• Refresher covering key principles of preparing documentation
• The importance of functional analysis and characterisation of transactions
• Common mistakes in the preparation of functional analyses and how to get it right
• Principles and rationale for economic and benchmarking analysis
• Alternatives available for testing related party transactions, are databases the only option?
• Are searches and benchmarking analysis always required? How to identify exceptions?
• Hands on case study using databases
• How to test:
• service transactions
• buy/sell transactions
• intercompany loans
• Do and don’t’s when testing related party transactions
• How to identify ‘blind spots’ and key tips to minimise risks related to benchmarking analysis
• How to implement the results of benchmarking analysis
• Examples of how the implementation can go wrong.
Ms Adriana CalderonDirector
Transfer Pricing Solutions Asia
Asia Best Newcomer Firm of the Year 2017*
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. In Asia Pacific, Adriana has specialised in the area of TP, building on her Latin American experience as a lawyer in commercial and tax legislation.
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.
Adriana also enjoys teaching and has been involved in various TP seminars and workshops. Besides being a TP trainer at the Institute of Singapore Chartered Accountants, Adriana has also facilitated in training sessions for CFOs, tax teams of large companies and consultancies, and tax executives at the Australian Taxation Office.
*Asia Tax Awards 2017 by International Tax Review