Can Your Transfer Pricing Documentation Withstand the Scrutiny of IRAS?

14 May 2020, Thursday

09.00AM - 05.00PM
Hotel Venue to be Advised

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Programme Synopsis

Many Singapore taxpayers are required to prepare transfer pricing documentation for Year of Assessment (“YA”) 2019 in accordance with Section 34D of the Income Tax Act and the Income Tax (Transfer Pricing Documentation) Rules 2018.  Stemming from the need to prepare mandatory transfer pricing documentation, the IRAS has started conducting transfer pricing audits whereby IRAS has explicitly requested for transfer pricing documentation. 
While taxpayers may have prepared transfer pricing documentation, IRAS has also commented on the inadequacy of such documentation in certain cases. Thus, this workshop addresses the pertinent question of whether the transfer pricing documentation prepared will withstand the scrutiny of IRAS. 

The highly-experienced Trainer will share practical experiences from case studies and live audit cases, and observations on the type of scrutiny that IRAS applies to transfer pricing documentation. 

Programme Outline

The transfer pricing landscape
  • Key drivers of transfer pricing
  • Key takeaways from BEPS Action Plans

Components of transfer pricing documentation
  • Understanding transfer pricing documentation compliance in Singapore
  • Preparing transfer pricing documentation
  • What related party transactions exist in your organisation
  • Do your related party transactions demonstrate compliance with the arm’s length standard

Does your transfer pricing documentation withstand the scrutiny of IRAS? 
  • Through a live case study, we will further examine the following:
  • Areas of IRAS scrutiny
  • How can you answer queries raised by IRAS?
  • Defending your transfer pricing documentation

Dispute resolution and prevention strategies
  • What is an APA?  Conditions to rely on an APA
  • What is a MAP? Conditions to rely on an MAP
  • Using APA/ MAPs to your advantage

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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