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It has been business as usual for Ernst & Young, maintaining its strength in the market. Craig Robson took the helm of the tax practice in July 2010. He has expanded the team, hiring partners nationwide. Reid Zuplo joined the firm in Brisbane, and is ... [more]

It has been business as usual for Ernst & Young, maintaining its strength in the market. Craig Robson took the helm of the tax practice in July 2010. He has expanded the team, hiring partners nationwide. Reid Zuplo joined the firm in Brisbane, and is focusing on the tax transactions market. In Perth, Vaughan Lindfield is concentrating on the mining sector.

Paul Balkus heads the transfer pricing department, a key growth area in Ernst & Young's tax practice. The team has been involved in several matters and has been negotiating advance pricing arrangements with the ATO.

Balkus, along with Martin Caplice and David Tracey, worked with a client in the FMCG (fast-moving consumer goods) industry on a complex transfer pricing audit. The deal resulted in an agreement between the ATO and the client for the years under audit. The team was also involved in negotiating an APA on behalf of the client, which will help provide certainty on future transfer pricing positions.

Ernst & Young's practice is sub-divided into China North, Central and South, each managed by a tax market segment leader. Joseph Lee heads the tax department in Greater China and has looked to expand the tax team, adding two partners and five executive ... [more]

Ernst & Young's practice is sub-divided into China North, Central and South, each managed by a tax market segment leader. Joseph Lee heads the tax department in Greater China and has looked to expand the tax team, adding two partners and five executive directors.

The tax team advised a large multinational on the issue of beneficial ownership to pursue the reduced withholding tax rate on dividends under the double tax arrangement between Hong Kong and China. During the process, the team introduced several international tax concepts to the SAT.

The result of this process could have a significant impact on how the beneficial ownership issue will be practically interpreted and handled in the future.

Ernst & Young has brought in a specialised team from Europe to help strengthen its presence in financial services.The firm launched its Asia Pacific Tax Centre in late 2010 to provide advisory services to clients that have a focus on Asia Pacific. A ... [more]

Ernst & Young has brought in a specialised team from Europe to help strengthen its presence in financial services.

The firm launched its Asia Pacific Tax Centre in late 2010 to provide advisory services to clients that have a focus on Asia Pacific. A recent addition to the Hong Kong office, Christian Pellone, leads the group.

International tax partners Christopher Finnerty and Alice Chan-Loeb joined the Hong Kong office in August 2010 from the Ernst & Young offices in Shanghai and Taiwan, respectively.

Tracy Ho oversees the tax practices in Hong Kong and Macau. While advising a client on tax restructuring, she discovered an error made by the client's former tax representatives in relation to the tax treatment of R&D, where a deduction of almost $125 million in expenses resulted.

Agnes Chan and her corporate tax team successfully assisted a global apparel company in claiming a tax refund of more than $13 million from the Inland Revenue Department (IRD) by lodging an offshore non-taxable claim on the commission income earned over the past six years.

The tax policy and controversy team under Joe Chan successfully helped a Hong Kong client resolve a permanent establishment dispute with a tax authority in Europe, generating a tax saving of around $5 million. The team has also assisted a client with the settlement of a tax audit case with the IRD, escaping with a minimal amount of tax and penalties. The dispute was mainly related to transfer pricing adjustments of around $13 million.

Sudhir Kapadia has taken over from the experienced Srinivasa Rao as Ernst & Young's national tax leader. Rao has moved on to a firm-wide role as head of the firm's technology, communications and entertainment business unit. The firm has overseen three ... [more]

Sudhir Kapadia has taken over from the experienced Srinivasa Rao as Ernst & Young's national tax leader. Rao has moved on to a firm-wide role as head of the firm's technology, communications and entertainment business unit. The firm has overseen three lateral partner hires from PwC and one from BMR Advisors in the last 12 months.

The team provided tax advice to IT firm iGate in January 2011 on its $1.2 billion acquisition of a majority stake in Patni Computer Systems. Advice was also provided to Apax Partners, a private equity and venture capital firm, for their partial funding of the acquisition. Key issues included multi-jurisdictional cross-border transactions, project management and coordination, understanding the Indian regulatory landscape, and balancing commercial, tax and regulatory requirements.

Ernst & Young has been involved in several controversy matters. Rajan Vora, K T Chandy and Chavali Narayan advised a client seeking an advance ruling about whether a foreign company lacking a business presence in India is subject to minimum alternate tax (MAT) on long-term capital gains on sales of shares. The Authority for Advance Rulings (AAR) used previous rulings to decide that the provisions of a MAT were applicable to foreign companies. Ernst & Young argued that the foreign companies in the previous rulings had a presence in India, while the client in this case has no physical presence in India. The authorities ruled in favour of the client and stated that the provisions of the MAT were not applicable.

After this ruling, the firm's litigation team obtained a similar ruling in another case. In this instance, the authorities also held that there is no capital gains tax in India on the transfer of shares in the Indian company, since the client is a tax resident of Mauritius.

Ben Koesmoeljana has taken over from the retired Robert Darmadi as head of tax at Ernst & Young.The tax team won several cases in the tax court concerning issues such as VAT on exports of services, VAT on the sale of foreclosed assets by banks, and reinstatements ... [more]

Ben Koesmoeljana has taken over from the retired Robert Darmadi as head of tax at Ernst & Young.

The tax team won several cases in the tax court concerning issues such as VAT on exports of services, VAT on the sale of foreclosed assets by banks, and reinstatements of provisions for banks.

The firm is in regular contact with the tax authorities on issues including transfer pricing, APAs and mutual agreement procedures.

Partner Carlo Navarro joined from the Vietnam office in July 2010 to head the transfer pricing team in Indonesia. Since his arrival, he has conducted documentation work for clients, worked to increase the royalty rate for trademark rights, and helped a multinational in the gold mining industry apply for the first ever APA in Indonesia.

Ernst & Young Shinnihon Tax's tax practice is led by Kai Hielscher, who joined in August 2010 from Germany where he was the international and transaction tax services markets leader.Jose Huerta was appointed executive director in September 2010 for the ... [more]

Ernst & Young Shinnihon Tax's tax practice is led by Kai Hielscher, who joined in August 2010 from Germany where he was the international and transaction tax services markets leader.

Jose Huerta was appointed executive director in September 2010 for the firm's international and transaction tax services practice consisting of more than 155 professionals. He focuses on American multinational clients while partner Hans-Peter Musahl focuses on clients from the EU. Christopher Newman was promoted to executive director of the firm's transfer pricing team, which is made up of more than 85 professionals.

The team is providing transfer pricing services to a large pharmaceutical company that the firm has maintained a strong relationship with for more than 12 years. The tax and advisory teams assisted the client with its recent worldwide expansion into 12 countries including South Korea, Mexico, Turkey and Sweden.

Under the leadership of Eng Ping Yeo, the tax team at Ernst & Young maintains a positive relationship with the Malaysian tax authorities.Sockalingam Murugesan and Gary Ling's negotiation skills were put to the test while managing the investigation of ... [more]

Under the leadership of Eng Ping Yeo, the tax team at Ernst & Young maintains a positive relationship with the Malaysian tax authorities.

Sockalingam Murugesan and Gary Ling's negotiation skills were put to the test while managing the investigation of a client by the tax authorities. Issues included transfer pricing and corporate tax. The authorities assessed the company for about $6.3 million for the fiscal years 2001 to 2004, which was made up of transfer pricing adjustments, and about $1 million of withholding taxes including penalties. The team managed to eliminate the transfer pricing figure and the penalties. The case is still pending, with the outcome expected to be in favour of the client.

The firm has a large transfer pricing team, which advises many large domestic and multinational corporations. All aspects of transfer pricing are covered, including planning, documentation, risk review, business restructuring and controversy management.

Janice Wong and Shir Wei Foo teamed up to review and provide technical responses to queries raised by the authorities about intangible transactions. The pair successfully helped their client defend the arm's length nature of intangible transactions that involved payments for brand names and technical expertise.

David Haywood oversees the tax practice at Ernst & Young. Andy Archer leads the corporate tax team and Iain Blakeley is head of indirect tax.The firm strengthened in tax controversy with the addition of Richard Williams and Kirsty Keating, a lawyer with ... [more]

David Haywood oversees the tax practice at Ernst & Young. Andy Archer leads the corporate tax team and Iain Blakeley is head of indirect tax.

The firm strengthened in tax controversy with the addition of Richard Williams and Kirsty Keating, a lawyer with experience in IRD litigation.

Mark Loveday leads the 12-strong transfer pricing department, providing services to clients including six car companies in New Zealand comprising more than 50% of sales in the industry.

Loveday has concluded numerous APAs with the IRD in the last 12 months. In May 2011, he helped negotiate a unilateral agreement and binding ruling for a large global shipping company. The APA and ruling were sought on the back of a lengthy dispute over the taxation and quantification of the taxable profits in New Zealand. The APA and ruling covered areas the authorities had not focused on before. Issues included source of income, pricing and the application of a double tax agreement for international shipping.

Ernst & Young has an established presence in Singapore, with experienced professionals in all areas of tax. Like some of its competitors, the firm set up a business incentives advisory group to advise clients on the tax incentives and schemes that have ... [more]

Ernst & Young has an established presence in Singapore, with experienced professionals in all areas of tax. Like some of its competitors, the firm set up a business incentives advisory group to advise clients on the tax incentives and schemes that have been made available through the 2010 and 2011 annual budgets.

Previously in the China office, Luis Coronado took over as head of the Singapore transfer pricing practice in July 2011. His predecessor, Jesper Solgaard, has moved to the Australian office to be co-leader of the Oceania transfer pricing practice.

New addition Jow Lee Ying joined the firm from the Inland Revenue Authority of Singapore (IRAS) to assist clients with controversy issues including defending tax audits and seeking advance rulings and advance pricing agreements. Aside from her technically sound advice on transfer pricing, Jow has knowledge of the processes from the perspective of the tax authorities.

The transfer pricing practice is handling one of the first bilateral APAs between Singapore and Canada, and is also involved in substantial APAs with Australia, Japan, and Thailand.

Ernst & Young's tax team, led by Dong-Chul Kim, is leading several refund projects for domestic clients, helping them lower their effective tax rates. The team was heavily involved in identifying and analysing potential tax issues arising from the adoption ... [more]

Ernst & Young's tax team, led by Dong-Chul Kim, is leading several refund projects for domestic clients, helping them lower their effective tax rates. The team was heavily involved in identifying and analysing potential tax issues arising from the adoption of new financial reporting standards – the K-IFRS – in 2011.

Partner Danielle Suh joined from Kim & Chang in December 2010, while Yong Pyo Kong joined in January 2011 from the tax authorities.

Rap Choi's transfer pricing division has had a busy year. The team is involved in the first-ever synthetic bilateral APA between Korea and Taiwan. Since the two countries do not share a double tax treaty, unilateral APAs are in principle the only way to obtain APAs for cross-border intercompany transactions. The transfer pricing professionals are designing a synthetic bilateral APA structure to enhance the ability of taxpayers in the two countries to obtain further certainty about their transfer pricing issues.

After spending 14 years in the Shanghai office, the experienced Bill Seto returned to Ernst & Young Taiwan in July 2010 to head the tax department.George Chou oversees the transfer pricing department. He has expanded the practice aggressively, hiring ... [more]

After spending 14 years in the Shanghai office, the experienced Bill Seto returned to Ernst & Young Taiwan in July 2010 to head the tax department.

George Chou oversees the transfer pricing department. He has expanded the practice aggressively, hiring about 30 new professionals to bolster his team.

Sophie Chou and Ada Lin won a tax court case in June 2011 on the issue of goodwill amortisation, which the tax authorities had initially disallowed amortisation in all situations. Chou and Lin explained the nature of goodwill from transactional perspectives and successfully argued that the tax authorities should bear the burden of proof if they claim the value of goodwill is overstated. This case will affect future cases involving the amortisation of goodwill resulting from M&A transactions.

Despite the loss of head of tax Nam Nguyen, Ernst & Young is maintaining a stable presence in the market. Christopher Butler has taken over the firm's tax practice comprising 100 professionals.The transfer pricing division is providing advisory services ... [more]

Despite the loss of head of tax Nam Nguyen, Ernst & Young is maintaining a stable presence in the market. Christopher Butler has taken over the firm's tax practice comprising 100 professionals.

The transfer pricing division is providing advisory services and documentation support to several clients. Nitin Jain and Huong Vu teamed up in January 2011 to advise a client on a transfer pricing risk assessment. In addition to reviewing the arm's-length nature of and the supporting documentation for the client's related-party transactions, the pair validated a signed provision similar to an APA. The issue becomes complicated as there are no APA provisions in Vietnam's existing transfer pricing regulations.

Butler and Jain performed tax planning services for a client to provide a technically appropriate and commercially realistic transaction model, as well as associated transfer pricing policies, for the project.