Annie Pan is the latest interview in our ‘30 Seconds With’ series. A tax expert within Asia, we took the opportunity to talk to Annie before she speaks at our TP Minds Asia 2016 conference.
What are you currently spending most of your time on?
Australian multinational anti avoidance law (MAAL) provisions.
What is the biggest challenge facing Transfer Pricing executives in your particular industry at the moment?
Permanent Establishments (PE) risks in digital economy. Specifically, where should the revenues be taxed? Should it be taxed in the contractual country only?
What should a successful post-BEPS transfer pricing strategy look like?
Be able to defend your company on a global basis. In particular, you should be able to prove it is purely commercial driven for the business model/structure that has been adopted on a global basis.
Arm’s length or formulary apportionment?
Arm’s length.
Which areas of TP do you think the next wave of transfer pricing controversy will come from?
Cost sharing arrangement.
Which jurisdictions are likely to be keeping the Head of TP awake at night?
China, India and Australia.
What advice would you give an aspiring TP professional?
To be able to understand not only TP changes, but also keep yourself aware in regards to each change in other countries’ tax laws, especially any alterations to direct tax legislation.
You’re attending and speaking at IBC’s TP Minds Asia in Singapore next week. What are you most looking forward to?
I am looking forward to the panel discussion on the Changing TP Landscape, which includes a representative from the OECD and will be an in-depth look at BEPS.
Tell us a little known fact about yourself.
I have lived diversely between the cultures of the East and the West, having worked and lived in Australia, China, Hong Kong and Singapore. Over the past few years, I have also been teaching Australian tax law for James Cook University part-time.
Annie Pan