It is 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, which IRAS has started enforcing.
Additionally, the continued uncertainty of the COVID-19 pandemic has led to further updates to the transfer pricing guidelines (e.g., IRAS issued FAQs in January 2021, and OECD’s guidance in December 2020). It is therefore necessary to prepare the FY 2021 documentation with utmost care and compliance with the transfer pricing guidance. In the hope of providing further guidance to taxpayers on TP documentation, the IRAS has also issued frequently asked questions (“FAQs”) on TP documentation.
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.
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 6th 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 Uncertain Outcomes
- Organisation for Economic Co-operation and Development (“OECD”) transfer pricing developments
- IRAS Guidance
- Summary of transfer pricing regimes in the Asia Pacific region and globally
Dr Sowmya VaradharajanHead of Transfer Pricing
DFDL
Dr. Sowmya Varadharajan is the Head of the transfer pricing practice at DFDL. She 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 20 years of transfer pricing consulting experience.