of commercial issues. Fletch has also She has appeared in and managed approach to dispute resolution for all private ruling requests and objections on presented sessions at The Tax Institute’s appeals in the Federal and State Tribunals, taxpayers. This includes responsibility for a variety of tax related topics. Tom holds Queensland seminars and national the Federal Court and Supreme Court of Independent Review of large corporate a Master of Taxation from the University of conferences and has published papers on Queensland. and small business audits, all objections New South Wales, a Bachelor of Business topical tax and customs issues. and litigation, the ATO in-house facilitation Evan Last, CTA is a Partner in the Deloitte (with Distinction) from the University of service, other ADR approaches, the John Ioannou, CTA was admitted as a Brisbane tax practice and leads the M&A Southern Queensland, is a FCPA, FIPA, Independent Assurance of Settlements Solicitor in 2002 and is a Legal Practitioner tax team. He has significant experience Chartered Accountant, Tax Agent and a service, the Test Case Litigation Panel and Director of Deloitte Legal and a partner in advising clients on the international Chartered Tax Adviser. Dispute Assist. Jeremy joined the ATO in of Deloitte. He has experience in the tax aspects of inbound and outbound Alison Feather, CTA is Manager Group Tax January 2016, as the Deputy Chief Tax areas of taxation, structuring, commercial investments, tax due diligence and at Aurizon. She has over 10 years corporate Counsel. transactions, disputes, trusts and estates, transaction support, tax consolidations, 2020 Queensland Tax Forum taxinstitute.com.au 11
Presenter profiles continued cross-border financing and tax-effect national tax education program, which regulatory environment. During his tenure, Michael Robbins is a partner at KPMG accounting. Evan is a Queensland State has allowed the development of technical the office of the IGT grew four times in Enterprise and has over 16 years’ tax, Councillor for The Tax Institute and is also expertise in a broad range of corporate size and its role was expanded to that accounting and business advisory a Chartered Accountant. tax matters. Paul is now operating a tax of an ombudsman with respect to tax experience advising clients in a variety of consulting business of his own, Paul Mills administration. industries, ranging from large companies Jasmine Leonard, ATI is a Tax Advisory Consulting Pty Ltd. and corporate groups, private companies at Rio Tinto. Jasmine has extensive Prior to becoming the IGT, Ali was the Tax Counsel at Chartered Accountants Australia to high net wealth individuals. Michael’s experience in advising on mergers and Dominic Moon, ATI is a Special Counsel areas of focus include business sales and acquisitions for Rio Tinto and has over at Deloitte Private with expertise in and New Zealand having already worked at acquisitions, restructures, tax consolidation, 15 years of experience in corporate and taxation, estate planning and commercial large accounting and law firms in Australia tax effect accounting, tax loss recoupment mining taxation matters. Jasmine is a law. Dominic’s strength is in his ability to and the United Kingdom. and international transactions. member of the Minerals Council of Australia research, comprehend and implement Melinda Peters, CTA is a specialist tax Taxation Committee and holds a Masters in complex transactions for his clients with Mark Robertson, QC, CTA conducts and duty lawyer, focusing on corporate Taxation Law. a focus on achieving strong commercial an Australia-wide practice specialising in and taxation outcomes. Over the past few and transaction structuring at McCullough revenue and trust law, Mark is listed as Michael McLaughlin is a qualified lawyer years, he has built a substantial following Robertson. Melinda currently acts for a leading tax QC by Chambers & Partners at West Garbutt specialising in transaction of Accountants and Financial Planners who multinational corporations with Australian Asia Pacific 2019 and listed as ‘Preeminent’ taxation and structuring as well as litigious rely on his technical expertise to service the resource interests, a number of ASX-listed by Doyle’s Guide 2018. He has appeared disputes with the Australian Taxation needs of their clients. While Dominic has companies, widely held investment funds for commonwealth and state revenue Office (ATO). Michael has over ten years’ worked across many different industries, and a number of Australian start-ups. authorities, Australia’s leading corporate experience providing technical advice he has developed specialised knowledge in In addition to providing transaction groups, high net wealth individuals, as well on various aspects of the taxation law, professional services, pharmacy, transport structuring advice and tax opinions, as foreign investors in relation to proposed drawing on his transaction and dispute/ and extractive industries. Melinda advises on employee incentive and completed domestic and cross-border litigation expertise and experience in roles arrangements for both listed and private transactions (including in estate and family with leading Australian law firms and major Ali Noroozi, FTI has Bachelor degrees in groups. She also regularly acts for clients law contexts). Engineering and Law as well as a Master of in taxation objections and disputes with international accounting firms. Michael has Laws degree in Taxation. He has 27 years the ATO. Ben Seumahu, is a Director at KPMG, acted for publicly listed and large private of experience in taxation and is currently a with over 25 years’ experience providing groups in both buy side and sell side tax partner at PwC where his role includes Rohan Porter, has over 20 years of tax accounting advice to entities across a transactions, as well as major restructures assisting clients in their engagement with the experience shared evenly between the range of industries, including mining, and corporate dealings. His transaction Australian Taxation Office. profession and commerce. In his more financial services, government and software work often involves liaising with the ATO and Ali may be better known for his recent roles as Head of Tax at Virgin companies. Ben also supports engagement seeking clearance through the ruling and achievements as the Inspector-General Australia, and as a senior member of the teams resolve complex finance reporting early engagement systems. of Taxation (IGT), a position he held for Flight Centre Global Tax team, Rohan has issues as part of his role in KPMG’s centre of Paul Mills worked in the PwC corporate 10 years from 2008 to 2018. He became engaged with Executives, Boards and the excellence for technical accounting. Ben has tax practice for 20 years, for the main part known as an energetic senior statutory ATO with managing corporate initiatives and a specialisation in deferred tax accounting, focusing on mining and energy clients. In appointee who was highly respected by strategies in the changing tax governance and is a member of KPMG’s Asia Pacific his last seven years at PwC, Paul ran the all side of politics, overseeing a complex and reporting environment. Income Taxes topic team. 12 THE TAX INSTITUTE – 2020 Queensland Tax Forum
Sian Sinclair, CTA is a Tax Partner and Linda Tapiolas, CTA is a Partner in the Coles Limited, Macquarie Group consortia the Middle East to reduce the marginal cost National Industry Leader for Real Estate Cooper Grace Ward Lawyers Commercial acquisitions of Boart Longyear Limited and and streamline the management of indirect & Construction, Grant Thornton Australia. team. She provides a range of support Dyno Nobel Limited and their subsequent taxes affecting their business or transaction. Sian’s real estate and construction expertise services to accountants, financial planners listing on the Australian Securities Exchange. He works across many industries in draws on twenty five years of experience in and other professional advisers. This Grant now leads the thought leadership Australia with a focus on managing ATO taxation, accounting and general business includes technical advice on complex tax, on tax policy and consultation on new law, regulatory review, and also leads project consulting. Advising clients from the start-up CGT and Div 7A issues, as well as acting on including KPMG’s response to base erosion implementation teams for tax technology and growth phases of business through business sales and acquisitions to ensure and profit shifting (BEPS) and the OECD and system upgrades on a national and to those looking to realise their wealth via clients achieve commercial and tax-effective Action Plan. He is Co-Chair of the National global basis. exit strategies, her input is focused and outcomes. Prior to joining Cooper Grace Tax Liaison Group, an Adviser to the Board Ward, Linda worked as an accountant for of Taxation, a member of the KPMG Global Karen Young is the Global Tax Director practical with real insight into the issues at Flight Centre Travel Group Limited with impacting businesses in the industry. With 18 years advising clients on capital gains, BEPS Steering Group and the KPMG business acquisitions and restructuring. Responsible Tax Group. responsibility for all taxation matters across experience managing tax risk for large Flight Centre’s 30+ countries. Karen has She also conducted seminars and training groups, including advising on significant Scott Wedgwood is a principal in been a tax practitioner for over 17 years sessions on various topics including CGT transactions and group consolidations, the Barry Nilsson Lawyers family law and was previously a Senior Manager within small business concessions. Sian oversees the compliance and planning team. He is an Accredited Family Law EYs corporate tax division including 2 years needs of Australian and international Adele Townsend, CTA is a Tax Partner Specialist and has practiced exclusively in EYs international tax practice in New business groups. Having worked with at BDO. She is an experienced domestic in this jurisdiction for more than 25 York. Karen has extensive experience in Grant Thornton in Brisbane, Melbourne and international taxation adviser with both years. Scott advises on all family law international and transaction tax, including and the USA, she spent 4 years as the listed and private clients in a wide range issues, but he has particular expertise in M&A, financing, structuring, due diligence Global Head of Real Estate & Construction of industries, including mining services, high-end, complex property settlements, and transfer pricing. During her time with and remains the chair of Grant Thornton’s transport, manufacturing, biotechnology and especially those involving difficult taxation Flight Centre Karen has also focused heavily Global Industry Committee. Sian has been property. She also has significant experience issues. Respected for his extensive on tax policy & strategy, board reporting and the National Industry Leader for Real Estate advising individuals on a range of complex knowledge, technical skills and practical tax risk management for the global group. and Construction for Grant Thornton since taxation matters such as divorce, death and experience, Scott was named Lawyer 2011 and has extensive experience with international residency. of the Year for Family Law Mediation businesses in the property development in Brisbane in the 2020 edition of Best Grant Wardell-Johnson, CTA is the Lead Lawyers. Scott is a strong negotiator and and construction industries and advises Tax Partner of the Economics and Tax a number of key industry participants on enjoys collaborating with other skilled Centre at KPMG. Grant has a background in professionals to reach the best possible tax matters. As a current member of the providing tax advice relating to international outcome for his clients. Property Council of Australia’s Queensland and domestic tax structuring, international Divisional Council and the Australian Tax cross-border acquisitions and initial public Tony Windle, ATI is a Partner in Indirect Tax Office’s Property & Construction Forum, Sian offerings. Grant has been the lead Tax at Grant Thornton and is the Global Head of regularly contributes to thought leadership Partner on many high-profile projects in Indirect Tax for Grant Thornton International. and advocacy on tax matters impacting the the Australian and international markets, Tony advises clients throughout Australia industry. including the Wesfarmers acquisition of and across Asia-Pacific and Europe and 2020 Queensland Tax Forum taxinstitute.com.au 13
Venue Event information Registration options and inclusions Thursday Online access to Lunch and networking drinks presentations and morning/ How to register and Friday forum technical papers afternoon tea close drinks A Full registration Register online or This registration option entitles one ✔ ✔ ✔ complete the form delegate to attend the entire event. included in this brochure. B Day registration ✔ ✔ Register online or This registration option entitles ✔ for your for your complete the form one delegate to attend a full day selected day selected day included in this brochure. of technical sessions C Young Tax Professionals (YTP) ✔ ✔ stream ticket ✔ Register by completing This registration option entitles one for the YTP Lunch and the form included in this Thursday delegate to attend the YTP stream, sessions and Thursday brochure. networking drinks plus Session 6. Session 6 only afternoon tea D Employer ticket Please contact the This registration option allows one Queensland Team on ✔ ✔ registration to be shared between 07 3225 5200 or at Stamford Plaza Brisbane multiple attendees from the same firm qld@taxinstitute.com.au Edward Street & Margaret Street, Brisbane City Getting there Register online at taxinstitute.com.au/qtf Stamford Plaza is conveniently located in Brisbane’s CBD, near the Botanic Gardens and Brisbane River. Discounts Confirmation of registration If you are travelling from interstate, Stamford Plaza is a Early bird registration A confirmation will be sent via email. Please note you will 25-minute drive from the Brisbane Domestic Terminal. receive two separate emails in the form of a confirmation All full conference registrations received and paid for on or before Friday 17 April 2020 will be entitled to an early bird email and tax invoice. Parking discount. Parking is available at the Stamford Plaza. Self-parking CPD accreditation will incur a rate of $45 per car, per day, and valet Group discounts Full forum attendance counts for 13 hours of Structured parking will incur a rate of $57 per car, per day. Continuing Professional Development (CPD) accreditation If you are registering four or more people from the same firm, please contact the Queensland Team on 07 3225 5200 or at with The Tax Institute. Attendance at Day 1 of the forum qld@taxinstitute.com.au. counts for 6.5 hours of Structured CPD and Day 2 counts for 6.5 hours CPD. Employer ticket attendance will be allocated accordingly to each attendee. Please see page 19 for further Event information. 14 THE TAX INSTITUTE – 2020 Queensland Tax Forum
2020 Queensland Tax Forum 40844 | WD Event A tax invoice and confirmation letter will be sent on receipt of your registration. Please photocopy for Registration form additional delegates and retain original copy for your records. All prices quoted are in Australian dollars and include GST where applicable. ABN 45 008 392 372. 1 Registration 2 Delegate contact details A Full conference registration (13 CPD hours) Member no.: Member New member* Non-member If your member details are up-to-date, you can skip this section. Early bird registration Received on or before 17 April 2020 $1,890 $2,230 $2,300 Standard registration Received after 17 April 2020 Title: Mr Mrs Miss Ms Date of birth: DD/MM/Y Y Y Y $2,090 $2,430 $2,500 I acknowledge that I will receive electronic access to the available papers and presentations First name: through The Tax Institute CPD app. Last name: B Single day registration (6.5 CPD hours) Position: Member Non-member Company: Registration $1,100 $1,350 Address: I acknowledge that I will receive electronic access to the available papers and presentations through The Tax Institute CPD app. Suburb: State: Postcode: Telephone: Mobile: *EVENT AND MEMBERSHIP OFFER Signature: Email: If you are not a member, bundle your membership with your registration. You will receive the member rate for registration and Dietary requirements: pay only $340 for membership through to June the following year. I hereby apply for membership of The Tax Institute and declare Date of signature: Please tick this box if you do not wish your name to be included on the delegate list provided to all attendees for networking purposes. that I am a person of good fame, integrity and character and agree to be bound by the Constitution of The Tax Institute. DD/MM/Y Y Y Y Further information available at taxinstitute.com.au Promotional code: C Young Tax Professionals stream Young Tax Professionals stream ticket $195 Attendees will gain a greater understanding of, and ability to recognise, key issues in relation to the following topics: Optimising Outcomes by Effective Negotiation Managing Clients as the Trusted Advisor Objections and Audit Paper Responses – Drafting to Win!
3 Technical sessions options 4 Payment method Please note: all registration payments must be made prior to the event, unless other arrangements have been made with The Tax Institute. Thursday 21 May 2020 9.00–10.00am Session 1 Cheque payable to The Tax Institute (in Australian dollars) 10.20–11.20am Session 2A Session 2B Credit card Card type: AMEX Visa MasterCard Diners 11.20am–12.20pm Session 3A Session 3B Session 3C 1.20–2.20pm Session 4A Session 4B Session 4C 2.20–3.20pm Name on card: Session 5A Session 5B Session 5C 3.40–5.10pm Session 6 Card no.: Expiry date: MM/ Y Y Friday 22 May 2020 8.30–10.00am Session 7 Cardholder’s signature: 10.00–11.00am Session 8A Session 8B For our refund, cancellation and replacement policy visit taxinstitute.com.au/professional-development/event-policy. 11.20am–12.20pm Session 9A Session 9B 1.20–2.20pm Session 10A Session 10B For event enquiries, please contact the Queensland Team on 07 3225 5200 or 2.40–3.40pm Session 11A Session 11B qld@taxinstitute.com.au. 3.40–4.40pm Session 12A Session 12B For registration enquiries, please contact customeradmin@taxinstitute.com.au Collection notice The Tax Institute (TTI) complies with its obligations under the Privacy Act 1988 (Cth) with respect to how it handles personal information. For information on how TTI collects, uses, holds and discloses personal information, please see its privacy policy at www.taxinstitute.com.au. [You can also request TTI’s consultants to provide you with a copy of TTI Privacy Policy.] By submitting your application to TTI, you confirm that you have read TTIs Privacy Policy and you consent to your personal information being collected, used and held by TTI and disclosed to third parties in accordance with TTI’s Privacy Policy. TO REGISTER 0283QLD_02/20_v6 Online Mail Email Fax taxinstitute.com.au/qtf L37, 100 Miller Street, North Sydney NSW 2060 customeradmin@taxinstitute.com.au 02 8223 0077
2020 Queensland Tax Forum 40844 | WD Employer ticket A tax invoice and confirmation letter will be sent on receipt of your registration. Please retain original copy Registration form for your records. All prices quoted are in Australian dollars and include GST where applicable. ABN 45 008 392 372. Registration information 2 Employer ticket co-ordinator details Employer registration If your member details are up-to-date, you can skip this section. § Multi-user registration (register up to 12 delegates from the same organisation) Member no.: § Attendance at any session of your choice (total 12 technical sessions) Mr Title: Mrs Miss Ms Other (please specify) § Electronic access to download available technical papers and presentations § Morning and afternoon refreshments Date of birth: DD/MM/Y Y Y Y § 13 CPD hours First name: Session selection Please complete the form overleaf indicating the sessions that each person is attending. Please note that Last name: sessions will be allocated on a first-come, first-served basis, so please make your selections as soon as possible to avoid disappointment. Please ensure the form is correct as CPD hours will be allocated accordingly. Position: Note: Employer tickets do not include attendance at the networking lunches. Company: Once you have registered You will receive a tax invoice and confirmation letter including details of your session selections. Address: Please check your session details and contact The Tax Institute on 02 8223 0040 if any details are incorrect. Suburb: Early bird offer Register on or before 17 April 2020 to save. State: Postcode: Telephone: Fax: Mobile: Email: Please tick this box if you do not wish your name to be included on the delegate list provided to all attendees for networking purposes. 3 Payment method Cheque payable to The Tax Institute (in Australian dollars) Credit card $ Card type: AMEX Visa MasterCard Diners 1 Registration options Name on card: Early bird registration Received on or before 17 April 2020 $2,390 Card no.: Expiry date: M M/ Y Y Standard registration Received after 17 April 2020 $2,590 Cardholder’s I acknowledge that I will receive electronic access to the available papers and presentations through signature: The Tax Institute CPD app. For our refund, cancellation and replacement policy visit taxinstitute.com.au/professional-development/event-policy.
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