Transfer Pricing University 2022

Programme agenda

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

Module 1: Basic

Transfer pricing fundamentals and documentation

Key TP concepts that are essential for a basic understanding of TP, recent developments in the international tax landscape and preparation of factual and technical sections of TP documentation will be discussed in Module 1.

Topics for Module 1 will include:

• TP frameworks: Organisation for Economic Co-operation and Development (OECD), United Nations, key Asia-Pacific countries and Singapore
• 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) and why they are important in Singapore and other jurisdictions
• The basics and latest developments in TP for intercompany financing transactions

Module 2: Advance

Country-by-Country Reporting

This session will focus on Action 13 Country-by-Country Reporting (CbCR), as well as the implications for taxpayers in Singapore. The session will also present the ways in which the CbCR information may be interpreted by tax authorities as well as typical areas of concern based on EY's experience, and highlight leading practices in terms of being CbCR-ready and practical considerations in data collation and management.

BEPS 2.0

On 12 October 2020, the OECD released a series of major documents in connection with the BEPS 2.0 project on addressing the tax challenges arising from the digitalisation of the economy. These documents included Blueprints on Pillar One (on new nexus and profit allocation rules) and Pillar Two (on new minimum tax rules), which stakeholder comments were requested through a public consultation. In December 2021, the OECD released the Model Rules on the Pillar Two Global Minimum Tax, as approved by the OECD/G20 Inclusive Framework on BEPS. This session will provide an overview of the two pillars and the latest developments on BEPS 2.0, and discuss what the global tax changes mean to taxpayers and Singapore.

Operational TP

This session will explain the nature and importance of operational TP, which covers the challenges and practical aspects associated with ensuring that your intercompany transactions are applied and monitored appropriately. The session will also cover leading practices associated with appropriate application of a TP set-up for intercompany transactions, leading practices for ongoing monitoring of the TP practices, and go through examples on true-up adjustments and considerations.

Looking ahead: tax controversy department of the future

The programme will close with a high level discussion on how to build the tax controversy department of the future. This is an approach to proactively address the challenge of increased risk of tax controversy by consolidating multiple leading practices observed into a single methodology, and to assist taxpayers in fostering improvement across all phases of the tax controversy lifecycle – tax risk assessment, tax risk management and tax audit management.