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Can mark up be reduced? Can the service be suspended? Benefit test issues if services provided remotely? Can abnormal expenses be excluded?
Can the royalty be suspended? Can the royalty be reduced? Issues with service provider?
Why high risk and why attention? Because a contract is sufficient to originate the transaction. As a result tax authorities are experiencing tax leakages as a result of excessive interest expenses deduction and excessive interest income place in low tax or no tax countries.
What is the impact of COVID-19? Need to modify price of transaction? Need to modify contracts? Need to modify supply chain? Need to perform end of year adjustments? Need to adjust transfer pricing documentation? Need to adjust benchmarking?
The COVID-19 crisis has provoked an unprecedented shift toward working from home (#WFH), and for businesses to implement tools and resources allowing employees to work from home and look after their customers as seamlessly as possible.
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?