Transfer Pricing Issues for Trustees, Family Offices and Fund Managers
Over the years, Singapore has continued to develop as a choice location for investment management and wealth management. Fund managers and fund vehicles have been moving ‘onshore’ into Singapore, driven by developments such as the introduction of the Singapore VCC. The number of family offices in Singapore have continued to multiply. The use of a trust (often with a private trust company) have also continued to grow in popularity.
These structures give rise to tax and transfer pricing considerations. Transfer pricing issues have emerged amidst such
developments and heralded in a whole new era where we now see an evolved global tax landscape that is still very much changing. COVID-19
layered upon this, an extra dimension of complexity. The issues of pricing of services and which method to use are just two issues covering
the tip of iceberg on tax and transfer pricing risks management.
What we'll cover
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
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.
Recently the tax authority issued a tax assessment regarding transfer pricing to Rio Tinto’s aluminium division according to which additional taxes in an amount of $86.1 million.
The submission of corporate tax returns dateline in Singapore is around the corner, with most companies having to submit their tax return by 30 November 2022.