Transfer Pricing for SMEs

01 April 2020, Wednesday

09.00AM - 12.30PM
60 Cecil Street, ISCA House, Singapore 049709

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Programme Synopsis

Due to increased tax authority scrutiny around the world, transfer pricing has become one of the riskiest areas for multinational corporations from both a compliance and tax planning perspective. Amazon, AOL, Adobe, Hewlett-Packard, Microsoft, and other multinationals have all made headlines in recent years because of transfer-pricing disputes over potential adjustments to income ranging from tens of millions to upward of a billion dollars. However, if you think transfer pricing affects only big companies, think again. Size is immaterial. The only condition that triggers transfer pricing is the existence of multiple facilities in more than one taxing jurisdiction.

Unfortunately for the small guy, whilst the Base Erosion Profit Shifting (“BEPS”) project refers to Small and Mid-size Entities (SMEs) and Multi-National Entities (MNEs) it seldom differentiates the rules between them. Despite the fact that cross-border structures typically employed by SMEs do not have the same characteristics of the ones by large MNEs, the same BEPS tax rules and scrutiny apply for both SMEs and MNEs. As Singapore adopts the lengthy and complex BEPS recommendations into our tax legislation, the impact of many changes being suggested will be felt in increased governance, compliance costs and in some cases taxing authority audits.

This seminar discusses how SMEs can best manage the new transfer pricing landscape on a smarter basis. Singapore SMEs need to play their cards right and ensure that their global tax footprint is commensurate with group operations and value creation across tax jurisdictions. Design will be important and any planning will need improved focus on substance.

Programme Outline

​​​​​- The transfer pricing life cycle and what it means for SMEs
- Transfer pricing topics of interest for SMEs (Case Studies)
  • Best practices for charging management fees to related parties
  • Managing intellectual property
- A practical toolkit for SMEs to:
  • Build your own transfer pricing landscape
  • Assess your transfer pricing risk
  • Plan and prioritize documentation efforts to meeting compliance deadlines whilst managing costs
  • Understand “safe harbor” and other exemptions (from Singapore transfer pricing documentations) available for SMEs

About the Presenter(s)/ Trainer(s)

Ms Elis Tan
Transfer Pricing Executive Director

Elis has more than 15 years of tax transfer pricing experience. Currently, she is the Executive Director heading the transfer pricing team at BDO Tax Advisory Pte Ltd.

Elis started her career with a Big 4 firm where she provided transfer pricing services to a diverse portfolio of clients in the industrial, consumer manufacturing, retail, pharmaceutical, oil & gas, banking, and asset management sectors. From 2006 to 2009, Elis was based in Shanghai, helping China-based multinational clients manage their transfer pricing risks. Elis also spent more than 3 years as Head of Transfer Pricing, Asia-Pacific region, at one of the largest multinational insurance groups based in the United States.

Elis has extensive experience in handling all aspects of transfer pricing including documentation compliance, planning and controversy management. Her work includes transfer pricing risk assessment, audit defence, tax effective value chain management in relation to the use of regional principals, application and negotiation of tax incentives and working with customs and tax colleagues for overall tax optimisation. She also has experience negotiating advanced pricing arrangements (APAs) with tax authorities in Singapore, China and Japan.

  • Accredited Tax Practitioner (Income Tax) of Singapore Institute of Accredited Tax Professional Limited (SIATP)
  • Member (Non-Practising) of the Institute of Singapore Chartered Accountants (ISCA)
  • Graduated from the Singapore Nanyang Technological University with a Bachelor of Accountancy (Honours) Degree

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