See the Unseen in Intercompany Loans, 31 May 2019

HomeEventsSee the Unseen in Intercompany Loans, 31 May 2019

See The Unseen In Intercompany Loans 31 May 2019

Back by Popular Demand!

Programme Synopsis

A subsidiary borrows from a third party at 1% to 2% and on-lends to its head office at a significantly higher interest rate. This arrangement resulted in its head office claiming a large interest deduction and the subsidiary earning a profit of over $1 billion which was not taxed in any country. Sounds familiar? This was the much talked about Chevron case in Australia which the courts ruled in favour of the Australian Taxation office and resulted in approximately AU$340 million of disallowed deductions.

In this session, Ms Adriana Calderon, Director at Transfer Pricing Solutions Asia, aims to highlight the TP complexities and risks surrounding the intricate nature of intercompany loans and guarantee fees. The session offers participants the opportunity to go beyond fundamentals and grasp what it takes to structure these financial transactions to comply with the Arm’s Length Principle. Adriana will also dive into some of the nuances often missed, but that companies must take note of.

Programme Outline

Be aware of the key considerations in establishing intercompany loans and guarantee fees that will  hold fort amid scrutiny by tax authorities

  •  Explore the practical aspects of the ‘How’s to manage TP risks in these areas
  • Understand the crucial aspects of documentation and frequency of review
  •  Grasp what it takes to ensure an appropriate benchmarking analysis
  • Know the best practices to manage these financial transactions

Join this workshop organised in collaboration with Singapore Institute of Accredited Tax Professionals (SIATP). The session will focus on practical ‘hands-on’ case studies and practical insights on how to do it right.

Register now for this unique workshop. Registration is open until 25 May 2019; special discount applies to members of SiATP, ISCA, SICC SMF and TPS clients. Please open the following link for more information about the event:https://siatp.org.sg/images/PDF/RegForm_310519_IntercoLoans.pdf

For further enquiries about the event, please visit https://www.siatp.org.sg/events.html

Or contact Elaine Sow at 6597 5718 or email to enquiry@siatp.org.sg 



Related Blogs

27 Mar

When the Berry Ratio Works – And When It Becomes a Red Flag

The Berry Ratio may sound light‑hearted, but in transfer pricing it is one of the most debated Profit Level Indicators (PLIs) used under the Transactional Net Margin Method (TNMM). Simple in formula yet demanding in application, the Berry Ratio continues to attract scrutiny from tax authorities worldwide.


READ MORE READ MORE
27 Mar

Transfer Pricing in an Era of Geopolitical Turmoil

Geopolitical volatility has moved from the margins of risk management to the centre of transfer pricing strategy. For multinational groups operating across Australia, Asia and Europe, geopolitical turmoil is no longer a short-term disruption to be explained away in annual documentation.


READ MORE READ MORE
5 Mar

Singapore Budget 2026 - Strategic Implications for Multinational Groups

Singapore’s Budget 2026 sets out a clear strategy to strengthen competitiveness in a changing global environment. The Budget introduces important tax measures while confirming Singapore’s implementation of OECD Pillar Two global minimum tax rules.


READ MORE READ MORE