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Transfer Pricing Documentation Masterclass

Expert Speaker Dr Sowmya Varadharajan

$1,400.00 (including GST)



In 2015, the Inland Revenue Authority of Singapore (“IRAS”) introduced the requirement for corporate taxpayers in Singapore to prepare and maintain transfer pricing documentation that is compliant with the Singapore transfer pricing guidelines.  Further revisions have been made in both 2016 and 2017.  These revisions have further strengthened the transfer pricing regime in Singapore.  The requirement to explicitly report the company’s related party transactions in the tax return will also increase transfer pricing scrutiny. 

As the burden of proof in supporting the related party transactions lies squarely with the Singapore taxpayer, it is critical that taxpayers prepare adequate transfer pricing documentation to demonstrate that related party transactions are conducted in an arm’s length manner.

There is also a growing trend of tax authorities requesting to engage directly with tax payers and business owners rather than third party consultants during audits. Preparing key parts of the transfer pricing documentation in-house will ensure complete ownership of the process. 

This Masterclass Programme is specifically designed to give Finance and Tax Professionals a practical understanding of how to prepare most sections of the transfer pricing documentation in-house. Discover how to optimise intercompany pricing which may reduce tax liabilities and improve profitability for shareholders.

What You Will Learn

At the end of this programme, you will:

  • Have additional insights on the changes in the Singapore transfer pricing regime.
  • Have a good understanding of the various transfer pricing methods and how they apply to all related party transactions (tangible goods, services, intangible property and intercompany loans)
  • Find out if existing transfer pricing models are compliant under the post-BEPS era
  • Know how to prepare transfer pricing documentation with reference to OECD Transfer Pricing Documentation Rules (Action Plan 13) and from an IRAS perspective
  • Understand how to undertake functional and economic analysis
  • Know how to develop an optimal documentation plan to minimise risk of controversy and dispute
  • Be abreast of recent transfer pricing developments in the Asia Pacific region.  

Programme Outline

Day One



  • Overview of related party transactions entered into by MNCs
  • Key triggers of related party transactions

Application of Transfer Pricing Methods

  • Application of the arm’s length principle
  • Understanding and application of the methods using case studies

Overview of the Singapore Transfer Pricing Regime

  • Detailed understanding of the Singapore transfer pricing regime
  • Recent developments
  • Case studies

Preparing transfer pricing documentation

1.Company Overview/Industry Analysis

  • Writing the company overview
  • Writing the industry analysis
  • Preparing for a value chain analysis

Day Two

2.Preparing Functional Analysis

  • Functions performed by each entity involved in a related party transaction
  • Assets utilised by each entity involved in a related party transaction
  • Risks borne by each entity involved in a related party transaction
  • Value chain analysis

3.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

Documentation Requirements

  • Understanding compliance requirements for Action Plan 13:  Transfer Pricing Documentation (Masterfile, Local file and Country-by-Country Reporting)
  • Data compilation process for Masterfile and CbCR

Global and Regional Update on Transfer Pricing

  • Summary of transfer pricing regimes in the Asia Pacific region

Expert Speaker

Sowmya is a Director at IC Advisors Pte Ltd, a firm that helps companies design and document appropriate transfer pricing strategies and approaches for their related party transactions.  Having been trained in the U.S. on international tax and transfer pricing issues through blue-chip corporations, Sowmya now applies her transfer pricing training to transfer pricing issues in the Asia Pacific region.  Sowmya has extensive experience in the high technology/semiconductor as well as pharmaceutical/biomedical industries. 

In addition to transfer pricing, Sowmya is also skilled in IP valuation.  With the growth in transfer pricing related audits in the Asia Pacific region, Sowmya has assisted clients in India, China, Malaysia, Indonesia and Singapore in defending their transfer pricing arrangements with tax authorities.

Sowmya is an economist with Ph.D. in Economics from Cornell University and more than 16 years of transfer pricing consulting experience. 

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