Description

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It is now mandatory for businesses to prepare the Transfer Pricing (TP) documentation, if certain conditions are met. Non-compliance with the TP Documentation Rules will effect a costly penalty of $10,000 per offence, to the taxpayer.

Additionally, the recent onslaught of the COVID-19 pandemic has led to further updates to the transfer pricing guidelines (e.g., IRAS issued FAQs in September 2020, and OECD’s guidance in December 2020).  It is therefore necessary to prepare the FY 2020 documentation with utmost care and compliance with the transfer pricing guidance. 

This Masterclass Programme is specifically designed to give Finance and Tax Professionals a practical and in-depth understanding of the intricacies involved in preparing and defending transfer pricing documentation.

Programme Outline

INTRODUCTION

Overview

• Overview of related party transactions entered into by MNCs
• Key triggers of related party transactions
• Singapore Income Tax Act transfer pricing provisions:  Section 34D – Section 34F

The Singapore Transfer Pricing Regime

• Detailed understanding of the 5^th edition of the Singapore Transfer Pricing Guidelines
• Income Tax (Transfer Pricing Documentation) Rules 2018
• Recent developments
• Case studies

Economic Analysis

• Analysing related party transactions
• Determining the appropriate transfer pricing method:  Requirements and process
• Benchmarking process
• Bridging the gap between documentation and implementation
• Implementation methodologies/price settings/ management measures
• Risk allocation and implementation
• Transfer pricing adjustments

Defending the Pandemic Year Outcomes

• Organisation for Economic Co-operation and Development (“OECD”) transfer pricing developments
• IRAS Guidance
• Summary of transfer pricing regimes in the Asia Pacific region

What you will learn

At the end of this programme, you will:

• Have a robust understanding of the latest developments in the Singapore Transfer Pricing regime
• Have a good grasp of the various transfer pricing methods and how they apply to all related party transactions (i.e. tangible goods, services, intangible property, and intercompany loans)
• Learn the differences between transfer pricing analysis, and transfer pricing documentation vs. qualifying past transfer pricing documentation
• Be aware of the differences in information required under the Base Erosion and Profit Shifting (“BEPS”) Action Plan 13, and the Transfer Pricing (Documentation) Rules 2018 
• Be mindful of the COVID-19 pandemic’s impact on transfer pricing documentation
• Be abreast of recent transfer pricing developments in the Asia Pacific region 

Expert Speaker

Dr. Sowmya Varadharajan is a Director at IC Advisors Pte Ltd, a firm that helps companies to 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 Intellectual Property (“IP”) valuation.  With the growth in transfer pricing related audits in the Asia Pacific region, Dr. 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.