In light of the Inland Revenue Authority of Singapore’s (IRAS) recent success in tax recovery through Transfer Pricing Audits (TPA), businesses must navigate an increasingly stringent tax environment. This workshop by CLA Events provides a practical understanding of transfer pricing principles, compliance strategies, and risk management to help organizations mitigate exposure to tax disputes. Through real world case studies and expert insights, participants will gain actionable knowledge on implementing robust transfer pricing policies, conducting comparability analyses, and handling tax authority inquiries. The session will also explore Singapore’s regulatory approach, the arm’s length principle, and the latest market challenges in transfer pricing.
A Highlight of Key Areas:
Fundamentals of Transfer Pricing & Why It Matters
- Definition and key principles
- IRAS’s increasing focus on TP audits and enforcement trends
- Consequences of non-compliance: Penalties, disputes, and double taxation
Transfer Pricing Methods: Selection & Application
- Traditional vs. transactional profit methods (CUP, Resale Minus, Cost Plus, TNMM, Profit Split)
- Which method works best for different transactions (tangible goods, services, intangibles, financing)
Arms Length Principle & Comparability Analysis
- Understanding the arm’s length standard in Singapore and globally
- How to conduct a defensible comparability analysis
- Common pitfalls and challenges in benchmarking
Managing Transfer Pricing Risks in 2025
- Latest IRAS & ASEAN TP Developments
- Increased scrutiny on services, intangibles, supply chain restructuring, and financial transactions - Essential Documentation & Compliance
- Beyond intercompany agreements: Master File, Local File, and Country-by Country Reporting (CbCR)
- Best Practices for maintaining contemporaneous documentation - Advance Pricing Agreement (APAs) & Dispute Resolution
- When to consider unilateral, bilateral, or multilateral APAs
- Managing MAP (Mutual Agreement Procedure) cases and tax authority disputes
Handling TP Audits & Tax Authority Challenges
- How IRAS conducts TP audits: Red flags and Risk areas
- Case studies on recent TP disputes in Singapore and ASEAN
- Strategies for defending TP policies and negotiating with Tax authorities
Emerging Issues & Future of Transfer Pricing
- Impact of OECD’s BEPS 2.0 Pillar One and Two
- Impact of Tariffs on Global Trade