Tax and Transfer Pricing of Intercompany Financing Arrangements (Live Webinar)
Date:
02 November 2026, Monday
Venue:
Online Classroom in or outside of Singapore
Details/ Promotion:
Please click
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Contact:
Please refer to organiser’s webpage here.
Programme Synopsis
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 by ISCA 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.
Programme Outline
A Highlight of Key Areas:- 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
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