Course Detail()
Not Available

UTAP Funding

3.50 CPE Hours (Category 1, Category 2, Category 3, Category 4, Others)
Live Webinar

Programme Objective

Transfer pricing is increasingly an area of focus and seen as an alternate source of tax revenue by tax authorities across the region. Whilst many MNEs have started managing their transfer pricing risks associated with business operations (e.g. intercompany sales and purchases, intercompany services, royalty transactions), intercompany financing arrangements remain an area of tax and transfer pricing risks that is largely left uncovered. 

As part of the BEPS Action Plans, the OECD has introduced a wave of changes to the tax and transfer pricing landscape relevant to intercompany financing arrangements, such as Action 4 and Action 8-10. More recently, the OECD has introduced Chapter X of the OECD Transfer Pricing Guidelines, specifically covering intercompany financial transactions. With the increasing maturity of the transfer pricing expertise of the tax authorities in the region, coupled with the increasing pressure to address declining tax revenue and increased fiscal spending during COVID-19, it is expected that intercompany financing arrangements will be scrutinised with greater frequency and intensity going forward.

This course is designed to equip the participants with an appreciation of the concepts and principles revolving around intercompany financing transactions as well as the tax and transfer pricing implications. 

  • What are the common types of intercompany financing transactions? 
  • What are the tax and transfer pricing considerations around these transactions? 
  • How do we go about pricing intercompany financing transactions on an arm's length basis? What are the factors to be considered from an OECD and Singapore transfer pricing perspective?
  • What are the compliance requirements around intercompany financing transactions? 

Programme Outline

  • Tax and transfer pricing landscape specific to intercompany financing transactions
  • Debt-equity structure and thin capitalisation rules 
  • Common types of intercompany financing transactions
  • Approach to apply the arm's length principles
  • Compliance requirements and safe harbour rules
  • Operational considerations for intercompany financing transactions

Training Methodology

Lecture / seminar style with interactive participation and walk-through of practical case examples. Participants are encouraged to actively contribute and share their perspectives from their experiences and organizations.

Closing Date for Registration

1 week before programme or until full enrolment.

Intended For

Foundation to Intermediate course for financial controllers, accountants, auditors, tax and finance professionals who are involved in all aspects of intercompany financing transactions or treasury function.

Schedule & Fees

Testimonial


The programme covers an area of taxation that is still evolving and imparts valuable knowledge that could be helpful in ensuring tax professionals in the commercial sector comply with existing regulations.

Past Participant


The speaker is knowledgeable and the content is good. I will definitely recommend the course.

Past Participant


This session not only helped me gain more insight on latest TP update, but the examples and case studies also help me understand the application of these guidelines better

Past Participant


This course is relevant for our audit & tax challenges encountered in all industry and an understanding on the compliances & TP guidelines are fundamental for our profession.

Past Participant

Funding

1] NTUC Union Training Assistance Programme (UTAP)

NTUC members enjoy 50% *unfunded course fee support for up to $250 each year when you sign up for courses supported under UTAP. NTUC members aged 40 and above can enjoy higher funding support up to $500 per individual each year, capped at 50% of unfunded course fees, for courses attended between 1 July 2020 to 31 December 2025.

*Unfunded course fee refers to the balance course fee payable after applicable government subsidies. This excludes material fees, registration fees, misc. fees etc.

This course is approved for UTAP support for intakes conducted between 08 February 2024 – 31 March 2025.

As UTAP is given on calendar year basis, and calculated based on year of training taken, it cannot be accumulated.

  • Maintained paid-up NTUC membership before course, throughout course duration and at the point of claim and;
  • Course by training provider must be supported under UTAP and training must commence within the supported period and;
  • Unfunded course fee must not be fully sponsored by company or other types of funding
  • Unfunded course fee must be S$20.00 and above, and;
  • Member must achieve a minimum of 75% attendance for each application and sat for all prescribed examination(s), if any and;
  • UTAP application must be made within 6 months after course ends.

For more information on UTAP Funding and to submit for UTAP claims, please visit https://www.ntuc.org.sg/uportal/programmes/union-training-assistance-programme. Terms and conditions apply.

Programme Facilitator(s)

Programme Objective

Transfer pricing is increasingly an area of focus and seen as an alternate source of tax revenue by tax authorities across the region. Whilst many MNEs have started managing their transfer pricing risks associated with business operations (e.g. intercompany sales and purchases, intercompany services, royalty transactions), intercompany financing arrangements remain an area of tax and transfer pricing risks that is largely left uncovered. 

As part of the BEPS Action Plans, the OECD has introduced a wave of changes to the tax and transfer pricing landscape relevant to intercompany financing arrangements, such as Action 4 and Action 8-10. More recently, the OECD has introduced Chapter X of the OECD Transfer Pricing Guidelines, specifically covering intercompany financial transactions. With the increasing maturity of the transfer pricing expertise of the tax authorities in the region, coupled with the increasing pressure to address declining tax revenue and increased fiscal spending during COVID-19, it is expected that intercompany financing arrangements will be scrutinised with greater frequency and intensity going forward.

This course is designed to equip the participants with an appreciation of the concepts and principles revolving around intercompany financing transactions as well as the tax and transfer pricing implications. 

  • What are the common types of intercompany financing transactions? 
  • What are the tax and transfer pricing considerations around these transactions? 
  • How do we go about pricing intercompany financing transactions on an arm's length basis? What are the factors to be considered from an OECD and Singapore transfer pricing perspective?
  • What are the compliance requirements around intercompany financing transactions? 

Programme Outline

  • Tax and transfer pricing landscape specific to intercompany financing transactions
  • Debt-equity structure and thin capitalisation rules 
  • Common types of intercompany financing transactions
  • Approach to apply the arm's length principles
  • Compliance requirements and safe harbour rules
  • Operational considerations for intercompany financing transactions

Training Methodology

Lecture / seminar style with interactive participation and walk-through of practical case examples. Participants are encouraged to actively contribute and share their perspectives from their experiences and organizations.

Closing Date for Registration

1 week before programme or until full enrolment.

Intended For

Foundation to Intermediate course for financial controllers, accountants, auditors, tax and finance professionals who are involved in all aspects of intercompany financing transactions or treasury function.

Programme Facilitator(s)


No course instances or course instance sessions available.