Top 10 Transfer Pricing Tips for Headquarters (HQs)
Multinational corporations centralise their activities in regional offices to tap into economies of scale and facilitate the efficient running of conglomerates. Unfortunately, it is these efficiencies of amalgamations and re-charges that have received the attention of tax authorities across the world.
With the recent publication of Inland Revenue Authority of Singapore (IRAS)’s guidance, it is time to dissect through what has been
said and understand the business implications for headquarters in Singapore, from the fundamentals to the complexities. Be in top form and
join in the discussion on the implications to the core business processes of businesses and what it takes to get TP and TP documentation
What we cover
Against the challenging international backdrop, the TP environment is no doubt tougher than ever and will only get more intense going forward. It is therefore crucial for MNE groups and Singapore HQs to actively manage their growing TP risks by reviewing their existing TP processes and practices, as well as evaluating the adequacy of their TP documentation.
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
Be prepared for potential transfer pricing audits by tax authorities. Ensure that your transfer pricing documentation is readily available, organized, and easily accessible.
There is an increasing focus on transfer pricing documentation for intragroup loans in Malaysia. Tax authorities expect comprehensive documentation that demonstrates the arm's length.
In Singapore Taxpayers are required to review and update your transfer pricing documentation annually to ensure its accuracy and relevance.