“The OECD and Brazil's Receita Federal (RFB) held a joint high-level event on 12 April 2022 in Brasília to present the key features of Brazil’s proposed new transfer pricing system”. OECD and Brazil work together to align Brazil’s transfer pricing rules to international standards – (April 2022, OECD)
A service company in TP refers to a company that renders services to its related parties, and the types of services may include, inter alia, management services. Accordingly, IRAS is prepared to allow the adoption of the CM basis, in place of the “normal trading company” basis of assessment (‘NTC basis’), for service companies on the assumption that its business is simple and its expenses are typically operating costs of a revenue nature. Hence, no significant tax adjustments are expected to its tax computation.
This session discusses the concept of TP and the application of the arm’s length principle for companies servicing only related. Understanding your business’s fundamental TP (potential) risks will allow you to manage your tax risk confidently.
The taxation law is used in this seminar to describe the rules and principles that together form how IRAS asserts and limits its jurisdiction to tax income flows. However, you should be aware that there is no universally accepted view as to the precise nature of tax law, and there is even a view that there is no overarching tax regime. That there are competing views in this area is of little surprise.
What you’ll learn:
- Introduction to Transfer Pricing
- Transfer pricing rules: acceptable transfer pricing methods
- Comparability analysis: FAR Analysis
- Exploratory case study – Centralised Activities in Multinational Enterprise Groups
Who should attend: Both tax and non-tax trained junior executives or anyone interested in understanding the impacts of international tax/cross-border transactions on their line of work.
Presenter: Kevin Lee, a business finance professional and subject-matter expert in the tax practice.