Tax and Transfer Pricing of Intercompany Financing Arrangements (Live Webinar)

Date:

20 June 2024, Thursday

Time:

09.00AM - 12.30PM

Venue:

Online Classroom in or outside of Singapore

Details/ Promotion:

Please click here for more details and here to register.

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Contact:

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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.

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

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

About the Presenter(s)/ Trainer(s)

Mr James Yeo
Tax Manager

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.

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