Does your foreign parent company documentation provide AU compliance?
Learning Centre • Videos & Webinars • Does your foreign parent company documentation provide AU compliance?
Learning Centre • Videos & Webinars • Does your foreign parent company documentation provide AU compliance?
A US multinational company with subsidiaries around the world, including Australia, recently prepared new US transfer pricing documentation.
The company applies their transfer pricing policies on a global basis. The US tax director instructs the Australian tax director to use this documentation to support the prices charged by the US Company to the Australian subsidiary.
Is the US documentation acceptable in Australia?
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.
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