EN | CN
9 April 2026, Thursday, 10.30am –12:00p.m.
With the release of the updated Transfer Pricing Guidelines at the end of last year, 2026 sees tax professionals now turning their
attention to what these regulatory updates mean in practice. Ahead of SCTP’s in-person session with IRAS to break down the key changes
after two years, this webinar that aims to help you better understand the practical implications and applications of the TPG cannot be
missed!
The session will focus on the practicalities of what the changes imply, from new documentation requirements to the interplay between
audit and taxation. Come join in the discussion in the areas of permanent establishment matters, related party financing and an explanation
of the various changes in the FAQs, amongst various other matters.
Join Accredited Tax Advisor (Income Tax) Ms Adriana Calderon, Director, Asia and Malaysia at Transfer Pricing Solutions Asia for a
practical discussion on how to operationalise the changes, know what the Simplified and Streamlined Approach (SSA) is, identify key
action points and prepare your organisation or clients for the new TP landscape ahead.
Ms Adriana Calderon
Director, Asia and Malaysia - Transfer Pricing Solutions Asia
Accredited Tax Advisor (Income Tax)
Adriana is the co-founder of Transfer Pricing Solutions Asia. She has extensive international experience with Big Four and mid-tier firms
advising multinational companies in the areas of corporate and international taxation across South America, the US, Australia and the Asia
Pacific Region. As a Transfer Pricing practitioner, Adriana has advised companies in the Asia Pacific Region across various industries and
in a wide range of projects associated with planning, compliance and dispute resolutions with tax authorities. She has also participated in
specialised projects involving pricing of financial transactions, business restructures and negotiation of APAs. Most recently, she has
participated in transfer pricing planning projects to implement BEPS’s Action Plan and country-by-country reporting.
Adriana also enjoys teaching and is a regular speaker and facilitator of Transfer Pricing seminars and workshops. She is a transfer pricing trainer for the Institute of Singapore Chartered Accountants and Singapore Institute of Accredited Tax Professionals. Adriana has also facilitated training sessions for CFOs, tax teams of large companies and consultancies, and tax executives at the Australian Taxation Office. In addition, Adriana is also SCTP’s representative for the TP Roundtables organised by the tax authority.
Adriana Calderon, Managing Partner - Asia & Malaysia at Transfer Pricing Solutions, shares insights from the IFA APAC Conference in Tokyo, highlighting key trends in transfer pricing across Asia. She explores regional differences in approach, increasing regulatory complexity, and rising audit activity, while reflecting on the importance of global networks in fostering collaboration and shaping the future of international tax.
Malaysia’s transfer pricing framework continues to evolve, with the Inland Revenue Board of Malaysia applying increasing scrutiny to how multinational groups price, document and defend related‑party transactions. For businesses operating in Malaysia, transfer pricing has become a core tax risk area rather than a routine compliance exercise.
Across Asia, transfer pricing audits are becoming more frequent, more detailed and more analytically driven. Tax authorities are no longer limiting their reviews to whether documentation exists. Instead, they are interrogating whether transfer pricing outcomes genuinely align with commercial reality, operational substance and financial results over time.
