2016 NATIONAL RESOURCES TAX CONFERENCE · Jaime Hayes, EY Len Hertzman, CTA, Australian Taxation...

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taxinstitute.com.au 2016 NATIONAL RESOURCES TAX CONFERENCE 26–28 October 2016 Crown Perth, Western Australia

Transcript of 2016 NATIONAL RESOURCES TAX CONFERENCE · Jaime Hayes, EY Len Hertzman, CTA, Australian Taxation...

Page 1: 2016 NATIONAL RESOURCES TAX CONFERENCE · Jaime Hayes, EY Len Hertzman, CTA, Australian Taxation Office Peter Hyman, ATI, INPEX ... Goodman Fielder Wattie, where Justice Hill observed

taxinstitute.com.au

2016 NATIONAL RESOURCES TAX

CONFERENCE

26–28 October 2016Crown Perth, Western Australia

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WELCOME2016 National Resources Tax Conference

No doubt the National Resources Tax Conference comes at a challenging time for the energy and resources sector.

Challenging from both a commercial and tax perspective.

Politicians and tax administrators around the globe are grappling with the difficult job of balancing public perceptions and demands for tougher action on corporates with the need to maintain stability and confidence in the tax system and thereby encourage compliance. Reflecting this mood, we have speakers from the Australian Taxation Office speaking on anti-avoidance, valuation and transfer pricing – areas where this tension is paramount.

There is also a strong focus in the program on the difficult technical tax issues facing the sector. These sessions will be delivered by outstanding speakers who are recognised experts in the relevant topics, including:

� Jonathon Woodger, Deputy Chief Tax Counsel, ATO

� Ann-Maree Wolff, CTA, The Board of Taxation

� Ken Spence, CTA (Life), Greenwoods & Herbert Smith Freehills

� Simon Steward QC, FTI, Victorian Bar

� Larry Magid, CTA, Allens.

I am confident the program will deliver on The Tax Institute’s reputation for providing relevant material at a level of detail necessary for those operating in the sector. As always, there will also be ample opportunity for networking with colleagues.

I congratulate the committee on delivering an exceptional program and look forward to seeing you at the conference.

Nick Heggart, CTA Chair, Conference Organising Committee

Thank you

The Tax Institute gratefully acknowledges the generous assistance of members of the National Resources Tax Conference Organising Committee:

Nick Heggart, CTA, Greenwoods & Herbert Smith Freehills (Chair, Conference Organising Committee)Phil Bisset, CTA, Clayton UtzKurt Burrows, KPMGGrant Cathro, CTA, AllensJaime Hayes, EYLen Hertzman, CTA, Australian Taxation OfficePeter Hyman, ATI, INPEXJasmine Leonard, ATI, Rio Tinto Gregory Leyden, CTA, Esso AustraliaSara Mattsson, South32Richard McBride, CTA, Alcoa of Australia LtdJohn Middleton, CTA, Clayton UtzHayden Scott, FTI, PwCJerome Tse, CTA, King & Wood MallesonsVladimir Younger, CTA, Oil Search

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TECHNICAL PROGRAM

Day one – Wednesday 26 October 2016

Time Session

12.45pmWelcome and Opening Address Speaker: Nick Heggart, CTA, Greenwoods & Herbert Smith Freehills

1.00pm–1.45pm Session 1: Economic Update – Where Will the Resources Rollercoaster Go in 2017?Speaker: John Nicolaou, ACIL Allen Consulting

The resources boom of 2004 to 2012 was a once-in-a-century event that generated unprecedented wealth and opportunity for Australia, and an economic legacy that will continue for decades to come. Western Australia has risen to international prominence as a major destination for investment and people, with more than 400,000 jobs created during this time, and a population that has grown by more than 500,000 as people migrated from interstate and overseas to enjoy the boom-time conditions created by the growth in the resources sector.

Since 2012, the combination of sharp falls in commodity prices and the completion of a number of major resources projects has dramatically changed the economic landscape and the economics of the resources industry, which is now focused on driving efficiencies and lowering costs of production to maintain global competitiveness.

So what’s next for the resources industry?

John Nicolaou will explore the future outlook for the resources industry, and what it means for Australia’s economy looking ahead. This will include a discussion on issues such as:

� Current economic conditions in Australia � The economic outlook for Australia � The importance of the resources sector to future prosperity � Opportunities and challenges facing the resources sector � Economic reform agenda required.

1.45pm–2.30pm Session 2: Managing Part IVASpeaker: Jonathan Woodger, Australian Taxation Office

The general anti-avoidance rule (GAAR) in Part IVA of the Income Tax Assessment Act 1936 continues to be a notable feature of the Australian tax landscape.

In this session, Jonathan will provide an ATO perspective on the GAAR, and will cover topics that include:

� The advantages and limitations of a general anti-avoidance rule, and the nature of the task confronting the tax official in administering it � The Courts’ approach to valuation issues � Issues that still need to be resolved � The administration of the “Multinational Anti-Avoidance Law” in the new s177DA of the 1936 Act � Any recent developments that are of particular relevance to the energy and resources sector � The operation of the ATO’s GAAR Panel.

2.30pm–3.00pm Afternoon tea

3.00pm–4.00pm Session 3: The Legal Meaning of “Market Value”Speaker: Tim Kyle, CTA, Greenwoods & Herbert Smith Freehills

Determining market value is an increasingly significant issue in tax matters and a growing source of dispute with the ATO and other revenue authorities.

There are a number of critical building blocks in producing a robust market valuation for tax purposes, including:

� A proper understanding of the statutory context of the relevant provision � An awareness of the various statutory provisions and regulations that may impact the proper approach � Understanding the growing case law on market value in a tax context � An appreciation of the numerous instances where the legal meaning of market value departs from international valuation guidelines.

This session explores those building blocks.

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TECHNICAL PROGRAM

Day one – Wednesday 26 October 2016

Time Session

4.00pm–4.45pm Session 4: Market Value Panel DiscussionChair: Hugh Paynter, CTA, Herbert Smith Freehills Panel: Louise Clarke, Australian Taxation Office, Nicki Ivory, Deloitte, Tim Kyle, CTA, Greenwoods & Herbert Smith Freehills, Simon Steward QC, FTI, Victorian Bar

This session draws together leading experts to discuss a number of different perspectives to consider topical market value issues such as:

� The ATO’s approach to valuation issues � The Courts’ approach to valuation issues � Issues that still need to be resolved � How resolution of valuation matters can be improved.

5.00pm–7.00pm Sundowner welcome reception

Day two – Thursday 27 October 2016

Time Session

9.00am–10.00am Session 5: BEPS and International Tax – The New RealitySpeaker: Peter Collins, FTI, PwC & Stuart Landsberg, FTI, PwC

The OECD’s BEPS project and the related focus on multinational corporations’ tax practices have reached the highest level of government and stakeholder attention. The energy and resources sector has been particularly impacted. This session will provide an overview on the key BEPS and international tax changes relevant to the industry, including:

� Financing, including hybrid mismatch measures and Action 4 (thin capitalisation) initiatives � Practical impacts of the changes to PE definitions and profit attribution � Australia’s unilateral BEPS responses, including the Diverted Profits Tax and the Multinational Anti-Avoidance Law � Part IVA implications of restructuring in response to proposed law changes � Other topical international tax considerations.

10.00am–11.00am Session 6: Can Salary Paid To An Employee Ever Be On Capital Account?Speaker: Simon Steward QC, FTI, Victorian Bar

The deductibility of salary paid to employees working on capital projects is a perennial issue for the energy and resources sector. The issue has remained unresolved since Goodman Fielder Wattie, where Justice Hill observed that there had previously been no case which had addressed the problem, and that it raised a question of fact and degree. This session will address this difficult issue head on by:

� Considering relevant authorities � Considering different circumstances – e.g. employees working part-time or full-time � Providing Simon’s views on when such expenditure is or is not on capital account.

11.00am–11.30am Morning tea

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TECHNICAL PROGRAM

Day two – Thursday 27 October 2016 (cont)

Time Session A Session B

11.30am–12.30pm Session 7A: What’s New For Tax LossesSpeaker: Martin Fry, FTI, Allens

Plummeting commodity prices and cost blow-outs on projects mean that some Australian energy and resources companies have entered a new phase of loss accumulation in recent years. Martin will examine the issues facing these companies in carrying forward and recouping these losses with particular focus on the following:

� The new continuity of ownership test (COT) rules for companies that have issued different classes of shares, which apply from 1 July 2002

� Recently enacted tracing concessions for satisfying the COT test � Recent and proposed amendments to the same business test � The treatment of unrealised losses and when they can be made unavailable to taxpayers.

Session 7B: Transfer PricingSpeaker: Fiona Craig, ATI, Deloitte & Louise Clarke, Australian Taxation Office

The role of transfer pricing in the mining and energy sector has never been more topical. This session will be split into parts with a primary focus on the role of hubs in the current transfer pricing debate – be it marketing, procurement, technology, R&D or outsourcing in general. For this part of the session, Fiona will present on how hubs have evolved into one of the most significant transfer pricing issues confronting the mining and energy sector with commentary from Louise on how the ATO views certain hub arrangements.

In the second part of the session, Louise will summarise the arguments made for and against in the Full Federal Court appeal of the Chevron transfer pricing decision.

12.30pm–1.30pm Lunch

1.30pm–2.15pm Sessions 8A: Accounting Concepts Invading TaxSpeaker: Michelle Mori, EY

The interplay between tax and accounting continues to grow, be it accounting concepts used in tax legislation, accounting treatments not relevant to tax, or tax accounting which brings together tax positions adopted and their reporting outcomes. This session will look at current issues facing tax professionals in this area, including:

� Focus on tax accounting balances by various stakeholders � Concept of effective tax rate and the crossover into tax, tax transparency and the impact on accounting and other disclosures

� Tax impact of recent and proposed changes in accounting standards � Need for tax advisers to understand accounting treatments to ensure the appropriate tax outcomes

� Impact of tax law changes on financial statements.

Session 8B: Rehabilitation ObligationsSpeaker: Katrina Parkyn, ATI, King & Wood Mallesons

Rehabilitation obligations are a significant aspect of a resource project. Planning for rehabilitation expenditure is an important part of a project’s development and can be incurred throughout a project’s life.

This session will provide a practical overview of the tax issues associated with rehabilitation obligations, including:

� Deductibility of rehabilitation expenditure, including the scope for a general deduction under s 8-1 versus a specific deduction under Div 40

� Meaning of “mining site rehabilitation” under s40-735 � Off-site rehabilitation expenditure – special issues � Treatment of rehabilitation obligations when buying or selling a mine � State tax considerations � Petroleum Resource Rent Tax issues.

2.15pm–3.00pm Sessions 9A: State TaxesSpeaker: David W Marks QC, CTA, Queensland Bar

This session will explore a number of highly topical state taxation issues impacting the energy and resources sector, including:

� Royalties – the states took about $10 billion in mining royalties in 2013–2014, according to work commissioned by the Minerals Council of Australia. It is therefore not surprising that some recent disputes have arisen. An analysis of some of these disputes will show how they differ from other tax disputes and how they can be managed

� Landholder duty – what’s in and out? What it’s worth? There will be reference to some interesting recent cases

� Payroll tax – contractors as employment agents. Indirect impacts of recent FBT and GST cases about transport and housing will be discussed.

Session 9B: CGT and Non-residents – Topical IssuesSpeaker: Philip Bisset, CTA, Clayton Utz

With recent developments, it is an opportunity to reflect on the CGT treatment of non-residents investing in Australian energy and resources projects, including:

� The role of Div 855 � How it works � Differences to landholder duty � The extended concept of land in Div 855 � Treaty issues that arise � New non-resident CGT withholding rules – the impact on transactions � Interaction with the new FIRB tax conditions.

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TECHNICAL PROGRAM

Time Session

3.00pm–3.30pm Afternoon tea

3.30pm–4.30pm Session 10: Tax Transparency – The Information Is Flowing So What Have We Learned?Speaker: Jonathan Rintoul, CTA, EY & Ann-Maree Wolff, CTA, The Board of Taxation

This session will take stock of the various voluntary and mandatory tax transparency initiatives currently impacting energy and resources companies in Australia. A panel of stakeholders will share their perspectives on what we have learned from these initiatives so far. They will also consider whether these initiatives are delivering the outcomes expected of them, and discuss the challenges and benefits of ongoing and increasing tax transparency.

6.00pm–9.00pm Conference networking dinner

Day three – Friday 28 October 2016

Time Session

9.00am–10.00am Session 11: Capital ManagementSpeaker: Larry Magid, CTA, Allens

The efficient management of debt and equity capital is a key concern of all energy and resources companies, and one which raises particular issues for listed companies and their shareholders, including tax issues. This session will identify and analyse the tax issues arising out of a range of capital management techniques in recent use. The topics covered will include:

� The permissible sources of and funding for franked dividend distributions � The treatment of rights issues and the circumstances in which the payment of a retail premium in respect of unexercised rights may be taxable as a dividend, other ordinary income or as a capital gain

� The treatment of hybrid capital raisings and the effect of present and proposed tax reforms on the use of capital management tools.

10.00am–10.30am Morning tea

10.30am–11.30am Session 12: Consolidations – Where Is It All Up To And What Does It Mean?Speakers: Ken Spence, CTA (Life), Greenwoods & Herbert Smith Freehills & Ryan Leslie, ATI, Greenwoods & Herbert Smith Freehills

Given the critical importance of the consolidation regime to resources M&A transactions, this session will focus on the current state of play in relation to an array of government announcements over the last three years including the last Federal Budget. As well as analysing the potential practical implications of these developments, this session will also revisit ongoing issues for the resources sector.

11.30am–12.30pm Session 13: M&A Topical IssuesSpeaker: James Macky, CTA, KPMG & Angus Wilson, ATI, KPMG

The current wave of tax reform both in Australia and internationally means there is never a dull moment in M&A. In this session, we will discuss recent tax changes – both proposed and implemented – and how they are likely to impact resources transactions. The topics covered include:

� Trends in financing and structuring arrangements – how are companies financing acquisitions and expansions? � Attribution managed investment trusts (AMITs) – impacts for investors and vendors of infrastructure assets � Non-resident investors – trends and possible trends for structuring investments into Australia, including the impact of BEPS and the proposed rules for collective investment vehicles.

12.30pm Close

Day two – Thursday 27 October 2016 (cont)

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Philip Bisset, CTA, is a taxation partner at Clayton Utz. He has over 27 years’ experience in many facets of revenue law and commercial taxation, practising as a lawyer, chartered accountant and corporate tax manager. He has significant experience in managing audit and tax disputes and in negotiating settlements to successful outcomes. Philip also helps his clients develop robust tax policies and risk guidelines to minimise the potential reputational and commercial threats to their organisations in connection with tax audits and disputes. Philip is the instructing solicitor for a number of cases currently before the Federal Court.

Louise Clarke is an Assistant Commissioner at the ATO. As part of her current role in the ATO’s Tax Counsel Network, she leads the newly formed Infrastructure Focus Group. Louise is also heavily involved in strategic litigation and international taxation matters, including transfer pricing cases. In recent years, Louise has also worked on new tax measures, the most recent example being the replacement rule for s974-80.

Peter Collins, FTI, is a specialist in global tax, assisting foreign investors structuring their Australian investments and Australian corporates expanding offshore. He works with the firm’s global tax network to develop solutions to complex cross-border problems for clients and is a member of the global firm’s International Tax Services executive. Peter is a member of the Australian Treasury’s BEPS Tax Advisory Group.

Fiona Craig, ATI, is the national leader of Deloitte’s Transfer Pricing practice and has over 18 years experience with Deloitte in Australia and the UK, including 13 years specialising in transfer pricing. She has experience implementing and pricing tax-efficient structures for large listed and privately owned multinationals. Fiona advises clients across a variety of sectors, with a particular focus on energy and resources.

Martin Fry, FTI, has been a Partner in the Allens Tax Group for over 15 years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto’s 2015 off-market

tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects, including the M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne.

Nicki Ivory is National Mining Leader at Deloitte and leads the Perth Financial Advisory practice. She has over 20 years professional experience in Australia and South Africa. Nicki has experience in providing valuation advice, including independent expert reports and other non-public valuations. She has also advised clients on the buy and sell side of transactions, with a focus on the resource industry and companies that service the resources industry.

Tim Kyle, CTA, is a Director of Greenwoods & Herbert Smith Freehills, based in the Sydney office. He focuses on the resources and financial services industries, advising clients on a wide range of income tax matters, including mergers and acquisitions, capital management, cross-border dealings, market value issues, audits and tax litigation. He lectures on market value issues in the University of Sydney Masters of Law programme.

Stuart Landsberg, FTI, is a partner specialising in international tax and the energy and resources industry. He has over 10 years experience focusing on the resources industry, including three years in PwC’s Sydney office advising clients on the tax implications of inbound and outbound investment. Stuart is a member of the firm’s Australian international tax and energy and resources focus groups and regularly contributes to the firm’s thought leadership in both areas.

Ryan Leslie, ATI, is a Senior Associate in the Melbourne office of Greenwoods & Herbert Smith Freehills. Ryan has experience in advising on the income tax aspects of a broad range of corporate, international and trust tax taxation matters, with a particular focus on mergers and acquisitions, internal restructures and disputes. Ryan has also been involved in assisting clients in their dealings

with the ATO on various corporate tax matters, including tax consolidation.

James Macky, CTA, is a Partner with KPMG, and has been advising on corporate tax for 20 years. James is the leader of KPMG’s Tax Advisory Services business and is the Chair of KPMG’s Energy and Natural Resources group in Victoria. In addition he is a Senior Fellow of the University of Melbourne, lecturing in Mineral and Petroleum Tax.

Larry Magid, CTA, has been a Tax Partner at Allens for over 30 years. He specialises in corporate and international taxation including, in particular, financing issues, capital raising and company distributions. He has represented the Law Council of Australia in consultations with government on Part IVA (as well as on the NTLG Finance & Investment Subcommittee) and was a member of the Roundtable which advised Treasury on the amendments made to Part IVA in 2013. He was also a member of the Board of Taxation working group which conducted the post-implementation review of Div 974.

David W Marks QC, CTA, appears in court as a specialist advocate. He gives tax advice informed by his appearance practice. He was called to the Queensland Bar in 2000. Prior to that, he worked in tax with a large firm of solicitors for 10 years. David has appeared for and against the revenue, as well as in the equitable, administrative law and commercial jurisdictions of the state and federal courts, and in tribunals.

Michelle Mori is a Partner with EY and has over 15 years experience providing specialist tax and tax accounting advisory services to local and multinational organisations. She specialises in assisting Australian and multinational companies in the preparation of their ongoing tax accounting disclosures, including the impact of tax accounting on acquisitions and disposals. In addition, Michelle is experienced in the development of processes to assist companies in the preparation of their tax accounting obligations and has extensive experience in relation to providing corporate tax compliance services to clients.

PRESENTER PROFILESAn overview of our experts

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John Nicolaou joined ACIL Allen Consulting in August 2015 as a Director, before taking on the role of Executive Director of the Perth Office in February 2016. He is highly respected across business and government at a state and federal level, with nearly 20 years of experience as an economist, policy leader and senior executive working at the Commonwealth and WA Treasuries and the Chamber of Commerce and Industry of WA (CCIWA). As Chief Economist at CCIWA for more than 10 years, John led the organisation to become a key source of economic intelligence, with a particular focus on resources. He developed WA surveys of business and consumer confidence, a leading index of WA economic activity and forecasting model for the WA economy. As a senior executive at CCIWA, John also led its policy development and advocacy, contributing to the debate on a range of business issues, including through the development of thought leadership papers on human capital, the federation, taxation reform, energy markets, productivity and infrastructure. In leading the development of key policy papers, John has represented CCIWA and its members to governments at a state and federal level, and presented to government inquiries, media and conferences and events. John holds a Bachelor of Economics with First Class Honours and a Master of Business Administration from the University of Western Australia, and has been an Adjunct Professor at Curtin Business School. In recognition of his contribution to economics and the policy debate, John won a prestigious WA Business News 40under40 award in 2011.

Katrina Parkyn, ATI, is a Partner in the tax group at King & Wood Mallesons. While based in Brisbane, she routinely advises on transactions Australia-wide across a range of sectors, including major infrastructure, resources and funds management. Katrina has a breadth of experience which spans from advising on routine tax queries to advising government entities and major corporations on some of their most complex and novel transactions. She has particular experience in advising on projects that involve significant land and land-related assets.

Hugh Paynter, CTA, is a Partner in the Disputes group of Herbert Smith Freehills. Hugh has extensive experience in commercial

dispute resolution and has a particular focus on tax disputes, acting in cases involving strategic advice and risk reviews through to litigation in Courts and Tribunals. He regularly represents clients in matters involving valuation issues, including for energy and resources clients in revenue matters at both State and Federal level.

Jonathan Rintoul, CTA, is a partner at EY in Melbourne. Jonathan’s experience includes providing corporate tax advice and compliance services to listed, government, private and foreign-owned entities, predominantly in the resources, energy and utilities sectors. This experience is complemented by two long-term secondments into senior “in-house” tax roles for listed entities, including during 2015 when Australian corporate taxpayers faced a range of new tax transparency demands in the face of increasing public interest in this issue.

Ken Spence, CTA (Life), is a Special Counsel in the Melbourne office of Greenwoods & Herbert Smith Freehills. He has been closely involved for many years in advising Australian and foreign-owned listed companies on M&A transactions and has been extensively involved with both clients and tax professional bodies in relation to all aspects of the tax consolidation regime. Ken is a past President of The Tax Institute.

Simon Steward QC, FTI, is a barrister who specialises in revenue law. Simon took Silk in 2009, and has appeared in numerous cases in the Federal and High Courts, including the recently heard Chevron matter, and the BHP Billiton Finance, Noza Holdings, SNF, Roche, WR Carpenter, Bluebottle, McNeil, Citylink and Sun Alliance cases. He is also a Senior Fellow in the University of Melbourne Faculty of Law and is the immediate past President of the Tax Bar Association.

Angus Wilson, ATI, is the Head of Deal Advisory M&A Tax for KPMG’s Australian and ASPAC practices with extensive expertise in Australia, Asia-Pacific and Europe in relation to structuring transactions and global funds. Angus has over 15 years experience in advising Australian companies on transactions as well as international and M&A tax issues. He was previously based in the UK where he led KPMG UK’s tax initiatives in relation to infrastructure, power and utilities and building and construction.

Ann-Maree Wolff, CTA, has over 24 years experience as a qualified tax professional with over 14 years experience in senior tax roles within the mining industry. She is currently the Asia Pacific Head of Tax for Rio Tinto responsible for all tax matters relevant to Rio Tinto in Australia and the broader Asia Pacific region. She is a Chartered Tax Advisor and Fellow of Chartered Accountants Australia and New Zealand. Ann-Maree has been extensively involved in tax policy development in her roles on the Tax Committees for the Business Council of Australia and Minerals Council of Australia, the Executive Committee of the Corporate Taxpayers Association, as well as through consultation directly with the Australian Treasury. Ann-Maree is a member of the Board of Taxation, which is a non-statutory advisory body that provides the Australian government with real-time advice on tax policy issues by contributing a business and tax community perspective to improving the design and operation of taxation laws.

Jonathan Woodger is a Deputy Chief Tax Counsel at the ATO. Along with the Chief Tax Counsel, and the other three Deputy Chief Tax Counsels, he has overall responsibility for the ATO’s interpretation of the tax law. Jonathan took over this role in 2011. He is now Chair of the ATO’s General Anti-Avoidance Rules Panel in Melbourne. Jonathan spent the first nine years of his career as a legislative drafter at the Office of Parliamentary Counsel in Canberra, where he drafted a large amount of tax legislation and many other measures. He joined the ATO in 2003.

PRESENTER PROFILESAn overview of our experts

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FURTHER INFORMATIONWhat, when and how to

Online registrationDelegates are encouraged to register online at taxinstitute.com.au/nrtc

Registration inclusions � Participation in the full technical program

� Access to all PowerPoint presentations and technical papers via The Tax Institute app

� Materials may be purchased on a USB or in hard copy for an additional fee.

� Sundowner welcome reception

� Conference dinner

� All refreshments during conference hours.

� Registration fees do not include accommodation or hotel incidentals.

Early bird registrationAll registrations received and paid for on or before Friday 9 September 2016 will be entitled to an early bird discount.

Group discountsPurchase four full conference registrations (advanced, early bird or standard) and receive a fifth full registration for FREE. This offer cannot be redeemed in conjunction with any other offer, promotional code or discount. All attendees must be from the same firm and all registration forms must be submitted together.

Tailored packages For tailored group packages, please contact Brian Martin for a tailored package on 08 6165 6600 or email [email protected]

VenueCrown Perth Great Eastern Highway Burswood, Western Australia

Crown Perth is a fully integrated entertainment precinct renowned for its world-class facilities and luxury accommodation.

Situated on the eastern banks of the Swan River, it is only minutes from the Perth CBD and both domestic and international airports.

Crown Perth is home to many premium restaurants, including Rockpool Bar & Grill, Nobu, Bistro Guillaume, Silks and Modo Mio.

AccommodationAccommodation has been reserved for delegates at favourable room rates at Crown Promenade and Crown Metropol. Conference room rates are available to delegates until Friday 23 September 2016 (subject to availability).

Crown Metropol «««««Crown Metropol offers distinctive, modern and stylish accommodation within the Crown complex.

Room rates $290 room only; $325 breakfast for one; $350 breakfast for two at Atrium (subject to availability)

Crown Promenade ««««Crown Promenade is adjacent to the Crown complex and offers modern, stylish and affordable accommodation a short walk from the conference facilities.

Room rates$250 room only; $275 breakfast for one; $295 breakfast for two at Market & Co (subject to availability)

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FURTHER INFORMATIONWhat, when and how to

Booking Accommodation

OnlineAll delegates are able to secure and manage their reservations directly with the hotel via the following dedicated website: https://resweb.passkey.com/go/2016NationalTaxConference

PhoneDelegates can contact the Reservations Department on 08 9362 8888 (choose option ‘3’ after selecting hotel). To book Crown Metropol quote TAX261016MP; for Crown Promenade quote TAX261016PP.

Car parkingThere is a range of free, paid, undercover and open car parks at Crown.

Getting therePlaneRegular flights operate between Perth and major cities around Australia. Delegates are advised to book early to secure best pricing.

Taxi ranks are located on the ground floor of the domestic terminals (T2 and T3).

Public transportThere are convenient train and bus services close to the venue. To plan your journey, please contact TransPerth on 13 62 13 or visit transperth.wa.gov.au.

Social activitiesPerth and greater WA is a great place for a weekend stay. For information on activities in Perth during the conference, visit westernaustralia.com or showmeperth.com.au.

Welcome sundowner reception – Wednesday, 26 October 2016Network with speakers and delegates as you enjoy drinks and canapés. This event will be held onsite at Crown Perth and is included for all full conference delegates, with additional tickets available to purchase for $80.

Please note that dinner on Wednesday night is not included in the registration fee. Crown Perth boasts a variety of restaurants, including Rockpool Bar & Grill, Nobu, Bistro Guillaume, Silks and Modo Mio. To make a booking please contact dinner reservations on 08 9362 7551.

Conference networking dinner – Thursday 27 October 2016This year the gala dinner will be held at the Crown Perth. The dinner is included for all full conference delegates, with additional tickets available to purchase for $160.

Dress codeBusiness or business casual clothing is suitable for the duration of the conference.

The 2016 National Resources Tax Conference appThe app will be accessible for delegates to download all available presenter materials and event information one week prior to the event. The app will contain session and presenter information, delegate list, sponsor offers and other relevant information.

Printed materials Printed materials are not included in your registration. A delegate folder with all available printed materials (technical papers and slides) can be purchased at a cost of $100 or for an additional $50 receive the materials on a USB. These must be purchased and paid for in conjunction with your registration. Please note there will be no additional folders available for purchase at the event.

Delegate listA delegate list will be included in the conference folder to assist with networking. Please indicate on the registration form if you do not want your name included on the list.

Confirmation of registrationAn email confirming your registration will be sent to the email address on your registration form. If you do not receive this confirmation, please contact the Perth office on 08 6165 6600 or [email protected].

CPD accreditationAttendance at the conference counts for 12 hours of Structured CPD Accreditation with The Tax Institute.

Changing or transferring sessions Space permitting, delegates will be able to amend their concurrent session selection on the day. Registrations can be transferred subject to the Institute’s alteration and cancellation policy.

Alteration and cancellation policy The Tax Institute reserves the right to alter, amend or cancel all or any of the arrangements contained in the program. It is a condition of acceptance of registration that an administration fee of 20% of the registration fee will be charged for cancellation. No refund will be given for cancellations received within five working days of the event. A replacement may be nominated. If the replacement is not a member, the non-member or new member registration fee will apply. CPD hours will be allocated to the designated attendee. The Tax Institute cannot accept responsibility for delegates’ late transport arrivals or non-arrivals due to delays.

EnquiriesFor further information regarding this event, please contact Destelle Taylor in the Perth office on 08 6165 6600 or email [email protected].

Join Australia’s leading professional tax body

There is no time like the present to join Australia’s premier tax body and take advantage of the special new member introductory offer. The new member registration fee includes the fee for Affiliate level membership of The Tax Institute so that you can take advantage of the many benefits membership affords. Membership extends until 30 June 2017.

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Early bird registration Received on or before Friday 9 September 2016

Standard registration Received after Friday 9 September 2016

Member New member* Non- member Member New member* Non-member

Full conference registration $1,600 $1,900 $1,795 $1,750 $2,050 $1,950

I acknowledge that I will receive electronic access to the available papers and presentations through The Tax Institute CPD app.

I would like to purchase a hard copy of the available technical papers and PowerPoints – add $100 (refer to “Printed materials” on page x)

I would like to purchase a USB including technical papers and PowerPoints – add $50 (refer to “Printed materials” on page x)

Flexible registration options Member New member* Non- member

Wednesday only^ $495 $795 $595

Thursday only^ $895 $1,195 $995

Friday only^ $495 $795 $595

^Single-day registration does not include tickets to any networking function. Tickets can be purchased separately for the welcome reception and conference dinner.

*SPECIAL NEW MEMBER OFFER For an additional $300 on the member rate, become a member of The Tax Institute. The new member introductory rate will run until 30 June 2017 at the Affiliate level. Please read and sign below to take up membership. I hereby apply for membership of The Tax Institute. I declare I am a person of good fame, integrity and character and agree to be bound by the Constitution of The Tax Institute. For more information on membership, visit taxinstitute.com.au.

Signature: Date:

Register

OnlineSave time, register online at taxinstitute.com.au/nrtc

Fax02 8223 0077

MailGPO Box 1694 Sydney NSW 2001

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REGISTRATION FORMA tax invoice and confirmation letter will be sent on receipt of your registration. Please photocopy for additional delegates. All prices quoted include GST. ABN 45 009 392 372

PLEASE PRINT IN BLOCK LETTERS.

Select your technical sessions

Please tick the breakout sessions you would like to attend during the conference:

Thursday 27 October

11.30am–12.30pm Session 7A – What’s New for Tax Losses?

Session 7B – Transfer Pricing

1.30pm–2.15pm Session 8A – Accounting Concepts Invading Tax

Session 8B – Rehabilitation Obligations

2.15pm–3.00pm Session 9A – State Taxes

Session 9B – CGT & Non-Residents – Topical Issues

Registration options (all prices include GST) Delegate details

Title: (Dr/Mr/Miss/Ms/Mr/Other)

First name:

Last name:

Member no: Company:

Postal address:

Suburb:

State: Postcode:

Tel: Fax:

Email:

Dietary requirements:

Please tick this box if you do not wish your name to be included on the delegate list provided to all delegates.

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12 - THE TAX INSTITUTE - 2016 National Resources Tax Conference

Total payable $

I enclose a cheque* for $ OR

Please charge my credit card $

AMEX Visa MasterCard Diners

Card no. / / /

Expiry date:

Cardholder’s signature:

Cardholder’s name:

*Please make cheque payable to The Tax Institute.

Payment method

Conference networking dinner (For catering purposes please complete the following)

The conference dinner is INCLUDED in the registration fee for delegates attending the full conference. Day delegates and guests can book tickets at an additional cost below.

Day two – Thursday 27 October 2016: Crown Perth

Please note that dinner places are limited due to the venue’s limited capacity, so please advise as soon as possible if your attendance option changes.

Yes, I WILL be attending the conference dinner OR No, I WILL NOT be attending the conference dinner

Additional tickets

Yes, I require additional tickets for the conference dinner at $160 per person: $

Name(s):

Dietary requirements:

Sundowner welcome reception (For catering purposes please complete the following)

The welcome reception is INCLUDED in the registration fee for delegates attending the full conference. Day one – Wednesday 26 October 2016: Crown Perth

Yes, I WILL be attending the Sundowner reception OR No, I WILL NOT be attending the Sundowner reception

Additional tickets

Yes, I require additional tickets for the Sundowner reception at $80 per person: $

Name(s):

Dietary requirements:

Accommodation

To book accommodation, please follow the link on the National Resources Tax Conference website to receive the negotiated rate at hotels within close proximity to the conference.

Payment details summary

Payment details summary $

Delegate registration fee $

Printed delegate folders (add $100) $

USB (add $50) $

Additional welcome reception ticket(s) (add $80 per person) $

Additional conference networking dinner ticket(s) (add $160 per person) $

Total payable $

ReplacementsPlease note: registrations for the event are not interchangeable but replacements are acceptable. Please notify us at least two days prior if you intend on sending a replacement. CPD hours will be allocated to the designated attendee. If the replacement is not a member, the non-member registration fee will apply.

CancellationsThe Tax Institute must receive cancellations in writing five working days prior to the seminar. No refund will be given for cancellations received within five working days of the event. It is a condition of acceptance of registration that an administration fee of 20% of the registration fee will be charged for cancellation. A replacement may be nominated. Further details on The Tax Institute’s cancellation policy can be found at taxinstitute.com.au.

For all event enquiries and registrations, For event enquiries, please contact Destelle Taylor on 08 6165 6600 or [email protected].

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