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Module VI Outline : 企业联盟模式

 

As the global economy recovers, mergers and acquisitions (M&As) are expected to gain momentum. Various factors lead to M&As and in ensuring a successful exercise, consideration must be given to several aspects including the relevant tax implications and planning opportunities. A host of tax issues would arise from M&As and these must be considered from the outset. Steps must be taken to mitigate the tax exposures with an ultimate view to achieving overall tax efficiency for a group of companies. Apart from domestic M&As, we have witnessed various Malaysian companies venturing overseas. In so doing, various foreign tax and regulatory aspects must be given due consideration. Amongst others are corporation taxes, withholding taxes, capital gains (exit strategy), availability of tax treaties, transfer pricing rules, exchange control, foreign equity participation, licensing etc. A proper entry and exit planning are crucial to ensure a successful M&As. By participating in this workshop, participants will be able to understand better the tax issues and planning opportunities in connection with M&As.

 

Objectives
1.      1. Understanding the various phases of tax transaction lifecycle and the their significance
2.      2. Understanding the objective of a tax due diligence review and learning how to priorities
3.      3. Appreciating the tax implications of M&A
4.      4. Mastering the steps in achieving a tax-aligned M&A

 

Course Outline
1.      1. Tax Transaction Life Cycle
2.      2. Tax Due Diligence Review
3.      3. Tax-efficient Considerations For M&As
a)      Deal structure
b)      Income tax
c)      Real property gains tax
d)     Stamp duty
e)      Indirect tax
f)       Regulatory
4.      4. Specific Issues For International M&As
a)      Deal structure
b)      Holding structure
c)      Funding structure/hybrid instruments
d)     Debt-push down etc
e)      Thin capitalization
f)       Treaty planning
g)      Transfer pricing
h)      Exit strategies etc
5.      5. Other Planning Opportunities
a)      Early stages planning
b)      Post-deal tax structuring/restructuring
c)      Review of business models/Tax-aligned supply chain

 

 

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