As businesses expand their digital footprint, there has been a recent growth in intercompany services and royalty transactions. The COVID-19 pandemic has also resulted in an increase in intercompany financing arrangements as multinational corporations decided to source funding internally rather than increase the cost of borrowing externally.
In light of these changes, the Inland Revenue Authority of Singapore (“IRAS”) and the OECD have updated their transfer pricing guidelines to provide additional guidance on how these related party transactions should be analysed from a transfer pricing perspective.
This workshop is designed specifically to give Finance and Tax Professionals a practical understanding of how to manage cross-border transfer pricing risks in relation to intercompany services, financing, and royalty transactions.
The recent guidance from IRAS as discussed in the Singapore Transfer Pricing Guidelines, 6th edition, as well as the OECD will also be discussed.
Examining the Importance of Cross-Border Intercompany Services, Loans and Royalties
Transfer Pricing Considerations for Cross-Border Intercompany Services
Understanding Cross-Border Intercompany Royalties
Understanding Intercompany Financing Transactions
A Recap on Key Takeaways: Transfer Pricing Implications on Cross-Border Intercompany Services, Financing and Royalties
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 more than 16 years of transfer pricing consulting experience.