EY Transfer Pricing University Singapore 2025

Join us for a two-day program exploring transfer pricing fundamentals, documentation, operational challenges, and recent tax developments.

EY Transfer Pricing (TP) University Singapore aims to equip tax, accounting, legal and finance professionals with the latest developments and trends across the global TP landscape, including:

• Practical aspects of TP compliance (including documentation) incorporating leading practices related to the recently enacted base erosion and profit shifting (BEPS) 2.0 provisions
• Global TP controversy trends in dispute prevention and resolution
• TP operations and governance

Conducted by the EY TP leadership team in Singapore, this premier TP event will focus on demystifying technical TP concepts and associated issues through case studies, interactive panel discussions and breakout sessions. EY professionals will discuss and share practical insights on how to better manage TP obligations in an ever-changing tax environment.

This programme is suitable for tax directors, in-house TP managers, tax executives, finance managers, legal counsel and corporate accountants.

Programme agenda

The two-day programme consists of the following key topics as outlined below.

Day 1 (13 May 2025): TP fundamentals and documentation (case study discussions)

We will focus on the key TP concepts that are the building blocks for every TP professional taking an in-depth look at the components of TP documentation. We will also consider recent developments in the international tax landscape. Topics for Day 1 will include:

• Overview of TP frameworks: Comparison of the Organisation for Economic Co-operation and Development (OECD), United Nations (UN) and Singapore TP Guidelines, and identification of key considerations
• The Seventh Edition Singapore TP Guidelines and its impact
• Case study discussion on TP documentation, including Local and Master File on the following:
  • Basic concept of the arm’s length principle
  • How and why we need to evaluate value chain processes and the functions performed, assets employed, and risks assumed
  • TP methods
  • Components of TP documentation (e.g., three-tier documentation relating to Country-by-Country Reporting, Master File and Local File) and why they are important in Singapore and other jurisdictions
• The basics and latest developments in TP for intercompany financing transactions

Day 2 (14 May 2025): TP controversy, operational TP, TP BEPS 2.0 developments and more

Topics for Day 2 will include:

• Recent trend of TP queries with the Inland Revenue Authority of Singapore (IRAS)

We will be discussing frequently encountered TP issues that are currently trending with the IRAS, including the enforcement TP documentation requirements and related TP-specific penalty regime.

• Operational TP

The objective of operational TP seeks to ensure that your intercompany pricing policies are applied and monitored as originally designed. Several internal operational issues can challenge this objective. Hence, this session covers leading practices governing the effective implementation of TP policies, along with processes for ongoing monitoring to ensure their alignment. We will also outline approaches to making TP adjustments effectively.

• BEPS 2.0 developments

This session will focus on TP-related topics of Pillars One and Two such as Amount A and B, 3.2.3. adjustments and Transitional Country-by-Country Reporting Safe Harbour (TCSH) and their key considerations.

• Operating Model Effectiveness (OME)

OME is viewed as the point of convergence between people, intangible property and the supply chain. While developing the OME for a business requires tax and non-tax inputs, tax is a significant cost of a business and hence an important consideration in the overall operating model. This session intends to provide the tax function with insights into the broader concepts of OME that would assist the tax function to understand and identify OME arrangements for their businesses going forward.

• Different approaches to manage TP risk

This session will focus on risk assessments, International Compliance Assurance Programme (ICAP), Advance Pricing Agreement (APA), Mutual Agreement Procedure (MAP) and TP audit preparedness. We will also discuss on the tax controversy of the future and approach to proactively address the challenges of increased risk of tax controversy by consolidating multiple leading practices observed into a single methodology. We would also assist taxpayers in fostering improvement across all phases of the tax controversy lifecycle – tax risk assessment, tax risk management and tax audit management.

• TP frameworks: Key Asia-Pacific jurisdictions

We will provide jurisdictional specific overviews of the TP regulatory frameworks for key Asia-Pacific markets with a focus on recent changes and key compliance deadlines.

• Panel discussion session with participants

Our culminating panel discussion will share how companies globally are dealing with the issues that we have presented over the two-day course, outlining their risk mitigation approaches, potential opportunities and how the need for integration of different departments within the finance function are required to manage TP effectively.

Programme Details

Dates: Tuesday, 13 May 2025 (Module 1) and Wednesday, 14 May 2025 (Module 2)

Time: 9:00 a.m. to 5:30 p.m. (Registration starts from 8:30 a.m.)

Venue: Fairmont Singapore & Swissôtel The Stamford, 2 Stamford Road, Singapore 178882

Presenters

• Luis Coronado , EY Global Tax Controversy Leader
• Stephen Lam , Partner, International Tax and Transaction Services - Transfer Pricing, Ernst & Young Solutions LLP
• Jonathan Belec, Partner, International Tax and Transaction Services - Transfer Pricing, Ernst & Young Solutions LLP
• Paul Griffiths, Partner, International Tax and Transaction Services - Transfer Pricing, Ernst & Young Solutions LLP
• Rachel Kok, Partner, International Tax and Transaction Services - Transfer Pricing, Ernst & Young Solutions LLP
• Rajesh Bheemanee , Partner, Financial Services Transfer Pricing, Ernst & Young Solutions LLP
• Sharon Tan, Partner, International Tax and Transaction Services - Transfer Pricing, Ernst & Young Solutions LLP
• Vivienne Ong, Partner, International Tax and Transaction Services - Transfer Pricing, Ernst & Young Solutions LLP

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