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Australian Financial Markets Association Liaison Group key messages 21 May 2021

Summary of key topics discussed at the Australian Financial Markets Association Liaison Group meeting 21 May 2021.

Last updated 9 September 2021

Welcome and opening remarks

The ATO is seeing staff returning to the office more and therefore able to meet face to face going forward, though may depend on room availabilities.

The ATO has issued a letter to AFMA regarding Justified Trust for the Top 1,000. It contains guidance on how Top 1,000 foreign banks can take steps to obtain high assurance. It represents the gold standard and highlights the areas where the ATO have not, in certain circumstances, been able to obtain high assurance. However, it is not expected that taxpayers would necessarily invest to obtain high assurance on all issues.

Given that the ATO is still completing the first round of Top 1,000 cases, additional issues may be added once those cases conclude.

The ATO noted that the foreign bank cohort was not one where it was seeing systemic or widespread tax risks or interpretative issues.

The intention is that the letter will make it easier for taxpayers to achieve a higher level of assurance the next time they are reviewed.

There are still eight cases outstanding in the first round, a majority which will complete in the next six weeks, and a couple with later due dates in the next financial year. Due to the complexity of the business, nature of the products offered and the extent of related party transactions, the ATO often spends more time reviewing compared to other industries. This does not reflect adverse findings or poor performance, merely complexity of the industry that requires additional work.

The ATO is considering what commentary it can include in the annual report around the foreign banks.

As the ATO now begins the second round of reviews, taxpayers that reached high assurance should have a lighter touch in this round. The focus will be on areas that the ATO has concerns with, with the aim of moving more to high assurance so there may still be a stronger touch for those where concerns remain.

However, from a GST perspective, this will be the first time a GST review will be incorporated.

Second round of Top 1,000 Combined Assurance Reviews

The second round reviews of the Top 1,000 population will be Combined Assurance Reviews (CARs), which reflect the broader integration of income tax and GST at the ATO.

For the banking & finance industry, income tax (IT) and GST teams will work together to complete the cases.

The CAR product involves IT and GST. For IT, it is an assurance based review, similar to the first round, while for GST, it is a high-level risk based product which seeks to identify areas of GST risk for further action and to increase our understanding of taxpayer’s GST governance frameworks.

Income tax

Round 2 should be more streamlined than Round 1, with heavy reliance on the foundation work and findings from Round 1. While the ATO will still focus on key areas, where a taxpayer received high assurance in Round 1, and where the facts and law are largely the same, the ATO may rely on Round 1 ratings.

The bigger focus will be on unassured areas, or areas that are new, such as the hybrid rules.

The ATO is already nearing the end of the first financial year for Round 2, with some Banking and Finance (B&F) cases underway.

The four pillars of Justified Trust will still require the ATO to look at book to tax, corporate tax governance, risks flagged to marked, that is, relevant Practical Compliance Guidelines, Tax Determinations, Taxation Alerts that apply, and significant transactions of the taxpayer.

For the foreign banks, the ATO will again look at key tax issues such as transfer pricing, branch attribution, thin capitalisation, withholding tax, TOFA, and the reliance of the Australian operations on offshore support services and the attribution of those costs to Australia.

In parallel, Next Actions cases will also be commencing. These are more detailed, intensive reviews, focusing on issues identified in Round 1, typically those that received low assurance, or medium assurance due to large information gaps.

More Next Actions cases are scheduled to commence over the 2022 and 2023 financial years. As these are more detailed reviews, these will take time, and require the right capability, so will be spread out over Round 2.

Next Actions cases will focus on prior year tax returns that might have been reviewed in the first round of cases. However, since Round 2 will also consider subsequent years that have been lodged, it is envisioned that it will be a single engagement with the taxpayer.

AFMA queried whether taxpayers know if they’re marked for Next Actions, and where there is any commonality between Next Action cases across the industry.

The ATO noted that no notification letters have been sent out to date, so taxpayers are yet to be notified if they will be subject to a Next Actions case. However, a couple more taxpayers might be notified in the next couple of months.

In terms of commonalities, some of the issues captured in the Top 1,000 Key Observations letter will be reviewed in these one-to-one Next Action cases.

Round 1 led to the development of an internal framework that captures key tax technical areas that need to be addressed in foreign bank cases, such as branch attribution, funding, how the booking model operates in Australia, the use of detailed profit split methodologies. This will also assist staff to tailor and streamline the reviews in Round 2.

AFMA asked what the ATO’s strategy was to incorporate the hybrid rules in to Round 2, and whether there was a specific hybrid request for information (RFI).

The ATO noted that it was having a number of discussions with advisors, and so did not expect too many problems in the industry in relation to hybrids. There are standard questions in the RFI about the hybrid rules, although it is unlikely to form an altogether separate questionnaire. The ATO can share those questions with AFMA to discuss.


The GST reviews in Round 2 are considered a more risk-based product, and this will be reflected by the GST input into the RFI questionnaire, with specific questions for financial services and insurance.

At the end of the CAR, the aim is to determine whether there are risks that need to be escalated to a Streamlined Assurance Review or another product.

Most cases commenced so far are at the smaller end of the market, such as domestic banks or credit unions. It is anticipated that entities at the larger end of the population may be selected for review soon.

Some entities may be selected for a more tailored product, such as a GST risk review, which will involve a deep dive to key issues under the GST Financial Services and Insurance (FSI) strategy.

ATO areas of focus under GST FSI strategy

Key issues to be reviewed will be GST apportionment, entitlement to reduced input tax credits and the application of reverse charge, as well as some other GST issues.

The ATO will be looking to see that taxpayers have GST apportionment methods that are well thought out, documented, reflect how costs objectively relate to their supplies, and are regularly updated. GST reviews will also cover compliance with recent public guidance to market on GST apportionment for specific financial products, such as credit cards, transaction accounts and home loans.

For foreign banks in particular, the application of the reverse charge provisions is a key consideration, as this also applies to intra-entity transfers. The ATO is looking to leverage off the transfer pricing work under income tax reviews to get assurance over the treatment of those transactions for GST. For example, for the allocation of management services from Head Office to the Australian branch, the reverse charge provisions would likely apply.

AFMA queried whether a taxpayer could be reviewed for both IT and GST at the same time.

The ATO stated that would be the case, with both IT and GST teams working together to address the review. If an adjustment is made to transfer pricing, the ATO would expect the same approach to be taken for GST. For example, when considering the allocation of costs from head office, the ATO would expect a similar approach across both IT and GST.

In terms of case selection for GST risk review products in particular, the ATO will be looking at taxpayers that have a particular risk for GST, likely at the larger end of the market, with particular issues such as GST apportionment or the application of the reverse charge. For a small group of taxpayers, the ATO is seeking to start reviewing those risks now, rather than waiting for a CAR to end. There is a very small population of taxpayers that would be in this category, where the ATO is reasonably certain that there are issues that the ATO would like to consider in detail.

The ATO noted that the GST FSI strategy team has developed internal documentation that sets out what teams should be considering so the reviews should be consistent and streamlined.

AFMA queried whether there would be further schedules to Practical Compliance Guideline PCG 2019/8 ATO compliance approach to GST apportionment of acquisitions that relate to certain financial supplies. The ATO stated that there were none planned at this stage, but that could change as reviews are completed where issues are identified.

Data testing for banks and insurers to prepare for reviews

There was a request from the industry for bespoke tests to deal with GST in relation to banking and insurance.

The ATO has sought to develop these data tests to try and deal with the specific risks that apply in the banking industry. For example, it has developed a test to look at transactions that may be subject to the reverse charge, by looking at invoices with overseas addresses and invoices in foreign currencies and matching to see whether they have been identified as having a reverse charge liability.

The tests have focused on some of the risks identified, such as whether recipient created tax invoices are validly issued. The tests have been designed so that taxpayers can conduct their own self-reviews prior to reviews.

AFMA noted that data generation will need an extended lead time to get internal IT involved in providing data in relation to reviews, and the ATO acknowledged that notice and due time will be provided in the event of a data request.

Justified Trust Top 1,000 Banking & Finance – Key Observations letter

Last year, it was flagged that one of the things the ATO was going to look at was whether it could use a ‘one to many’ approach to get key messages out to the market, with a real focus on messaging to assist taxpayers and provide more objective messaging about how to get to high assurance.

The decision was made to issue a letter rather than formal public advice and guidance because this would be more practical, and taxpayers can decide whether they want to invest their resources to get to high assurance.

The letter applies to the Top 1,000 B&F industry, which, other than foreign banks, also includes regional banks, credit unions, mutual banks and other non-bank entities.

However, a lot of the messaging in the letter is focused on foreign banks, since it is the largest submarket, and also due to the complexity of their operations.

The ATO considered issues that were common across multiple taxpayers, and developed a series of appendices to the letter that describes the problem, what was hindering taxpayers from getting to high assurance, provides practical examples to illustrate the issue, and then outlines what steps taxpayers may take to get to a level of high assurance.

The two significant appendices are Appendices B and C, which deal with transfer pricing of cross border dealings and branch attribution with mark-ups applied to cost allocations.

Appendices A, D and E resulted where some taxpayers have been taking a proxy or shortcut approach to the way they’re administering the law, or otherwise did not have a clear understanding of what is expected under the law. The ATO is not saying that there is mischief in these areas but wants to get the messaging out to the market that more information and analysis is required when using these proxy approaches, or that maybe some approaches are not quite in line with the law.

The letter and appendices are a culmination of the work that the ATO has completed on the Top 1,000 B&F population. It is not a criticism of the industry, and the ATO notes that achieving a medium level of assurance is actually a good outcome given the parameters of the case itself and the technicality of the issues involved.

The ATO noted that there is no expectation for the banks to achieve a level of high assurance, but at least provides the industry with the steps required to improve.

The ATO noted the potential scope for another letter to include funding.

AFMA noted that it was a positive step to issue the letter and agrees that it sets out the pathway to obtaining high assurance, giving clear expectations, with no ambiguity.

AFMA appreciated that the letter identified that there were no widespread concerns identified within the industry, as well as the confirmation that, while the Top 100 is expected to get to high, it is not the expectation that Top 1,000 will get there.

AFMA noted that members are considering whether there are any Australian Prudential Regulation Authority (APRA) or Australian Securities and Investments Commission (ASIC) consequences if any issues are rated with a red flag, that is whether there may be potential reporting requirements to ASIC under the breach reporting rules.

The letter also highlights that lower assurance is broadly associated with information gaps, where taxpayers are not providing adequate information to allow for testing or analysis. For example, where a taxpayer is asked for transfer pricing documentation that is reflecting of the Australian operations, but this is only available at the group level, this inherently leads to information gaps, particularly if the taxpayer is not forthcoming during the case. Without being able to validate or align documents to the actual practice, the ATO would have to give a low assurance rating. However, if documentation is provided, then transactions can be tested to validate assertions, which could leader to attaining a higher level of assurance.

AFMA noted that it was important to ensure that everyone gets the same opportunity to provide the information that is requested, but that, for foreign banks, perhaps the expectations were too high with the parameters.

The ATO will follow up with AFMA about a more detailed session on the letter.

Appendix A: Ceiling applied to notional payments of interest on intra-bank loans

Concerns arose with taxpayers taking shortcut methods in selecting the correct London Interbank Offered Rate (LIBOR) to use, for currencies that were still being quoted in LIBOR.

Appendix A seeks to highlight the expectations of the law, that the correct LIBOR should be based on the tenor of the inbound loan.

For currencies not quoted in LIBOR, and not Australian Dollars (AUD), taxpayers have been using a market type interest rate, which is not a reasonable proxy for LIBOR, or no proxy at all. The ATO would expect some modelling on the currency and for taxpayers to use a reliable reference rate to determine the cap on funding.

The ATO acknowledged that there was an issue in the law.

AFMA queried how LIBOR transition would impact this issue and noted that the administrative solution for AUD was initially meant to be temporary, and there is no basis now to say that the solution reflects the right outcome today. In the case, AFMA noted that where the law does not work, the ATO needs to strike a balance between what is technically right and what the ATO’s expectation is.

The ATO noted that, to date, it appears that most taxpayers are conservative in their approach, using very low reference rates. However, there are also some that have been pushing deductions, saying that there is no cap where no LIBOR is quoted. The ATO does not agree with this position as there is clearly a policy for the cap even though the legislation specifically refers to LIBOR.

From a policy perspective, AFMA considers that subdivision 815-C can deal with this issue, and the cap is not necessary. LIBOR itself is not the best reference rate, as it is not quoted for tenors longer than 12 months, and the approach is not consistent with other jurisdictions.

Appendix B: Cross border dealings – general

Appendix B concerns the information gap the ATO has identified, with taxpayers providing insufficient documentation to support their transfer pricing positions.

The ATO noted that it is challenging for a lot of foreign banks, where they are only a small presence in Australia of a larger offshore foreign bank.

The ATO stated it is not seeing enough specificity in transfer pricing documents about what banks are functionally doing in Australia. It is common that the transfer pricing documents are not tailored to the functions in Australia. While the ATO may be able to get an understanding of policies from the documents, when the ATO is testing, it was not able to see the analysis at a transactional level.

It is a question for taxpayers as to whether it would be feasible for them to invest in developing that documentation to move to a high assurance rating.

The other part to Appendix B concerns the use of the comparable uncontrolled price (CUP) methodology. It is a common method for pricing related party financial instruments, such as loans, but taxpayers are using shortcut methods that purport to be a CUP, where it is not actually the case.

Appendix C: Cross-border internal dealings for management or general administrative services and mark-ups

Appendix C addresses the issue around the use of mark-ups. This is a problematic issue for the ATO. The ATO acknowledges that there are a mix of different legal views in the market and a lot of foreign banks’ home jurisdiction would operate under the functionally separate enterprise approach, while the Australian branch would be required to use the relevant business activity approach.

The ATO has been seeing charges coming into Australia for different functions, such as ‘general administrative’ functions, which then have a mark-up applied.

Legally, the ATO does not accept mark-ups, unless it is related to a more valuable function, and it is a proxy for the attribution of income to the head office.

The ATO view is that most advisors agree with the ATO’s position, however, there remain taxpayers still including mark-ups without the necessary evidence to support that approach.

This is one area that the ATO will be firm with, in the future.

The ATO noted that this was an ATO view, not just limited to the B&F industry, and refers back to Taxation Ruling TR 2001/11 Income tax: international transfer pricing - operation of Australia's permanent establishment attribution rules. However, not as many other industries operate with branch operations, or otherwise have a separate entity interacting with the branch, so subdivision 815-B would apply instead.

AFMA noted the difficulty in working out what the mark-up component is.

AFMA queried how the mutual agreement procedure (MAP) process would deal with this issue, where a treaty operates differently to determine if the correct transfer pricing allocation has occurred.

The ATO noted that competent authorities have broad powers to agree on issues however this issue has not been subject to a MAP process to date and accordingly took the question on notice.

AFMA noted the value of running a specific session on this appendix, and noted that, as Australia is promoted as a place to do business, the issue of double taxation is not ideal.

The ATO confirmed that the principle also applies to outbound charges, but the main issue identified was on support coming from offshore head office to Australia.

Appendix D: Thin Capitalisation for inward investing ADIs

The thin capitalisation rules and explanatory memorandum allow foreign banks to rely on their home regulator prudential approach for risk weighting assets. The ATO would like to see an analysis of how that risk weighting exercise is carried out, as well as the tax decision making in relation to risk weighted assets attributed to the Australian branch.

Appendix E: OBU regime and the allocation of expenses

The issue is taxpayers who are still using the old, pre-2015 formula. Taxpayers should have some reasonable analysis to support the use of a revenue-based apportionment, otherwise the ATO would not be able to accept it as appropriate.

Bail-in and Treasury request

AFMA has received the email from the ATO and has asked its members for further information and will also talk to other foreign banks that are not AFMA members. There may be some commercial sensitivity issues, though this can be addressed by aggregating data disclosures.

The ATO noted that it attempted to convey gravity of the situation for foreign banks to Treasury and would appreciate AFMA’s involvement to push this issue.

AFMA and the ATO agreed that AFMA would be included in any meetings with Treasury going forward.

Draft Practical Compliance Guideline PCG 2021/D3 Imported hybrid mismatch rule – ATO’s compliance approach

The hybrid rules were introduced as a result of Organisation for Economic Co-operation and Development (OECD) Base erosion and profit shifting (BEPS) Action 2, which a lot of other countries have also adopted, and it is expected more countries will follow.

The BEPS Action 2 rules contain imported mismatch rules, which revolve around arrangements in offshore jurisdictions, where the effect is to import the offshore hybrid mismatch into the Australian tax base.

PCG 2021/D3 has adopted a practical approach to a complex set of laws, in response to feedback that the rules were complicated, and advice was requested on what was needed to justify a deduction.

The approach is that, if you cannot support that you do not have an offshore hybrid, then you should not claim a deduction unless you can support.

This raised compliance concerns about proving that something does not exist and requires investigation across the global group and all structured transactions.

The Draft PCG outlines recommended approaches to assess whether you have an offshore hybrid of not:

  • The top down approach starts with the global head of tax or similar and looking through various entities and identifying any transactions that would result in a deduction/non-inclusion or deduction/deduction outcome. Where some countries have corresponding rules, generally if another country neutralises the actual benefit, then their rules apply first, for example, if UK rules are similar to Australia’s rules, and UK rules deny the hybrid outcome, then Australia’s rules will not need to be activated. If not neutralised by another country, and is a hybrid under Australian rule, then Australia will neutralise (deny deduction/include income).
  • The bottom up approach essentially traces all of a taxpayer’s transactions with related parties across the border to determine if there are any offshore hybrids that meet the Australian requirements and have not been neutralised by another country.

The Draft PCG also has created risk zones and will inform the level of ATO engagement with a taxpayer.

The main purpose for the Draft PCG is to create awareness of the rules, provide a practical guide for disclosures, and empower tax teams to make the relevant enquiries in their group.

The main message is that the imported mismatch rule is an integrity rule that has come from the OECD. The more that other countries follow and adopt the rule, the lower the compliance burden would be.

AFMA queried whether there was any extension to lodge submissions.

The ATO noted that submission are open until 21 May 2021, but if anyone needs an extension until 28 May 2021, email link opens in a new window

AFMA noted that among its members are a large number of inbound financial institutions, that operate in almost every other market, and identified the compliance burden articulate by this Draft PCG. AFMA noted that, for example, PCG 2017/4, prudentially regulated ADIs were identified as operating in a different realm, by virtue of the sheer number of their related party dealings which were often regulated. AFMA was trying to see how PCG 2021/D3 is fit for purpose for banks, particularly inbound banks.

AFMA noted another issue is the commencement date. AFMA has some 31 December lodgers, who will be needing to lodge by 15 July, within the next two months. There is a comment in the draft that the PCG would apply prospectively but also to prior periods.

The ATO noted that it does not expect the PCG to be finalised before August. For taxpayers completing the Reportable Tax Position Schedule prior to then, Question 38 will not need to be completed in respect to the Draft PCG. However, in terms of application of the rules and lodging their income tax returns, taxpayers will still need to be satisfied that they are entitled to claim the deductions included on their tax returns. The ATO would expect taxpayers to go back and amend returns if, when lodging a subsequent income year, they identify an offshore hybrid mismatch that may have been relevant for the prior year.

AFMA noted the reversal of the onus in paragraph 16 of the Draft PCG. AFMA also queried the way that the rules would apply in an intra-entity dealing, that is from a branch to its head office or from a branch to a branch. AFMA’s submission will seek to confirm that the rules apply only to separate legal entities, that flows internal within an entity will not give rise application of the rules.

The ATO noted that, even though the Draft PCG has red zones, given the extent of the work required to be done by taxpayers, the ATO would not be surprised if many taxpayers are in the red zone in the first year. However, the ATO is looking to see a change over time.

AFMA queried how the Draft PCG would be applied in a Justified Trust and assurance review perspective.

The ATO noted it would consider this.

LIBOR transition and ATO guidance

The ATO has drafted tax guidance on the LIBOR transition. This guidance is intended not just for the B&F industry, but also for the wider corporate population. However, the examples have a B&F focus. The guidance will take the form of a technical discussion paper, considering the income tax, withholding tax and transfer pricing consequences.

The aim is to circulate the discussion paper to the market in June for consultation. It would be beneficial if members could share the paper with internal colleagues that are responsible for the relevant products, those who will actually be close to carrying out the changes needed for the transition, such as updating contracts, the repricing, determining the economic equivalence.

The ATO wants to ensure the right terminology is being used, particularly around the contract law terms, for example, an amendment verses a cancellation or replacement. The ATO considers that most situations would be a variation of an existing contract but will be guided by industry on this.

Examples used in the guidance are based on simple loans, but the ATO will also want to include some examples with derivatives as well, so are seeking input from members.

The guidance should be applicable to all transactions, and will cover scenarios where parties cannot agree, and where additional ‘top up’ payments are made.

AFMA noted that ASIC and the RBA have set out regulatory obligations that require members to treat counterparties fairly, or to otherwise act in favour of the counterparty.

The ATO noted that AFMA members should note if there are certain scenarios that would never happen.

AFMA noted that it was part of a working group that is considering LIBOR transformation from all perspectives, involving all affected industry bodies. AFMA will ask those bodies for examples, then overlay the tax considerations.

The ATO also stated that it was seeking contrasting examples, such as where there might need to be a balancing adjustment or where there is a transfer pricing issue that needs to be addressed.

AFMA noted that it would be good to see where the lines are drawn, such as a scenario that would constitute a reoffer.


Interest and compensation payments are not new terms. The ATO has a lot of existing guidance and case law on this.

Web-based guidance was previously published in relation to individuals that receive those payments from financial institutions, which addresses the implications for individuals in terms of loss on investments, refunds or reimbursement of advisor fees, and interest components, as well as guidance in relation to compensation received by super funds.

In April, a fact sheet was published to provide guidance to financial institutions about their reporting and withholding obligations in relation to remediation payments.

The ATO’s position is that interest or interest-like payments relating to Part VA investments have to be reported.

The ATO noted it has no plans to obtain bulk data for non-Part VA investments. If this changes, the ATO will provide formal notice.

While there have been a number of requests for additional guidance in relation to the definition of ‘interest’ and what is ‘in the nature of interest’, there are no plans to do so at this stage. The ATO considers that there is already established guidance and case law on this issue.

However, the ATO has received some requests for private binding rulings on this issue. If a number of similar fact scenarios arise, then the ATO may seek to supplement existing guidance, but these cases are usually bespoke, so it would be difficult to provide general public advice or guidance on these.

In the meantime, the ATO is able to work with those taxpayers that have requested private rulings.

AFMA noted that the guidance appears to be fit for purposes, allowing people to understand the consequence of remediation payments and no members had raised any issues.

Other business

Offshore Banking Unit (OBU) repeal and transition issues

OBU law reform is currently before Parliament. AFMA noted that there will be a point in time where members move their businesses around in advance of a repeal of the regime. However, if things are moved into the domestic banking unit, queried how the purity test would apply in that context.

The ATO noted the OECD’s FHTP had accepted Australia’s proposed legislative changes in April and was not aware of any proposed incentives which was suggested by Government in its announcement.

COVID-19 FAQ document and TR 2002/5A3

The ATO noted that the COVID-19 frequently asked questions guidance for permanent establishments was yet to be updated on the website, but the compliance approach has been extended to 31 December 2021.

AFMA noted the addendum to TR 2002/5A3.

ATO Early Engagement Service for New Investors, as announced in Federal Budget 2021–22

The ATO noted that Chris Ferguson, Assistant Commissioner for Case Leadership, would be overseeing this measure.

International Dealings Schedule (IDS) Question 18 – branch operations

The ATO noted that it had encountered a situation where outbound internal loans, such as from an Australian branch to its offshore head office, were not always being reported under Question 18 of the IDS. This may be due to the way the IDS instructions are set out, which suggest that if a taxpayer is within Part IIIB, then they can skip Question 18 and instead complete Question 40. However, that instruction only relates to inbound internal loans.

The ATO will send its proposed change to the IDS instructions to clarify, and AFMA will circulate to its members.


Attendees list




Nicholas Maley (Chair), Public Groups International


Andrew Nutman, Public Groups International


Bruce Matheson, Public Groups International


Dale Seiler, Public Groups International


Elizabeth Hardcastle, Individuals and Intermediaries


Frank McNamara, Public Groups International


Hans Tan, Public Groups International


James Campbell, Public Groups International


Jennifer Kong, Individuals and Intermediaries


Lindy Tan (Secretariat), Public Groups International


Michelle Gainford, Individuals and Intermediaries


Philemon Daniel (Secretariat), Public Groups International


Rhys Chalmers, Public Groups International


Virginia Gogan, Public Groups International

Australian Financial Market Association

Rob Colquhoun

Bank of America

Wee-Ling Chuan

Commonwealth Bank

Claudia Pitt


Jeff Tan

JP Morgan

Alice Lam


Kane Nicholson


Paul Connor


Tony Lo Russo

Societe Generale

Ainley Viengkhou


Apologies list




Lise Rawlings