Registration Date |
: | 06 Jul 2018 09:00AM to 10 Aug 2018 06:00PM |
SMF Member Fee |
: | $0.00 |
GS1 Member Fee |
: | $0.00 |
Non-Member Fee |
: | $0.00 |
Event Type |
: | SMF Supported Events |
Industry Group |
: | All |
Contact Person |
: | Gabriel Tan |
A subsidiary borrows from a third party at 1% to 2% and on-lends to its head office at a significantly higher interest rate. This arrangement resulted in its head office claiming a large interest deduction and the subsidiary earning a profit of over $1 billion which was not taxed in any country. Sounds familiar? This was the much talked about Chevron case in Australia which the courts ruled in favour of the Australian Taxation office and resulted in approximately AU$340 million of disallowed deductions.
In this session, Ms Adriana Calderon, Director at Transfer Pricing Solutions Asia, aims to bring participants into the depths of transfer pricing (TP) complexities surrounding the intricate nature of inter-company loans. The session offers participants the opportunity to go beyond fundamentals and grasp what it takes to structure inter-company loans to comply with the Arm’s Length Principle. Adriana will also dive into some of the nuances often missed, but that companies must take note of.
Fees :
$89 (SIATP/ISCA Member)
$109 (SICC/SMF Member/Transfer Pricing Solutions’ Client)
$149 (Non-Member)
Programme Outline
• Be aware of the key considerations in establishing
inter-company loans that will hold fort amid scrutiny by tax authorities
• Explore the practical aspects of the 'How's to manage TP
risks in this area
• Understand the crucial aspects of documentation and
frequency of review
• Grasp what it takes to ensure an appropriate benchmarking
analysis
• Know the best practices to manage inter-company loans
For enquiries, please visit www.siatp.org.sg/events, contact Nabila at 6597 5714 / Alastair at 6597 5717 or email to enquiry@siatp.org.sg