SGC Breakfast Briefing on "Transfer Pricing - Update on Singapore Guidelines"

About the Breakfast Briefing:

In January 2015, the Inland Revenue Authority of Singapore (IRAS) finalised the updated transfer pricing (TP) e-tax guide which compiles all the Singapore transfer pricing guidelines which will take effect immediately.

This seminar will provide recommendations on how your company can be best prepared to comply with the updated requirements, including discussion on the following:

• Type and extent of documentation that should be prepared/maintained
• Introduction of thresholds for which TP documentation is required
• New safe harbour rules for interest rates
• Introduction of 30-day rule to submit documentation to the IRAS upon request
• Transfer pricing penalty regime and tax adjustments under the new rules
• IRAS’ position on year-end adjustments and self-initiated retrospective adjustments as well as application of the Berry Ratio
• Guidance and sample documents for Advance Pricing Arrangements (APAs)/Mutual Agreement Procedure (MAP) cases
• EY’s suggestions on next steps for taxpayers in order to mitigate transfer pricing risks and to comply with the updated requirements

About the Speakers:

Mr Luis Coronado is a Partner based in Singapore and is ASEAN Transfer Pricing Leader. Mr Coronado has worked in Asia since 2005 as part of his more than 20 years advisory experience in international tax and transfer pricing issues.

Before relocating to Asia, Mr Coronado spent several years serving domestic and multinational companies in Latin America, namely his native Mexico, Brazil, Argentina, Colombia, Peru, and Venezuela. He has advised companies on the negotiation of bilateral APAs and competent authority resolutions with Singapore, China, Japan, Mexico, and the US. He has also served many German multinational companies and is fluent in German, having lived in Düsseldorf as a student. He has also worked in Amsterdam, Washington D.C. and Shanghai.

Mr Coronado is a member of the International Fiscal Association and has been voted numerous times into Euromoney's Guide to the World's Leading Transfer Pricing Advisers.

Mr Stephen Lam is Executive Director, Transfer Pricing Services at Ernst & Young Solutions LLP. Mr Lam relocated from London where he spent over 9 years advising European multinational corporations (MNCs) based in Belgium, France, Germany, the Netherlands, Republic of Ireland, Sweden and United Kingdom. Mr Lam has also worked on a number of transactions between these European companies and their operations in Asia.

Mr Lam has advised on projects including:

• Designing UK based MNC’s cash pooling structure for the group
• Valuation of a loan guarantee (expected loss approach) given by a parent to its subsidiary, incorporating thin capitalisation rules
• Intragroup lending, arm’s length evaluation of interest rates for intercompany loans between subsidiary companies.
• Cash Repatriation and Cash Pooling analysis

Mr Coronado and Mr Lam have extensive experience in providing international tax and transfer pricing advice to multinational companies in the Asia-Pacific, covering transfer pricing risk management, controversy, documentation and post implementation reviews and operational model effectiveness.


(Please be notified that pictures will be taken during the event for publications on our website, newsletters and printed publications).