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Singapore Tax Implications on Cross-Border Intercompany Services & Business Profits

Practical Insights in Mitigating Corporate Tax Risks in the Post-BEPS Era

Expert Speaker Sivakumar Saravan

$856.00 (including GST)


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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

  • Consultancy

  • Technical services

  • Secondment arrangements


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


Programme Outline

Taxation of Services from a Singapore Domestic Law perspective

  • Characterization of services

  • Withholding tax implications related to services transactions

    • Inter-company services

    • Management fees

    • Sales commissions

    • Guarantee fees

    • Cost-pooling arrangements

    • Secondment arrangements

    • Sub-contracting models

  • Withholding tax implications relating to digital services

  • Compliance requirements


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

  • Compliance requirements


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

Target Audience

  • CEOs, COOs, CFOs
  • Directors
  • Tax Managers/Professionals
  • Financial Controllers/Finance Directors/ Managers
  • Accountants
  • Those Involved In Corporate Tax Planning

Expert Speaker

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.

Enquiries: email

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