Dissecting OECD's Guidance on Transfer Pricing Implications
Transfer Pricing (TP) matters has always been laced with complexities. Exacerbated by the unprecedented economic conditions arising from
COVID-19, the application of the arm’s length principle has led to various practical challenges for many industries. To address the issues,
the OECD has recently released a guidance
on the Transfer Pricing Implications of the COVID-19 Pandemic to
enhance tax certainty in TP.
In this upcoming live webinar session, Adriana Calderon, Director of Transfer Pricing Solutions Asia dissects the guidance and navigates through the issues in the application of arm’s length principle relating to COVID-19, from a Singapore perspective. Diving into the interplay between OECD’s guidance and IRAS’ guidance, get to the crux of the matter and understand the practical approaches when performing comparability analysis.
Learn the tips and tricks on how to conduct your transfer pricing analysis for your business and clients under these unique
WEBINAR style. Participants can actively contribute and ask questions during the seminar.
The Singapore Chartered Tax Professionals (SCTP) is consistently working on the issue and has teamed up with Adriana Calderon, Director of Transfer Pricing Solutions Asia. Details of the webinar are provided below.
|DATE||Wednesday 10 February 2021|
|TIME||12:00pm - 1.30pm|
$60 (SCTP/ISCA Member)
$80 (Association Member/Transfer Pricing Solutions Asia's Clients)
|CLOSING DATE||Wednesday 03 February 2021 (unless fully booked prior)|
Adriana Calderon 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
As a TP 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 TP planning projects to implement BEPS’s Action Plan and country-by-country reporting.
*Asia Tax Awards 2017 by International Tax Review
The OECD guidance emphasised that, besides interest rates, all terms and conditions of the financing transactions (including the volume of debt) should be tested against the arm’s length principle.
Are your controlled transactions in line with the transfer pricing legislation? Mistakes in pricing will roll over from year to year. It is crucial to identify mispricing as soon as possible to better manager the transfer pricing risk.
A US multinational company with subsidiaries around the world, including Singapore, recently prepared new US transfer pricing documentation.
The company applies their transfer pricing policies on a global basis. The US tax director instructs the Singapore tax director to use this documentation. Is the US documentation acceptable in Singapore?