UTAP Funding
Programme ObjectiveTransfer 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 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.
Tax and transfer pricing landscape specific to intercompany financing transactionsDebt-equity structure and thin capitalisation rules Common types of intercompany financing transactionsApproach to apply the arm's length principlesCompliance requirements and safe harbour rulesOperational considerations for intercompany financing transactionsTraining MethodologyLecture / 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 Registration1 week before programme or until full enrolment.
Training MethodologyLecture / 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 Registration1 week before programme or until full enrolment.
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.
Others = 3.50 Hours
20 Jun 2024 (9:00 AM - 12:30 PM)
For Members: $ 183.12 For Non-Members: $ 218.00
15 Nov 2024 (9:00 AM - 12:30 PM)
For Members: $ 220.18 For Non-Members: $ 261.60
Past Participant
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.
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.
James Yeo
James is an experienced tax professional with more than ten years of tax and transfer pricing experience and is currently a Tax Manager at a NYSE-listed, Singapore headquartered internet company. Previously, James was a Transfer Pricing Manager at WTS Taxise, a Singapore-based law firm specializing in international tax, international trade and transfer pricing. James has also spent a number of years in the EY Singapore transfer pricing practice. During his time with EY, he has also worked in the EY London and EY Sydney transfer pricing practices, where he specialized in financial services transfer pricing.
He has advised numerous clients, across many industries, on their intercompany financing arrangements including intercompany loans, guarantees, cash pooling, hedging and treasury activities, as well as other complex financial transactions.
James holds a Bachelor of Accountancy from the Singapore Management University and is a Chartered Financial Analyst under the CFA Institute as well as a Chartered Accountant of Singapore under the Institute of Singapore Chartered Accountants.
Online Classroom in or outside ofSingapore
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29 Apr 2024 - 29 Apr 2024