Practical Transfer Pricing Masterclass - Calculation, Documentation & Implementation
Date: 17 - 18 November 2016
Time: 9:00am- 5:00pm
Venue: Singapore
Transfer pricing has always been a bit of a buzzword in the international tax arena. With changing regulations and increased scrutiny, companies must re-examine their transfer pricing methods and transactions, undertake proactive transfer pricing planning and diligently maintain contemporaneous transfer pricing documentation.
Jointly organized by Thomson Reuters and Aspect Advisory, this 2 day Practical Transfer Pricing Masterclass will provide an in depth overview of transfer pricing, and give practical and personalized solutions to your business life cycle needs. Our expert facilitator will delve deep into computation of pricing for goods and service under various transfer pricing methods, and related aspects such as documentation and dispute avoidance.
Benefit from In-Depth Exercises on Calculations and Computation of Alternative Transfer Pricing Models!
- Pros and cons of various transfer pricing methods and their application
- Key steps in transfer pricing implementation and monitoring
- Important elements of a realistic functional and risk analysis
- Transfer pricing risk sharing and risk shifting considerations
- Develop contemporaneous transfer pricing documentations
- Transfer pricing compliance obligations and typical non-compliance areas
- Defending techniques against complicated tax investigations
- The “Best “and “Worst” scenario analysis of intragroup transactions
- Benchmarking study of comparable companies and scenarios
Who Should Attend
Professionals involved in transfer pricing or cross-border taxation, from both private and public sectors, including:
- Chief Finance Officer
- Finance Managers, Directors and Controllers
- International and Cross-border Tax
- Accounting and Auditing
- Transfer Pricing
- Corporate Planning and Asset Management
- Tax Legal and Compliance
Practical Transfer Pricing Masterclass - Calculation, Documentation & Implementation
Date: 17 - 18 November 2016
Time: 9:00am- 5:00pm
Venue: Singapore
Download the Practical Transfer Pricing Masterclass brochure HERE
Day 1 – 17 November 2016
Transfer Pricing Legislation and Guidelines
- The arm’s length principles
- IRAS Transfer Pricing Guidelines
- BEPS action plan and OECD guidelines
Benchmarking - Comparability Analysis
- Benchmarking overview
- Safe havens and other materiality thresholds
- Internal vs external comparable data
- Comparability Factors
- Functions
- Assets
- Risks
- Comparability adjustments
Selections of Transfer Pricing methods – How and Why
- Regulations and practice
- Traditional transaction method
- Comparable Uncontrolled Price Method
- Cost Plus Method
- Resale Price Method
- Transactional Profit Methods
- Transactional Net Margin Method
- Transactional Profit Split Method
- Other methods
Exercise: Strength and weaknesses analysis
Exercise: Scenario analysis
Exercise: Computation of Arm’s Length Price under each method above
Step-by-Step Transfer Pricing Documentation
- Key components of transfer pricing documentation
- Masterfile and Local Country file
- Industry, company and functional analysis
- Operational and Legal structure
- Selection of method and implementation
- Other important information to be included
- Transfer pricing documentation template
- Effective drafting of the company overview and industry analysis
- Conducting functional analysis interviews on roles performed by every entity involved in a related party transaction
- Preparing functional analysis write-ups for assets and risks borne by each entity involved in a related party transaction
- Current and future transfer pricing documentation content recommended by the OECD
- Requirement set by Inland Revenue Authority of Singapore
- Updates on Singapore’s recent commitment to implement measures against BEPS and what this means for other countries?
Exercise: How it looks like – Sample of “Perfect” Transfer Pricing Documentation
Day 2 – 18 November 2016
Country-by-Country Reporting
- When is it relevant?
- What is required?
- How to analyse the results and manage risks
Transfer Pricing Implementation – Operational Transfer Pricing
- Implementation of a transfer pricing policy
- Monitoring of transfer pricing practices
- Adjustments
Transfer Pricing Risk management
- Transfer pricing risk management strategy
- Preparation for transfer pricing audit
Exercise: Transfer Pricing Risk Map
Transfer Pricing and Business Restructurings
- Current attention
- Main tax issues that arise when business restructure
Exercise: Restructuring of a Manufacturing Operation
Transfer Pricing Controversy and Dispute Resolution
- Tax dispute avoidance techniques
- Tax audit management practices
- Tax dispute resolution alternatives
Practical Transfer Pricing Masterclass - Calculation, Documentation & Implementation
Date: 17 - 18 November 2016
Time: 9:00am- 5:00pm
Venue: Singapore
Cherie Lehman
Managing Director
Aspect Advisory
Cherie Lehman is the Managing Director of Aspect Advisory, a global transfer pricing solutions provider focused on compliance issues. Cherie has over 15 years of transfer pricing experience in “Big 4” consulting firm environments, as well as leading the global transfer pricing teams of several multi-billion dollar multinationals. She has gained on-the-ground experience in the Asia region, Europe, the US and Australia, and therefore brings a unique, practical perspective to addressing transfer pricing matters.
Cherie’s transfer pricing career began with Arthur Andersen in Australia, and after attaining her Chartered Accountancy in 1996, she transferred to the firm’s Dublin office, and later to the New York office. After several years with KPMG’s transfer pricing team in New York, Cherie left consulting to lead transfer pricing from an in-house perspective. In 2010, after leading the transfer pricing teams of several large multinationals, Cherie founded Aspect Advisory.
Dona Mullick is a Senior Associate with Aspect Advisory, a global transfer pricing solutions provider focused on compliance issues. She obtained an MBA (Finance) in addition to her Bachelor of Business Administration (Finance) and has over five years of practical transfer pricing consulting experience. Dona’s transfer pricing professional career began with Deloitte Touche Tohmatsu in 2010 in India, and after gathering experience in global transfer pricing, she moved to serve local Indian clients with KPMG in India. During the period of serving Indian clients, she worked on variety of compliance and defence assignments, such as documentation, accountant’s report and, preparation of submissions for transfer pricing audit purposes. She joined Aspect Advisory in 2015 and has focused on global compliance services for multinationals throughout Asia, Europe and the North American regions.
Practical Transfer Pricing Masterclass - Calculation, Documentation & Implementation
Date: 17 - 18 November 2016
Time: 9:00am- 5:00pm
Venue: Singapore
Contact:
For more information regarding this event, please contact:
Andy Wong
Phone: (65) 6870 3411
Email: andy.wong@thomsonreuters.com
Practical Transfer Pricing Masterclass - Calculation, Documentation & Implementation
Date: 17 - 18 November 2016
Time: 9:00am- 5:00pm
Venue: Singapore
Pricing (excluding 7% GST charge) :
Early Bird Rate* SGD1,299 (SAVE SGD 200)
Standard Rate SGD1,499
*Early Bird Rate Ends On 21 October 2016.
SIATP Member Rate
Accredited Tax Professionals get to enjoy an additional 10% discount off all rates. Simply quote the code provided by SIATP when you are registering either online or directly through email or phone below.
Group Booking
SAVE ADDITIONAL 20% - Register five participants from your organisation and the 5th person attends for free.
To register, please visit www.regonline.com/transferpricing2016
To register, please visit www.regonline.com/transferpricing2016
For more information regarding this event, please contact:
Andy Wong
Phone: (65) 6870 3411
Email: andy.wong@thomsonreuters.com
