Transfer pricing documentation (local/master/country by country). We serve as a transfer pricing consultant, providing support in liaising with the tax authorities and defending your transfer pricing reports when it comes to tax audits. We help to negotiate Advance Pricing Arrangements (“APAs”) or mutual agreement procedures (“MAPs”). We serve clients in Singapore and overseas from various industries and jurisdictions.
What is transfer pricing documentation report about?
Transfer pricing documentation report is a report that showing whether the transactions entered into between related companies within a group of companies are at arm’s length. Arm’s length means that the prices or margins of these intercompany transactions are comparable to what would have been entered into between outside or unrelated parties.
Who are the companies that is required to prepare transfer pricing report?
Companies whose annual revenue is at least S$10 million for each financial year and the related party transactions value (excluding loans) exceed S$ 1 million whereas for loan, the transaction value must exceed S$ 1.5 million.
What are the deadlines for preparing transfer pricing reports?
The deadline is before end of November for paper submission or 15th December for electronic submission.
We ensure that the transfer pricing documentation complies with the Transfer Pricing framework and regulations in the individual local country as well as the OECD transfer pricing documentation requirements. We support our clients in transfer pricing planning and advisory as well as the resolution of queries from local or overseas tax authorities and helped them to defend their transfer pricing policies and documentation.
Our international portfolio includes clients from India, China, Australia, Malaysia, Thailand, Philippines, Vietnam, Indonesia and Singapore. We assist companies on transfer pricing advisory matters and the defence of their transfer pricing arrangements with the respective tax authorities. Additionally, we advised MNE and listed companies on complex transfer pricing issues, and we have extensive experience in the manufacturing, high technology, hospitality, and healthcare industries.
What is transfer pricing about and how does it affect you
Because there is increased scrutiny by tax authorities worldwide, a transfer pricing audit poses a big risk to multinational corporations and organisations from both the tax planning and compliance perspectives. Amazon, Adobe, AOL, Microsoft, Hewlett-Packard, and other large multinationals have all made the headlines in recent years due to transfer-pricing disputes over potential adjustments to income that ranges from tens of millions to over a billion dollars. But if you think transfer pricing affects only big companies, this is where people are often mistaken. Transfer pricing is only triggered when there is an existence of multiple facilities in more than one taxing jurisdiction.
We advise companies on how they can manage their transfer pricing life cycle in the best way. The life cycle consists of four phases: planning, implementation, documentation, and monitoring. Most companies are focused on the first three phases, but the changing tax landscape has made it necessary for companies to manage new pressures, such as increased data collection and information sharing among tax authorities by the active monitoring of their transfer pricing positions. It is crucial for companies to develop a clearly defined process that can manage and mitigate their transfer pricing risks.
Why do we conduct benchmarking analysis/studies ?
Benchmarking studies play a crucial role in any transfer pricing documentation and are a necessary defence for compliance purposes. They are carried out to understand how a company prices its related party transactions, and seek to validate that their pricing was done at arm’s length by reference to independent and comparable transactions.
The purpose is to find out the general conditions of the transactions conducted between international related parties. These studies will generate a range of values: referred to as the arm’s length range or mark-up range. Statistically, arm’s length range is defined by the upper quartile and lower quartile, comprising the range of values of price or profit attached to the related party transactions between unrelated parties that are in same or similar circumstances.
If a transfer price or profit level lies outside of the applicable arm’s length range, the tax authority will take the median value.
Our achievements include:-
Defended a client who has a subsidiary in Batam, Indonesia that is involved in the manufacturing of paper cartons and boxes on transfer pricing matters and devised their transfer pricing policies and documentation.
Devised transfer pricing documentation for a large main-board listed company in the leather furniture business with factories in Southern China and responsible for liaising with the local tax department.
Devised transfer pricing documentation for a local property agent services firm with operations in China.
Devised transfer pricing documentation for a shipping agency with operations in Middle East, India and South-East Asia.
Devised transfer pricing documentation for an investment holding company involved in intercompany service fee charge with China parent company.
Devised transfer pricing documentation for a local SME providing cable engineering works and project management services.
Devised transfer pricing documentation for a SaaS (Software-as-a-Service) involved in developing and owing an all-in-one software platform, which is specifically for recruitment and staffing agencies globally.
Devised transfer pricing documentation for a Japanese MNC involved in trading of electronic components.
We have a team of highly qualified in-house experts:
- Masters of International Taxation (New South Wales);
- Accredited Tax Advisor (Income Tax & GST), SCTP Singapore;
- Chartered Tax Adviser (Australia), Tax Institute of Australia;
- Fellow of the Taxation Institute of Hong Kong (TIHK);
- Member of the Tax Executive Institute (TEI),USA;
- Advanced Diploma in International Tax, Chartered Institute of Taxation;
- Advanced Professional Certificate in International Taxation (APCIT).
- Diploma in Transfer Pricing, Association of Taxation Technicians (UK).