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)
Course Location
About Tax Academy Singapore
The mission of Tax Academy of Singapore is to raise the professional competency of the tax community in Singapore and develop Singapore into a regional tax knowledge hub. A not-for-profit institution, the Tax Academy is set up by the Inland Revenue Authority of Singapore in collaboration with the international accounting firms, Deloitte & Touche, Ernst & Young, KPMG, PricewaterhouseCoopers, as well as the Institute of Singapore Chartered Accountants and the Law Society of Singapore. he Tax Academy of Singapore shall raise the professional competency of the tax community and develop our standing as a leading centre in taxation and regional tax knowledge hub.
See all Tax Academy Singapore courses- Pension Essentials John AcademySGD 33Duration: 2 To 3 Hours
- Finance and Accounting for beginners Alpha AcademySGD 42
SGD 694Duration: Upto 1 Hour
