Navigating the Maze: Strategies for Resolving Transfer Pricing Disputes

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Navigating the Maze: Strategies for Resolving Transfer Pricing Disputes.

The world of transfer pricing can be a complex and sometimes treacherous one, especially when disputes arise. As a Multi-National Company (“MNC”) operating in Singapore, Malaysia, or the wider Asia region, you’re no stranger to the labyrinth of regulations and potential pitfalls. One wrong turn, and you could find yourself embroiled in a costly and reputation-damaging transfer pricing dispute.

But fear not, fellow maze explorers! Join us for a sneak peek into the strategies that can equip you to navigate these challenges with confidence.

Unmasking the Beasts in the Maze

The Tangled Web of Pricing Errors: Did you know a simple misstep in calculating the cost base for intragroup services, or a mismatch within your intercompany agreements, can trigger a dispute? Unmask these hidden dangers and learn to price with precision.
The Documentation Dilemma: Incomplete or outdated transfer pricing documentation can be your worst enemy. Discover the secrets to crafting robust documentation that stands up to scrutiny and shields you from potential attacks.
The Regulatory Quicksand: The landscape of transfer pricing regulations is constantly evolving, and keeping pace can be dizzying. We'll equip you with the latest insights on regional and global trends, ensuring you stay ahead of the curve.

Forging Your Path to Resolution

Early Intervention – The Key to Avoiding Conflict: Learn the art of proactive problem-solving. We'll reveal strategies for identifying potential disputes early and engaging in constructive dialogue with tax authorities to prevent them from escalating.
The Power of Advanced Pricing Agreements (“APAs”): Discover how APAs can be your compass, providing certainty and minimizing audit risks. We'll delve into the practicalities of securing an APA and navigating the negotiation process.
Mutual Agreement Procedures (“MAPs”): When Negotiation Fails: Even when disputes arise, all hope is not lost. We'll explore the intricacies of MAPs as a valuable tool for resolving cross-border transfer pricing conflicts.

Beyond the Maze: Building Resilience

Developing a Robust Transfer Pricing Framework: Learn the secrets to building a framework that not only adheres to regulations but also reflects your unique business realities. We'll share best practices for documentation, risk assessment, and ongoing monitoring.
Empowering Your Team: Knowledge is power, and in the realm of transfer pricing, a well-informed team is your greatest asset. We'll equip you with the tools and training to empower your staff to confidently navigate transfer pricing challenges.
Audit-Readiness: Preparing for the Inevitable: Don't wait for an audit to come knocking. We'll provide practical tips for strengthening your internal controls, streamlining record-keeping, and ensuring your processes are audit-proof.

Talk to our transfer pricing experts.

Our purpose is to make a difference in the service we provide to our clients by being practical, proactive and cost-effective.

25 Mar

Introduction to Transfer Pricing: 52nd Run

The Introduction to Transfer Pricing workshop is designed to arm participants with an understanding of transfer pricing as well as transfer pricing compliance in various Asia Pacific countries. In addition, a discussion of the various transfer pricing methods and their application, as well as the transfer pricing regime in Singapore will be presented.

Registration for Multinational Enterprise Top-up Tax and Domestic Top-up Tax

Starting May 2026, in-scope multinational enterprise (MNE) groups must register for Singapore’s Multinational Enterprise Top-up Tax (MTT), Domestic Top-up Tax (DTT), and the GloBE Information Return (GIR) under the Multinational Enterprise (Minimum Tax) Act 2024.

2026 IRAS Indicative Margins for Related Party Loans

For the year 2026, IRAS has updated its indicative margin, reaffirming its support for simplified, arm’s length transfer pricing practices.