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Description

Many Singapore taxpayers are required to prepare transfer pricing documentation for Year of Assessment (“YA”) 2019 in accordance with Section 34D of the Income Tax Act and the Income Tax (Transfer Pricing Documentation) Rules 2018.  Stemming from the need to prepare mandatory transfer pricing documentation, the IRAS has started conducting transfer pricing audits whereby IRAS has explicitly requested for transfer pricing documentation. 

 

While taxpayers may have prepared transfer pricing documentation, IRAS has also commented on the inadequacy of such documentation in certain cases. Thus, this workshop addresses the pertinent question of whether the transfer pricing documentation prepared will withstand the scrutiny of IRAS. 

 

The highly-experienced Trainer will share practical experiences from case studies and live audit cases, and observations on the type of scrutiny that IRAS applies to transfer pricing documentation.  

What you will learn

At the end of this workshop, you will:

 

• Understand the key areas of scrutiny applied by IRAS to transfer pricing documentation
• Evaluate whether your transfer pricing documentation is prepared in a manner consistent with Income Tax (Transfer Pricing Documentation) Rules 2018
• Defend and enhance your transfer pricing documentation during transfer pricing audits. 
• Have heightened knowledge on handling tax authority queries

Programme Outline

The transfer pricing landscape

• Key drivers of transfer pricing
• Key takeaways from BEPS Action Plans

Components of transfer pricing documentation

• Understanding transfer pricing documentation compliance in Singapore
• Preparing transfer pricing documentation
• What related party transactions exist in your organisation
• Do your related party transactions demonstrate compliance with the arm’s length standard

Does your transfer pricing documentation withstand the scrutiny of IRAS? 

• Through a live case study, we will further examine the following:
  • Areas of IRAS scrutiny
  • How can you answer queries raised by IRAS?
  • Defending your transfer pricing documentation

Dispute resolution and prevention strategies

• What is an APA?  Conditions to rely on an APA
• What is a MAP? Conditions to rely on an MAP
• Using APA/ MAPs to your advantage

Expert Speaker

Dr Sowmya Varadharajan is a Director at IC Advisors Pte Ltd, a firm that helps companies design and document appropriate transfer pricing strategies and approaches for their related party transactions. Having been trained in the U.S. on international tax and transfer pricing issues through blue-chip corporations, Sowmya now applies her transfer pricing training to transfer pricing issues in the Asia Pacific region.  Sowmya has extensive experience in the high technology/semiconductor as well as pharmaceutical/biomedical industries. In addition to transfer pricing, Sowmya is also skilled in IP valuation.  With the growth in transfer pricing related audits in the Asia Pacific region, Sowmya has assisted clients in India, China, Malaysia, Indonesia and Singapore in defending their transfer pricing arrangements with tax authorities. Sowmya is an economist with Ph.D. in Economics from Cornell University and has more than 17 years of transfer pricing consulting experience.