Nazly Parlindungan Siregar

Nazly Parlindungan Siregar

Nazly is a senior tax advisor in international tax and transfer pricing with Assegaf Hamzah & Partners in Jakarta, Indonesia. She was previously an international tax partner in a Big Four accounting firm in Jakarta, Indonesia with Southeast Asia coverage and headed the Chinese Practice Group for tax in Indonesia.

Nazly commenced her career in the US after completing her undergraduate degree in commerce with major in accounting at Santa Clara University and went on to finish her graduate study in taxation at Golden Gate University and eventually earned her Certified Public Accountant to practice public accounting from the State of California.

Nazly garnered invaluable experience working in San Francisco for over 8 years dealing mostly with Silicon Valley’s high-tech and bio-tech companies, both mature and start-ups. The issues were quite similar namely IPO, IPO readiness, pricing valuation of royalty and stock options, foreign tax credits, intangible migration and Controlled Foreign Corporation regime. She continued her international exposure by accepting an opportunity to work in London for almost 3 years. In London, she worked mostly with investment banks, private equities, hedge-funds and venture capitalists. This time around, the issues she faced were taxation on complex derivatives, IPO, cross-border acquisitions and joint ventures for US shareholders, capital gains on share divestments and complex lending arrangements using various debt instruments.

After the global financial crisis in 2009, she decided to return to her hometown of Jakarta and started collecting her Indonesian tax experience.

Experience

Nazly is an international tax and transfer pricing specialist with Assegaf Hamzah & Partners in Jakarta, Indonesia which includes cross-border M&A, business model optimization and international tax advisory. She has an extensive international tax experience, having worked at Big Four accountings firms in the United States and the United Kingdom for more than 10 years before returning home in 2009.

Nazly focuses on foreign Multi-National Companies, private equities, hedge funds and venture capitalists with their investments into Indonesia, from structuring the acquisition and financing plans, business restructuring and supply chain management to providing post-acquisition tax planning strategy and postmerger integration. In addition, Nazly is also proficient in international tax outbound scenarios in which Indonesian investors invest overseas. The issues associated with the outbound scenarios are profit repatriation strategy, anti-deferral regime under controlled foreign corporations rules and exit planning.

Nazly has represented foreign investors from the US, the UK, continental Europe and Asia Pacific and has helped Indonesian investors with their investments in the US, Southeast Asia and Australia.

Nazly is often invited by the Indonesia’s Director General of Tax to provide her technical analysis on international tax matters including 2016’s key note speaker on Taxation on Trust conducted by the Indonesian Chartered Accountants Association.

A native Indonesian with western education and training, Nazly can communicate seamlessly with both western corporate executives and the Indonesian Tax Authority.

Qualifications

  • International Merger, Acquisition and Joint Venture
  • IPO readiness and Pre-IPO strategies such as tax-neutral merger, tax-neutral spin-off and tax-neutral share dilution
  • Cross-border transfer pricing including royalty, interest and profit margin determination
  • Lending arrangements using variety of debt instruments
  • Tax structuring for oil and gas, energy, construction and utility companies in form of, among others: PSC, EPC, CoW and PPA

Memberships/Directorships

  • Member of International Fiscal Association
  • Member of European Chambers of Commerce, Jakarta Chapter
  • Independent Commissioner of Sequis Life Insurance

Publications

  • "Taxation of Trade Representative Office" - published by Asia Pacific Tax Bulletin, International Bureau Fiscal Documentation in September/October 2014 Edition
  • "Thin Capitalization and Secondary Adjustment" - published by Asia Pacific Tax Bulletin, International Bureau Fiscal Documentation in September/October 2013 Edition

Recognition, Accolades & Awards

  • Noted Indonesian International Tax Partner - by International Tax Review, September 2014
  • Noted Indonesian International Tax Partner - by International Tax Review, September 2013
  • Winner of 2012 PwC Experience from Indonesia - by PwC Asia Pacific for the best client services

Transaction Experiences (strictly 2009 onwards)

Cross-border Merger, Acquisition and Joint Venture

  • Advising on tax structuring and financing structure for Swedish and Malaysian private equities in their investments in an Indonesia’s hospital chain company from capital structure, repatriation of profit strategy and exit planning strategies including IPO, outright sale and liquidation
  • Advising on tax implications of property developing company from the choice of jurisdiction, the repatriation of profit, loan arrangement to exit strategy for a Japanese property developing company
  • Advising on tax structuring to a Beijing-based Chinese conglomerate in their investments into Indonesia’s shopping mall complex which consisted of luxury hotel, apartment units and department stores.
  • Advising on tax structuring, business model optimization on the usage of vouchers, customers loyalty points and membership in lieu of conventional payment for a US hotel chain company for their 3 hotels in Java and Bali
  • Advising on taxation in real estate developing company including local strata title sale v. assets sale, ownership model and future exit for Hong Kong property company
  • Advising on tax-efficient strategy on various divestments in Indonesian hotels, Indonesian mining companies and Indonesian beverage company

Capital Market, Banking, Financial Services, Lending Arrangement and Debt Restructuring

  • Advising on tax-free mergers of two Indonesian banks subsidiaries of two Korean banks
  • Advising on feasibility of financing arrangement via collaterized deposit for Hong Kong telecommunication company
  • Advising on taxability of profit made by an offshore entity on assumption of Indonesian debts from an Indonesian lender for a large Hong Kong telecommunication company
  • Advising on cross-border leasing for state-owned airline company including the use of holding company and its treaty applicability
  • Advising on IPO readiness for a large Indonesian conglomerate including but not limited to elimination of entities through spin-off, merger and split-up

Business Restructuring, Supply Chain Optimization and Transfer Pricing

  • Advising on tax structuring and supply chain management for a Swiss cocoa plantation and manufacturing company on its investment in Indonesia including proposed capital structure and tax optimization in export savings
  • Advising on supply chain management and business restructuring for a UK manufacturing company and its Indonesian subsidiary, taking the Indonesian subsidiary from a licensed manufacturing to contract manufacturing
  • Advising on tax structuring, business model optimization on the usage of vouchers, customers loyalty points and membership in lieu of conventional payment for a US hotel chain company for their 3 hotels in Java and Bali
  • Advising on tax structuring, financing structure and supply chain management for a Japanese cosmetic company to set up an Indonesian subsidiary as limited risk distributor
  • Advising on supply chain management and business restructuring for a Japanese pharmaceutical company and its Indonesian subsidiary, taking the Indonesian subsidiary from a licensed manufacturing company to toll manufacturing company
  • Advising on supply chain management and business restructuring for a Belgian manufacturing company and its Indonesian subsidiary, taking the Indonesian subsidiary from a fully-fledged manufacturing company to contract manufacturing

Oil, Gas, Energy and Infrastructure

  • Advising on Engineering, Procurement and Construction taxation for two European construction companies with their contract with PGN including the taxation for their expatriates
  • Advising on tax implication of joint operation (“KSO”) for a European consortium with their contract with Pertamina including the taxation for their engineers
  • Advising on tax-efficient strategy on Production Sharing Contract (PSC) between BP Migas and three European oil companies with the use of a SPC and advising on the tax implication of direct and indirect sale of PSC and the tax liabilities for Permanent Establishments with and without the treaty
  • Advising on Tianjin-based Chinese energy company in their divestment in 3 Indonesia’s palm oil plantation companies. Exit strategies include assets sale versus shares sale, termination of related party debt, and the use of tax losses
  • Advising on Tianjin-based Chinese mining company in their sale of PSC including the determination of the selling entity and the impact on the Branch Profits Tax

 

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