International Tax Programme Level I

Course details

This module provides basic knowledge in tax treaties and transfer pricing. The module will be delivered through a combination of lectures, discussions and practical cases to reinforce participants' understanding of the basic principles and concepts.

Outline

1. Basic Concepts in Tax Treaty

• Introduction
• What is a tax treaty?
• Objective of a tax treaty
• Concepts on juridical and economic double taxation
• Interaction between domestic law and tax treaty, including concepts of tax residence, taxing rights and sharing of taxing rights between jurisdiction

Standard Treaty Model

• How is a treaty structured
• OECD model and UN model (introduction)

Key Articles and Terms

• Scope of treaty – Persons covered and taxes covered
• Definitions – resident and permanent establishments
• Taxation of Income : Business profits, pidends, interest & royalties, capital gains, income from employment, Directors’ fees, Artistes and sportsmen, pensions, government service etc
• Methods of elimination of double taxation

2. Basic Treaty Application

Concept of withholding tax

Illustrations on the interaction of treaties and domestic tax rules

• Business Profits
• Interest, pidends & royalties
• Employment income
• Foreign tax credit

3.Basic Concepts in Transfer Pricing (TP)

Introduction to Transfer Pricing and TP methods

• Key concepts
• Arm’s Length Principle
• Comparative analysis 

Methods

• Overview of methods
• Strength and weakness of each method
• Practical examples

Documentation

• What is documentation and why is there a need for TP documentation
• Concept of contemporaneous documentation
• What are the common consequences of lack of TP documentation

Disputes and risk management

• TP audits and risk management
• TP adjustments
• Dispute resolution (an introduction)

4. Singapore Transfer Pricing Guidelines

• Background of Singapore TP Guidelines

Reference to E-tax guides issued

Alignment with OECD TP guidelines

• Related party lending and routine services 5% safe-harbour
• Revised Documentation guidance

5.IRAS Transfer Pricing Consultation (TPC) Program

6.Future Developments

• Basic introduction to Base Erosion and Profit Shifting (BEPS)