Get to the crux of TP issues in Commodity Marketing and Trading activities!
Due to the depth of trading market and the close proximity to key markets, Singapore has been the preferred
location for commodity marketing/ trading activities. Coupled with the extensive network of buyers and sellers, these activities are not
only growing in scale but are also increasing in complexity.
When such activities are carried out with their related parties, how do tax professionals ensure compliance with the arm’s length principle and the relevant Transfer Pricing (TP) documentations? Beyond that, as TP developments continue to evolve, what are the risks and pertinent issues that you, as well as your clients, should take note and be aware of from the perspective of a commodity marketing/trading entity?
This upcoming session facilitated by Ms Adriana Calderon, Director at Transfer Pricing Solutions Asia will take you through the do’s and don’ts to watch out for and the practical insights in this complex TP area using various case studies. Come learn about the intricacies and understand what is involved in the preparation of TP documentation in the aspect of commodity marketing and trading activities.
Register now for this unique workshop. Registration is open until 13 March 2020; special discount applies to members of SiATP, ISCA, SICC SMF and TPS clients.
For further enquiries about the event, please visit https://www.siatp.org.sg/EventDetail.aspx?id=237
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 Pacific Region.
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
Singapore is often a preferred location for setting up headquarters as the door to conduct business in Asia. The IRAS has released its views on how Singapore HQ's should plan and implement their transfer pricing framework. Want to know more? Read our article with our views on IRAS TP Guidelines for Singapore HQs.
The Malaysian Finance Bill 2020 incorporates transfer pricing-related changes to the current Income Tax Act, 1967 (“ITA”). The changes permit significantly greater authority to the Malaysia Inland Revenue Board (“MIRB”) and re-emphasises the importance of transfer pricing compliance, with effect from 1 January 2021.
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.