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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.

Programme Outline


  • Base Erosion & Profit Shifting (“BEPS”) and key transfer pricing changes
  • COVID-19 and its impact on transfer pricing

Operational Aspects of TP

  • What is OTP?
  • Why is OTP gaining traction at this juncture?
  • How do you design and implement an effective OTP programme, i.e. end-to-end operating model, for the management of transfer pricing data, processes and governance?
  • What are the key OTP success factors?
  • What are the potential benefits and common fallacies of OTP?

Transfer pricing documentation

  • Understand transfer pricing documentation rules and regulations
  • Preparing robust transfer pricing documentation, relying on OTP.

Transfer pricing audits

  • Using OTP to defend in transfer pricing audits

What you will learn

At the end of this workshop, you will:

  • Grasp the working mechanisms of OTP
  • Learn to align inter-company pricing policies with transfer pricing processes and controls through OTP
  • Understand automation as an impetus to draw input and align various corporate stakeholders via OTP
  • Learn how to implement a reliable narrative for compliance purposes that covers both policies and data under OTP

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. 

This is a face-to-face event to be conducted on 26 October 2020

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