Transfer Pricing Documentation Masterclass: Preparing Transfer Pricing Analysis for the Pandemic Year

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21 October 2021, Thursday

09.00AM - 05.00PM
Hotel Venue to be Advised

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Programme Synopsis

It is now mandatory for businesses to prepare the Transfer Pricing (TP) documentation, if certain conditions are met. Non-compliance with the TP Documentation Rules will effect a costly penalty of $10,000 per offence, to the taxpayer.

Additionally, the recent onslaught of the COVID-19 pandemic has led to further updates to the transfer pricing guidelines (e.g., IRAS issued FAQs in September 2020, and OECD’s guidance in December 2020).  It is therefore necessary to prepare the FY 2020 documentation with utmost care and compliance with the transfer pricing guidance. 

This Masterclass Programme is specifically designed to give Finance and Tax Professionals a practical and in-depth understanding of the intricacies involved in preparing and defending transfer pricing documentation.

Programme Outline



  • Overview of related party transactions entered into by MNCs
  • Key triggers of related party transactions
  • Singapore Income Tax Act transfer pricing provisions:  Section 34D – Section 34F

The Singapore Transfer Pricing Regime

  • Detailed understanding of the 5th edition of the Singapore Transfer Pricing Guidelines
  • Income Tax (Transfer Pricing Documentation) Rules 2018
  • Recent developments
  • Case studies

Economic Analysis

  • Analysing related party transactions
  • Determining the appropriate transfer pricing method:  Requirements and process
  • Benchmarking process
  • Bridging the gap between documentation and implementation
  • Implementation methodologies/price settings/ management measures
  • Risk allocation and implementation
  • Transfer pricing adjustments

Defending the Pandemic Year Outcomes

  • Organisation for Economic Co-operation and Development (“OECD”) transfer pricing developments
  • IRAS Guidance
  • Summary of transfer pricing regimes in the Asia Pacific region

About the Presenter(s)/ Trainer(s)

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Dr Sowmya Varadharajan
IC Advisors Pte Ltd

Dr Sowmya Varadharajan is a Director at an international consultancy firm that specialises in transfer pricing and tax valuation. She is an economist with a PhD in Economics from Cornell University.

Sowmya started her career in transfer pricing at PwC. Having worked as part of the transfer pricing practices in both the US and Singapore, Sowmya has extensive experience in preparing transfer pricing documentation and defending such documentation before tax authorities either as part of the transfer pricing audit process, or through the Advance Pricing Agreement (APA) process.

Sowmya has advised on a wide variety of issues, ranging from simple transfer of goods between related enterprises, to more complicated arrangements of buy-in/cost share/cost contribution and intellectual property transfers. In terms of industry experience, Sowmya has extensive experience in the high-tech/semiconductor as well as pharmaceuticals/biomedical industries.

In addition to her transfer pricing expertise, Sowmya also has considerable experience on tax/intellectual property valuation projects.

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