|$856.00 (including GST)|
Enjoy a 20% discount for this workshop when you register and make payment online. Payment is via credit card only.
Simply key in the promo code “TWENTY2019” at checkout to enjoy the discount.
Intra-group /Cross-border intercompany services are an integral element of any multinational corporations that operates on a regional / global basis. With globalisation, the volume of intragroup services are on the rise. The growth of such services has thus resulted in greater scrutiny from tax authorities, who are particularly concerned that the payment of cross-border intercompany fees is eroding the tax base in their jurisdiction.
Hence, rightly structuring and managing tax exposures that arise from cross-border intercompany service transactions, in the post-BEPS era, is a key challenge for the regional finance team to address.
This programme is designed specifically to give Finance and Tax Professionals a practical understanding of how to handle the corporate tax aspects of cross-border intercompany services transactions. Singapore tax implications on the following cross-border intercompany services will be covered.
Management services, including routine support services
What You Will Learn
At the end of this workshop, you will:
Understand how cross-border intercompany services should be structured from a corporate tax perspective
Get practical pointers on managing direct tax exposures arising from cross-border intercompany services transactions
Understand the best practices on how to mitigate tax risks
Taxation of Services from a Singapore Domestic Law perspective
Characterization of services
Withholding tax implications related to services transactions
Withholding tax implications relating to digital services
Singapore Corporate Tax Implications on Cross-Border Intercompany Services Income
Review of the foreign sourced income exemption regime
Conditions to be met to enjoy the tax exemption on foreign sourced service income
Claiming foreign tax credits
Managing Cross-Border Taxation of Intercompany Services Using Tax Treaties
UN vs OECD Model Convention
Articles dealing with services
Service Income and using the Business Profits Article
Managing Permanent Establishment risks
"Business Profits" Article vs "Other Income" Article
Interpreting the 'Technical Services' Article
Interactions between Service PE and other provisions of Article 5
Implications of BEPS Action Plan 7
Essential Permanent Establishment (PE) Issues
How to determine the number of days?
Meaning of the word "month"
When does a PE start and when does it end?
Single project versus multiple projects
Providing services through employees versus through third party sub-contractors
Sivakumar Saravan, Senior Partner, Tax and Corporate Advisory, Crowe Horwath Singapore has about 20 years of experience in tax compliance and tax consultancy work for individuals as well as local corporations, multinationals and financial institutions. Siva is a member of Crowe Horwath's International Tax Committee and he has conducted several seminars on international tax to Crowe Horwath tax specialists in the Asia Pacific region as well as to members of the public. He is the author of CCH’s Singapore Withholding Tax And Treaties Online, Crowe Horwath’s Quick Guide to Business Tax in Singapore and Tax Essentials for HR Professionals’. He is the consultant editor of CCH's Singapore Master Tax Guide manual. Siva is an accredited tax advisor of the Singapore Institute of Accredited Tax Professionals. He is also a member of The Institute of Singapore Chartered Accountants of Singapore and the Singapore Institute of Arbitrators.
Prices shown are in SGD and inclusive of 7% GST but do not include handling & shipping (if applicable)
Copyright © 2016 Wolters Kluwer