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The dawn of 2020s’ has engulfed the world of transfer pricing with the Organisation for Economic Co-operation and Development (“OECD”)'s Base Erosion and Profit Shifting (“BEPS”) 2.0 initiative and the COVID-19 pandemic. Amidst the current topsy-turvy economic and regulatory-burdened climate, the time now is ripe for Operational Transfer Pricing (“OTP”) to re-surface in streamlining transfer pricing requirements with overall business drivers.
Companies are being assessed on whether their transfer pricing policies are on par with what is happening in reality. Tax authorities are also scrutinising companies' year-end results to evaluate their comparability with forecasts projected at the year’s commencement and, if not, whether there is a valid commercial reason for any true-up adjustments.
This is particularly a critical issue as companies are approaching the financial year end during a volatile, uncertain, complex and ambiguous world. Given that impact of COVID-19 on business operations, it is likely that the transfer prices set at the beginning of the financial year are not likely to appropriate as year-end approaches. Thus, it is necessary for taxpayers to determine if any transfer pricing adjustments have to be incorporated either before the financial year-end or when the tax return is submitted.
In view of the above, this workshop sets out to explore transfer pricing documentation and OTP in a renewed light by exploiting its boons and banishing its so-called banes.
Operational Aspects of TP
Transfer pricing documentation
Transfer pricing audits
At the end of this workshop, you will:
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.
This is a face-to-face event to be conducted on 26 October 2020