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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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