Understanding Transfer Pricing (SB170402)
Date: 19 Sept 2017, Tuesday
Venue: SBF Center, 160 Robinson Road #06-01 SBF Center Singapore 068914
Fee: SBF Member $450.00 | Non-SBF Member $580.00
Transfer pricing (TP) refers to the pricing of goods, assets, services and/or funds when they are transferred within an organisation (a corporation or similar entity) either between divisions of a company, or between companies in the same group.
The choice of the transfer price affects the allocation of the total profit among the parts of the company. This is a major concern for fiscal authorities who worry that multinational entities may set transfer prices on cross-border transactions to reduce taxable profits in their jurisdiction. This has led to the rise of TP regulations and enforcement.
It is important for Singapore companies to be effective in mitigating TP risks to ensure they have robust TP and related documentation in place to serve as an appropriate first level of defence against potential challenges by tax authorities, including Inland Revenue Authority of Singapore (IRAS). IRAS's annual updates on TP Guidelines underscore the authorities' efforts to enforce taxpayers' compliance, for instance:
- IRAS's 2nd edition of TP guidelines in 2015 represent IRAS's clear recognition of the increasing complexity in TP arrangements, and the need for timely and more transparent reporting of TP
- The 3rd edition in 2016 provides enhanced guidance on the Mutual Agreement Procedure, Advance Pricing Arrangement process as well as the application of the cost plus method
- The most current 4th edition serves to align with international tax developments and accepted practices, including those emanating from the Organisation for Economic Cooperation and Development (OECD)'s BEPs.
- Definition of the arm's length principle
- Introduction to OECD guidelines on transfer pricing
- An overview of various transfer pricing methods, their application and case studies
- An overview of Singapore's TP regime, including a detailed discussion on the guidelines (from 2015 to present)
- TP documentations as a first point of defense
- TP updates in selected Asian countries and how they impact Singapore companies in these markets
This one-day workshop is suitable for personnel handling tax matters, compliance and finance in management or senior positions, as well as senior management involved in overseas markets’ operations.
*Programme is accurate at the time of print