Top 8 Reactions To OECD'S Latest Transfer Pricing Guidelines
The Organisation for Economic Cooperation and Development (OECD) latest transfer pricing (TP) guidelines published on 20 January certainly created a buzz in the tax world. Comprising over 600 pages, its wide-ranging coverage will require resources to dissect and digest. Join in this 2-part series for an efficient update zooming in on key pointers in OECD’s guide, followed by an understanding of how this guide compares with Singapore’s own TP e-Tax guide. Be in the know!
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. In Asia Pacific, Adriana specialises in the area of TP, building on her Latin American experience as a lawyer in commercial and tax legislation.
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.
Adriana also enjoys teaching and has been involved in various TP seminars and workshops. Besides being a TP trainer at the Institute of Singapore Chartered Accountants, Adriana has also facilitated in training sessions for CFOs, tax teams of large companies and consultancies, and tax executives at the Australian Taxation Office.
*Asia Tax Awards 2017 by International Tax Review
Indicative margins were introduced by the Inland Revenue Authority of Singapore (“IRAS”) in 2017 to be used in related party loans. What is the impact for Singapore Taxpayers?
Whether you need to prepare a benchmarking study when entering into a related party transaction depends on the country's transfer pricing regulations and the specifics of the transaction.
This e-Tax Guide is relevant to any Singapore MNE group with international operations and annual group revenue of at least S$1,125 million.