The profit on trade and investment within national borders are with no doubt subject to income tax. The way in which those incomes are taxed is based upon a country’s domestic tax policy. The same principle also applies to international trades and investments.
As a country’s trade and commerce become increasingly internationalized, the taxation of international transactions becomes ever more important. Once an entity extends its arm beyond its national borders, it is most likely to fall within the ambit of the tax laws of another country. The way in which that country’s tax laws impact the entity will have consequences for the manner in which the entity is taxed domestically which in turn affect the overall profitability & cash-flow of the entity and its ultimate holding companies.
This course teaches knowledge in tax treaties and transfer pricing which are essential knowledge to equipped participants with understanding of the topic@ International Tax.
There will be hand on exercises, questions and problem solving with answer provided after the sharing session.
Upon completion of this course, participants will be able to:
- Appreciate knowledges in tax treaties and this include the treaty model and the various key articles and tax terms.
- Appreciate knowledges on Singapore treaty network and appreciating the current issue faced across ASEAN.
- Acquire knowledges in the application of the Transfer Pricing provisions and the main methodologies.
- Use data to support transfer prices & choosing he most appropriate transfer pricing method.
- Understand Singapore Transfer Pricing Guidelines with reference to E-tax guides.
The target audience includes in-house corporate tax managers/ executives, taxation professionals, accountants and banking and finance professionals, as well as those with partial/ full tax job scope dealing with overseas tax stakeholders.
- Basic Concepts in Tax Treaty
- What is a tax treaty?
- Objective of a tax treaty
- Concepts on juridical and economic double taxation
- Interaction between domestic law and tax treaty, including concepts of tax residence, taxing rights and sharing of taxing rights between jurisdiction
- Standard Treaty Model
- How is a treaty structured
- OECD model and UN model
- Key Articles and Terms
- Scope of treaty – Persons covered and taxes covered
- Definitions – resident and permanent establishments
- Taxation of Income : Business profits, dividends, interest & royalties, capital gains, income from employment, Directors’ fees, Artistes and sportsmen, pensions, government service etc Methods of elimination of double taxation
- 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
- Basic Concepts in Transfer Pricing (TP)
- Introduction to Transfer Pricing and TP methods
- Key concepts
- Arm’s Length Principle
- Comparative analysis
- Overview of methods
- Strength and weakness of each method
- Practical examples
- What is documentation and why is there a need for TP documentation
- Concept of contemporaneous documentation
- What are the common consequences of lack of TP documentation
- Disputes and risk management
- TP audits and risk management
- TP adjustments
- Dispute resolution
- Singapore Transfer Pricing Guidelines
- Background of Singapore TP Guidelines
- Reference to E-tax guides
- Alignment with OECD TP guidelines
- Related party lending and routine services 5% safe-harbour
- Revised Documentation guidance
- Future Developments
- Future of Singapore Tax System
- OECD & G20 BEPS Project
- Major Revolution@ Global Tax System