Tax and Transfer Pricing of Intercompany Financing Arrangements

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19 October 2021, Tuesday

02.00 - 05.30PM
60 Cecil Street
ISCA House
Singapore 049709

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Programme Synopsis

Transfer pricing is increasingly an area of focus and seen as an alternate source of tax revenue by tax authorities across the region. Whilst many MNEs have started managing their transfer pricing risks associated with business operations (e.g. intercompany sales and purchases, intercompany services, royalty transactions), intercompany financing arrangements remain an area of tax and transfer pricing risks that is largely left uncovered. 

As part of the BEPS Action Plans, the OECD has introduced a wave of changes to the tax and transfer pricing landscape relevant to intercompany financing arrangements, such as Action 4 and Action 8-10. In particular, the discussion draft on the transfer pricing aspects of financial transactions issued in 2018 is expected to be finalised by early 2020. At the same time, as we have witnessed the increasing maturity of the transfer pricing expertise of the tax authorities in the region, it is likely that intercompany financing arrangements will be scrutinised with higher frequency and to much greater level of details in the near future.

This course is designed to equip the participants with an appreciation of the concepts and principles revolving around intercompany financing transactions as well as the tax and transfer pricing implications. 

  • What are the common types of intercompany financing transactions?  
  • Does my organisation have intercompany financing transactions? And if so, what are the tax and transfer pricing implications around these transactions?  
  • How do we go about pricing intercompany financing transactions on an arm's length basis? What are the factors to be considered? 
  • What are the compliance requirements around intercompany financing transactions? 

Programme Outline

  • Tax and transfer pricing landscape specific to intercompany financing transactions
  • Debt-equity structure and thin capitalisation rules  
  • Common types of intercompany financing transactions 
  • Approach to apply the arm's length principles 
  • Compliance requirements and safe harbour rules 
  • Operational considerations for intercompany financing transactions

About the Presenter(s)/ Trainer(s)

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Mr James Yeo
Transfer Pricing Manager

James is an experienced tax professional with more than seven years of tax and transfer pricing experience and is currently a Transfer Pricing Manager at a leading international tax firm. James has previously worked as a Manager in the EY Singapore transfer pricing practice. During his time at EY, he also worked in the EY London and EY Sydney transfer pricing practices, where he specialized in financial services transfer pricing.

He has advised numerous clients, across many industries, on their intercompany financing arrangements including intercompany loans, guarantees, cash pooling and treasury activities, as well as other complex financial transactions.

James holds a Bachelor of Accountancy from the Singapore Management University and is a Chartered Financial Analyst under the CFA Institute as well as a Chartered Accountant of Singapore under the Institute of Singapore Chartered Accountants.


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