Course details
This module provides in-depth knowledge in international tax principles and concepts, with focus on specific issues on tax treaty and transfer pricing.
The course will be delivered through a combination of lectures, discussions and case studies to reinforce participants' understanding of tax treaty and transfer pricing principles and concepts.
Outline
1. Singapore treaty networks
- Singapore treaty model and positions of selected articles
- Singapore’s comments to the OECD model
- Singapore’s treaty network
- International tax dispute resolution – MAP, APA
- Singapore’s MAP procedures
- Common treaty issues
- Case studies on dispute resolution
2. Transfer pricing
Documentation: Elements of a Transfer Pricing Report. The OECD 3 Tier approach to Documentation Country-by-Country, Master file and Local file
Dispute Resolution Part 2: Mutual Agreement Procedures (MAPs) and Advanced Pricing Agreements (APAs)
Some common areas encountered in practice -
- Head-office Cost and management fee recharges
- Financing transactions
Operational aspects of TP
- Governance & controls,
- Good implementation of TP through the accounting systems
3. Case studies on interpretation of treaty
4. Case study
- Toll manufacturer
- Distributor
5. Recent international tax developments and impact
- Overview of the OECD’ BEPS developments
- Highlight of Key recommendations and resulting implications
- Unilateral measures
- Permanent Establishment
- Prevent Treaty Abuse – impact of LOB/MPT and implications
TP documentation – master file and local file (in relation to country-by-country reporting and disclosure of information/greater transparency)
- Contents
- Implications
6. Case study on interplay between treaty and transfer pricing
7. Selected countries’ tax systems with emphasis on international tax transactions
The following countries will be covered,
- China
- India
- Indonesia
Key observations, developments and trends
Treaty shopping
Anti-avoidance rules
Case studies
Updated on 08 November, 2015Course 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.
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