Responding to the Evolving Transfer Pricing Landscape

Complying with TP rules in the APAC region, the Digital Economy and Commodity Trading
12 December 2019, Thursday

09.00AM - 05.00PM
Hotel Venue to be Advised

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Programme Synopsis

2019 is the first year in which most markets in the Asia Pacific region will implement BEPS Action Plan 13: Transfer Pricing Documentation, consistently. Therefore, it is critical to have a robust understanding of each region’s TP documentation framework, which are classified as Developed, Less Developed and Developing.

Additionally, be updated on the two recent changes in the transfer pricing landscape likely to impact various companies in Singapore. Firstly, the latest issuance of transfer pricing guidelines for commodity trading entities by IRAS; and secondly the transfer pricing rules and legislation for the Digital economy. The trainer will provide a detailed understanding of how transfer pricing principles should be applied to commodity trading entities and the Digital Economy

Through the use of case examples, this seminar aims to ensure that taxpayers achieve a state of readiness to manage their transfer pricing compliance and avoid unnecessary penalties in the evolving TP landscape.

PLUS! Bonus Value-Added:
Obtain a cheat sheet providing a succinct summary of the transfer pricing regime in key APAC markets.  Taxpayers can rely on this to develop a robust transfer pricing action plan. 

Programme Outline

Obligations of Taxpayers under Action Plan 13 and Managing Transfer Pricing Compliance
  • Overview of Action Plan 13 and implementation guidelines provided to taxpayers
  • How “consistent” is the implementation of Action Plan 13? 
  • Find out what information on related party transactions is typically collected and learn how this impacts your transfer pricing documentation and analysis
  • Pitfalls of transfer pricing compliance under Action Plan 13
  • How to manage transfer pricing compliance in a cost effective manner when having operations across the Asia Pacific region?

Regional Transfer Pricing Framework – Developed, Less Developed and Developing
  • Cheat sheet for each of the market, outlining the specific nuances in the implementation of the transfer pricing legislation
  • Examining what does varying transfer pricing framework mean for companies that have operations across the region

Latest Update on Transfer Pricing Guidelines for  Commodity Trading Entities (1/4 coverage)
  • The commodity trading value chain
  • Functional analysis
  • Transfer pricing analysis of commodity trading entities

Proposed Transfer Pricing Regime for Digital Economy (1/4 coverage)
  • Proposed 3 pillar analysis
  • Impact on transfer pricing methodology

About the Presenter(s)/ Trainer(s)

Dr Sowmya Varadharajan
IC Advisors Pte Ltd

Dr Sowmya Varadharajan is a Director at an international consultancy firm that specialises in transfer pricing and tax valuation. She is an economist with a PhD in Economics from Cornell University.

Sowmya started her career in transfer pricing at PwC. Having worked as part of the transfer pricing practices in both the US and Singapore, Sowmya has extensive experience in preparing transfer pricing documentation and defending such documentation before tax authorities either as part of the transfer pricing audit process, or through the Advance Pricing Agreement (APA) process.

Sowmya has advised on a wide variety of issues, ranging from simple transfer of goods between related enterprises, to more complicated arrangements of buy-in/cost share/cost contribution and intellectual property transfers. In terms of industry experience, Sowmya has extensive experience in the high-tech/semiconductor as well as pharmaceuticals/biomedical industries.

In addition to her transfer pricing expertise, Sowmya also has considerable experience on tax/intellectual property valuation projects.

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