Global Minimum Tax (GMT) is one of the largest tax reformations as part of the initiative under Pillar 2 of the Base Erosion Profit-Shifting (BEPS) 2.0 project.
This article will provide an overview of what global minimum tax is, why it's important, and how it impacts multinational corporations and the global economy.
This article will explore the history of global minimum tax policies, from their origins to the latest developments, including the recent OECD/G20 agreement.
This article will discuss how technology can help multinational corporations streamline their global minimum tax compliance.
This article will discuss how global minimum tax policies affect multinational corporations, including changes to their tax planning strategies and compliance requirements.
This article will provide practical advice for multinational corporations on how to navigate the complexities of global minimum tax compliance.
This article will provide an overview of the legal and regulatory considerations that multinational corporations need to be aware of when dealing with global minimum tax.
This article will speculate on the future of international taxation in light of global minimum tax policies, including potential trends and challenges that may arise.
This article will examine the challenges and opportunities that global minimum tax policies present for developing countries, including their potential impact on tax revenue and economic development.
On 19 February 2024, OECD published the final report on Pillar One -Amount B, is designed to simplify and streamline the application of the arm’s length principle.
We are thrilled to share that Adriana Calderon, Director of Transfer Pricing Solutions Asia, has been appointed by ISCA as a Transfer Pricing Roundtable Representative for SCTP.
The indicative margin recommended by IRAS are market interest rate to be adopted by Singapore taxpayers for related party loans not
exceeding SGD15 million.
Generally, the IRAS publishes the indicative margins at the beginning of each calendar year.
If you are reading this article the chances are that you enjoy discussing about technical aspects of transfer pricing as much as we do. Any transfer pricing aficionado knows that changes to the OECD Transfer Pricing Guidelines are a reason for excitement in the tax and transfer pricing world.
The Malaysian Finance Bill 2020 incorporates transfer pricing-related changes to the current Income Tax Act, 1967 (“ITA”). The changes permit significantly greater authority to the Malaysia Inland Revenue Board (“MIRB”) and re-emphasises the importance of transfer pricing compliance, with effect from 1 January 2021.
Thec Covid-19 pandemic has triggered the most severe recession and is causing enormous damage to the world economy. The economic downturn will impact a group’s transfer prices, analysis and documentation, more so with the BEPS Action Plans in place and the high level of transfer pricing scrutiny across the globe.
JobKeeper forms part of taxable income in the tax return. Makes sense, it is a subsidy against wages, so I am sure there are no surprises there, but how do you assess the arm’s length financial outcomes of the entity for transfer pricing purposes?
The ATO expect that Australian entities will retain the benefit of the JobKeeper payment they receive. So how do you treat the JobKeeper payments for transfer pricing purposes?
Singapore introduced compulsory transfer pricing documentation effective from the year of assessment (YA) 2019. A new penalty regime was also included for non-compliance with the TP documentation requirements.
We are thrilled to announce that Transfer Pricing Solutions is shortlisted for the International Tax Review Asia Tax Awards 2020 with several nominations!
The Inland Revenue Authority of Singapore (IRAS) recognises the diversity in the commodity marketing/trading (CMT) activities undertaken by CMT entities in Singapore and the wide-ranging values they could bring to their multinational enterprise (MNE) group.
Transfer Pricing Solutions are thrilled to have won the Fast-Growing Firm of the Year award at the Australian Accounting Awards 2020!
The Organisation for Economic Co-operation and Development (OECD) has released in February 2020 the final Transfer Pricing Guidance on Financial Transactions (Guidance). The Guidance provides an insight on the arm’s length treatment of various financial transactions among related parties.
Do you have business in the Philippines? In August 2019, the BIR issued Revenue Audit Memorandum Order No. 1-2019
(“the TP Audit Guidelines”) to introduce standardised audit procedures and techniques applicable to taxpayers with related party
transactions.
Our firm has been a pioneer in using technology that allows our team of experts to work from anywhere and at any time.
COVID 19 crisis provoked an unprecedented shift toward working from home (#WFH), and business is implementing tools and resources to allow the employees to work from home and look after their customers as seamless as possible.
Do you want to know about transfer pricing for commodity traders? This article will give you an overview about transfer pricing for commodity trading companies with operations in Singapore
In light of the recent outbreak of Covid-19, which is now known as a global pandemic threat, has jeopardized businesses significantly across the globe. Businesses of various industries are expected to lose billions of revenues.
In a digitalised era, businesses can develop an active and sustained engagement in a market jurisdiction, beyond the mere conclusion of sales, without necessarily investing in local infrastructure and operations. Hence, the allocation of taxing rights can no longer be exclusively circumscribed by reference to physical presence.
Intangible properties (“IPs”) has become the main driver of business profits within Multinational Enterprises (“MNEs”) especially in the digital economy ecosystem.
On 15 December 2019, the Malaysian Inland Revenue Board (“IRB”) issued the updated Tax Audit Frameworks including Transfer Pricing (“TP”) Audit Framework 2019. The updated tax audit frameworks take effect from 15 December 2019.
Inland Revenue Authority of Singapore (“IRAS”) has introduced the indicative margins for related party loans since the past few years whereby the indicative margins are updated at the beginning of each calendar year.
The introduction of Earning Stripping Rules (“ESR”) limiting the interest deduction for financial assistance between related persons were announced in the Budget 2018.
Equip your employees with relevant skills imparted by our team of professional trainers.
On 01 November 2018, the Inland Revenue Board of Malaysia (“IRBM”) had a dialogue session with the Chartered Tax Institute of Malaysia (“CTIM”)’s Technical Committee on the updated version (mainly from Chapters II to XI) of the Malaysian Transfer Pricing Guidelines (“TP Guidelines”)
With the recent focus on profit shifting around the world, guidance on profit split method has revised by Organisation for Economic Co-Operation and Development (“OECD”) in June 2018. OECD published the “Revised Guidance on the Application of the Transactional Profit Split Method” under Base Erosion Profit Shifting (“BEPS”) project - Action 10.
On 13 July 2018, Hong Kong’s new transfer pricing regime was enacted through the Inland Revenue (Amendment) (No. 6) Ordinance 2018 (“Amendment Ordinance”). This new law codifies transfer pricing rules in Hong Kong and is largely consistent with the OECD transfer pricing guidelines.
The TP Minds Asia is a leading independent #transferpricing forum in Asia Pacific region which is held in Singapore from 25 to 26 September 2019.
This year, TP Minds will be held for three days from 24-26 September 2019 in the Novotel Singapore Clarke Quay. The agenda is packed with a number of hot #transferpricing topics that will be discussed by key TP leaders.
On 16 May 2002, the Revenue Department introduced its transfer pricing guidelines in the form of Departmental Instruction (“DI”) No. Paw. 113/2545. The purpose of the transfer pricing guidelines is to assist taxpayers in setting arm’s-length prices for their transactions with related parties while providing direction to revenue officers in reviewing whether taxpayers’ related party transactions are in compliance with the arm’s-length principle.
The transfer pricing team's trip to Australia has been amazing and productive.
This time, the Transfer Pricing Solutions team flew from India, Malaysia and Singapore to our Head Office in Mornington, Australia. There were a number of activities/events arranged for us apart from the usual work routine.
We are so proud to deliver you the good news! Our firm won the prestigious Asia Best Newcomer of the Year award at the ITR Asia Tax Awards 2019.
International Tax Review (ITR) Asia’s Tax Forum is a leading independent tax forum in the Asia Pacific region. The 14th Asia Tax Forum organised by the International Tax Review, a premier event in the region for taxpayers, officials ad practitioners, will be held in Marina Mandarin Singapore on May 8th and 9th 2019.
Being associated with you makes us proud. Your contribution and your commitment to our work are unmatched. Without you, this journey would
have been impossible. Have a happy work anniversary!
From Transfer Pricing Solutions Staff Team
On 26 December 2017, Malaysia Inland Revenue Board (“IRB”) gazetted the Country-by-Country reporting (“CbCR”) regulations for
Labuan entities.
The implementation of CbCR will take effect for the financial year starting on and after 1 January 2017. On 1 January 2019, IRB published
CbCR Guidelines for Labuan entities.
ATO released the initial Practical Compliance Guide (PCG) 2017/1that sets out the ATO’s compliance approach to transfer pricing issues related to centralised operating models (known as "hubs") involving procurement, marketing, sales and distribution functions.
Digital transformation has contributed significant changes to the world, changing the nature of the business and the industry value chain, even the way people interact with each other. Intangible Properties ("IPs") have become the main driver of business profits within Multinational Enterprises ("MNEs") especially in the digital economy ecosystem.
"Teamwork makes the dream work!"
Our nominations for 2019 are Australian Transfer Pricing Firm of the Year, Singapore Transfer Pricing Firm of the Year, Asia's Transfer
Pricing Practise Leader of the Year - Shannon Smit and Asia's Best Newcomer of the Year - Transfer Pricing Solutions Malaysia
Tax authorities worldwide are increasing their focus on companies involved in commodity transactions as a result of the introduction of new guidance on commodity transactions by the OECD in 2015 and the number of court cases involving companies in the mining industry worldwide.
With the increasing scrutiny from the Australian Taxation Office (“ATO”) in transfer pricing matters over the recent years, the burden and cost of compliance are taking its toll on taxpayers, particularly, the small to medium businesses.
To all of our accounting firm clients and potential clients, we wanted to alert you to the round of "Failure to lodge" notices that the ATO is now issuing. We recently received one from an accounting firm who as you can imagine, called us in absolute panic! The failure to lodge was for $525,000 penalty!!! Ok, I think I have your attention now!
In 2018, the Inland Revenue Authority of Singapore amended the Income Tax Act to enforce Mandatory Transfer Pricing Documentation for Singapore Taxpayers. Is the new TP Documentation a real game changer?
If you are an Entrepreneur, Start-Up or SMEs don’t disregard transfer pricing and fall under the trap of thinking that transfer pricing affects large MNEs only.
Is your Company subject to transfer pricing in Malaysia? Our article summarises key considerations to ensure compliance with transfer pricing in Malaysia
The challenge has been thrown down. How do we best simplify key points around transfer pricing? We think we’ve found the answer. Pizza. (Stay with us!) If transfer pricing was a pizza, what would be the main ingredients to consider?
The benchmarking analysis is the backbone of a transfer pricing analysis, benchmarking analysis that is reliable and defendable is key when preparing transfer pricing documentation.
Is your benchmarking analysis reliable?
Need a coffee break? Take a five minute and watch #5MinutesTP Episode 4.
Part two about #transferpricing and services transactions, how to price intra-group services
Need a coffee break? Take a break and watch #5MinutesTP Episode 3, #transferpricing for services, trips and traps on how to price services transactions
Do you want to hear from key transferpricing leaders the latest transfer pricing trends? Come and join TPMinds Australia the largest TP Conference in the region.
The Indonesian transfer pricing landscape continues in turmoil, where Companies are struggling to understand and comply with the latest released regulation No. 213/PMK.03/2016 (“PMK-213”).
Lodgement date for CbC Reporting has been extended to February 2018, does your Company need to complete CbC Report, Master File, Local File in Australia?
Unsure on whether your company is pricing services transactions correctly? This article will give key insights on how to price services correctly
Unsure where to start with BEPS Country by Country Reporting? This article explains all you need to know about CbC reporting requirements in Australia.
Good news! Two prestigious awards won - Asia Best Newcomer of the Year and Asia Transfer Pricing Practice Leader of the Year.
Our nominations for 2017 are Boutique Firm of the Year, Partner of the Year (Boutique) - Shannon Smit, and Thought Leader of the Year - Shannon Smit
Intra-group service transaction is an easy target for transfer pricing adjustment. Two steps to make sure you price them correctly.
Want to know more about how to perform a benchmarking? Read this excellent article published by ISCA Journal, March 2017 edition. Get a copy now, link to article is available in the blog.
New Guidance from the ATO about Australia’s Simplified Transfer Pricing Record Keeping Options, how does it impact your Company?
Australia Transfer Pricing Firm of the Year • Singapore Transfer Pricing Firm of the Year • Best Newcomer of the Year, Transfer Pricing Solutions Asia • Asia Transfer Pricing Practice Leader of the Year, Shannon Smit
Traditionally a preferred transfer pricing method as it is the most direct and reliable way to apply the arm's length principle. But what are the Pros/Cons of applying the CUP method?
On Monday 20 February, the Finance Minister Heng Swee Keat delivered in Parliament Singapore’s 2017 budget. With the tax authorities currently focusing on transfer pricing and the implementation of BEPS action plan, a few of the new measures will impact taxpayers and their related party dealings during 2017.
On January 2016, the ATO released new compliance approach to transfer pricing issues related to centralised operating models (hubs) involving procurement, marketing, sales, and distribution functions. This Practical Compliance Guideline (“PCG”) 2017/1 comes into effect from 1 January 2017 and will apply to existing and newly created hubs.
On 12 January 2017, the IRAS released the 4th edition of its Transfer Pricing Guidelines. We have summarised the key changes that can impact your Company.
The challenge has been thrown down. How do we best simplify key points around transfer pricing? We think we’ve found the answer. Pizza. (Stay with us!) If transfer pricing was a pizza, what would be the main ingredients to consider?
We are honored to be selected among many companies in Singapore to share our story; an excellent read about the human side of transfer pricing and why we love what we do.
We are delighted to announce Shannon Smit, Lead Partner of Transfer Pricing Solutions, as the winner of Partner of the Year – Boutique Firm at the Australian Accounting Awards 2016 organised by Accountants Daily.
As we see the Pokemon Go fever going up around the world, we were interested in knowing why is the world so excited about this game.
We all recovering from the Rio 2016 Olympic Games fever and coping with ‘the Olympic blues’ by following another sportive event or anxiously waiting for the next four years to go by and see our world athletes in Tokyo 2020.
With Australia’s new transfer pricing landscape and BEPS world, intercompany loans are viewed as high risk by Tax Authorities. We have compiled below Frequent Ask Questions from clients that can help you understanding what you need to do to mitigate transfer pricing risks associated with intercompany loans.
With the final reports of the BEPS Action Plan released in October by the OECD and the new transfer pricing documentation standard, a benchmarking analysis that is reliable and defendable is key when preparing transfer pricing documentation.
The Singapore Ministry of Finance announced on 16 June 2016 its commitment and intention to implement the BEPS Action Plan. Singapore will commence a consultation with Multinational Enterprises (MNE) on the implementation of Country By Country (CbC) Reporting and will release details on the outcome in September 2016.
On 15 June 2016, the OECD Council approved the amendments to the ‘Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations’ (Also as the OECD Transfer Pricing Guidelines). The changes are the most significant amendments introduced into the OECD Transfer Pricing Guidelines since 2010.
With transfer pricing gaining so much attention, we have seen an increased interest in accountants wanting to partner with us and outsource part or all of their transfer pricing.
We are delighted to announce Transfer Pricing Solutions as the winner of Australia Transfer Pricing Team of the Year in the Asia Tax Awards 2016 organised by the International Tax Review. The Asia Tax Awards.
The Australia Federal Budget introduced fundamental tax measures that reinforce the Government commitment to tax transparency. Since the released in October 2015 of the final reports from the OECD BEPS Action Plan, Australia has taken significant steps to address the issue of tax avoidance including
On 26 April 2016, The Australian Taxation Office (ATO) released four of Tax Alerts warning multinationals and their tax advisors on potential profit-shifting arrangements that will be closely examining to identify any attempts of tax avoidance.
In the Asia-Pacific Region, Australia, and Japan have both been on the front foot of the BEPS action plan changes releasing legislation to introduce CbC Reporting. It is expected that all countries in the Asia-Pacific Region will introduce the CbC Reporting as it is a key element of the BEPS Action Plan agreed by all 34 OECD member countries, G20 nations, and other nations which joined the BEPS discussions at the OECD.
Transfer Pricing Solutions (TPS) is pleased to reveal a new website to boot!
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The CbC Reporting has created a ‘BEPS wave’ in the industry and has become an area of focus for tax practitioners, with many countries releasing new legislation and reporting requirements for multinational enterprises (MNE).
Transfer Pricing Solutions is growing. As an industry leader in the Asia-Pacific Region, we are delighted to announce the opening of our new entity located in Singapore. Transfer Pricing Solutions Asia allows us to cement our expertise in transfer pricing solutions in one of Asia’s largest financial centres, increasing our presence in the region
Transfer pricing remains in the eye of the Australian Taxation Office (ATO) with further developments on the enforcement of Australia’s multinational anti-avoidance law (MAAL). The spotlight on the anti-avoidance law affirms Australia’s commitment to enforcing tax transparency and the implementation of BEPS Action plan.
The ATO is currently focusing on reviewing arrangements involving the use of offshore procurement hubs that source goods on behalf of Australian resident multinational enterprises (MNEs).
In the most recent Tax Payer Alert TA 2015/5, the ATO announced that is focusing on structures where the procurement hub offshore is sourcing goods on behalf of the Australian MNE and is also receiving services from another related party entity located offshore (Service hub).
On 3 December the federal government passed the Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015. The Bill implements the recent guidance set by the OECD as part of its Base Erosion and Profit Shifting (BEPS) initiative with respect to Action Plan 13 by introducing a new transfer pricing standard.
On 26 November the ATO provided further guidance on the application of the STPR options in the form of Frequently Asked Questions (FAQ). In the document, the ATO emphasises on the importance of demonstrating compliance with Australia’s transfer pricing rules, even when applying the STPR options.
We are hearing a lot are having trouble understanding what contemporaneous documentation really means and what are the practical implications. Read our case study as we summarise our experience with the most common misunderstandings.
As published in The Age on 23rd November 2015, the ATO is quoted to take a tighter approach to deal with multinationals on future taxes, meaning agreeing up front in the form of an Advance Pricing Arrangements. The ATO is becoming more ‘picky’ about entering into agreements and has delayed some renewals with major multinationals.
The Chevron case is a big win for the Commissioner and will definitely give confidence to the Australian Tax Office to pursue more transfer pricing cases, although it is expected that with a potential $322 million tax bill, Chevron will appeal.
With conflicting requirements, Year End Financial Statement auditors are in many cases declining to sign off on audits where there is no ‘evidence’, a company has satisfied the new transfer pricing requirements. The quandary for many companies is how to achieve this when transfer pricing documentation is not required to be prepared until approximately 6 months after year end, whilst the auditors come in 2 months after year end.
On September 16 the OECD released guidance on transfer pricing topics as part of the Base Erosion and Profit Shifting (BEPS) Action Plan announced in July 2013. These topics include guidance on Action 13 on transfer pricing documentation and country-by-country reporting.
Intercompany loans continue to be a hot topic and focus point for the Tax Authorities around the world as this type of transactions are considered high risk from a transfer pricing prospective. If your company has entered into intercompany loans it is critical to assess any transfer pricing risk related with the transaction and to have evidence of compliance with the arm’s length principle.
The Australian Treasury has released exposure draft legislation (Subdivision 815-E) to implement new OECD standards on transfer pricing documentation (Master File and Local File) and Country-by-Country (CbC) reporting. The new draft legislation makes Australia the second country (after Spain) to release legislation on this issue as a direct result of the recent guidance set by the OECD as part of its base erosion and profit shifting (BEPS) initiative with respect to Action Plan 13: Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting.
The Australian Treasury released an exposure draft bill to impose stronger penalties to combat tax avoidance and profit shifting. The draft legislation will apply to companies with annual global revenue exceeding AU$1 billion that are obliged to comply with the Country by Country (CbC) reporting.
The Australian Taxation Office (ATO) has released a new process for advance pricing arrangement (APA) negotiations (Practice Statement, PS LA 2015/4). The new process will apply to all ongoing APA negotiations and future APA requests (both new APAs and renewals). The APA program has been updated to ensure it reflects changes in global economy and the ATO’s anti-profit shifting work.
The new process includes three key steps as follows:
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