• Overview
  • Programme

IBF Masterclass - Transfer Pricing – application and impact on financial transactions

16 Jul 2020

The last decade was defined by a range of international tax and transfer pricing developments which came about due to the Base Erosion and Profit Shifting ("BEPS") Action Plans.  Although the BEPS Action Plans were finalised in 2016, a key aspect – on financial transactions - was largely left untouched.  In February 2020, the guidance on financial transactions was finally released by the OECD.  Such guidance was consistent with both Action Plan 4 (Limiting Base Erosion involving Interest Deductions and Other Financial Payments) as well as the broader Transfer Pricing Guidelines. 

The OECD's Guidance on Financial Transactions is timely given the current economic situation that has come about due to COVID-19.  While the guidance provides specific considerations for intercompany lending, it also expands on the role and analysis of the treasury functions by looking at transactions involving hedging, cash pooling and financial guarantees.  Furthermore, it also provides detailed guidance on how arm's length pricing for captive insurance and re-insurance should be undertaken. 

This is a significant step by the OECD towards providing an all-inclusive guidance on financial transactions, and clearly signifies that the OECD expects to see marked progress by multinationals, including financial institutions, in updating their existing transfer pricing policies on financial transactions to comply with the revised Transfer Pricing Guidelines.  Such guidance is also likely to provide the necessary framework for tax authorities to review their related party financial transactions.

This session will help participants gain a better

  • awareness of the key areas demarcated by the OECD for an accurate analysis to intercompany financial transactions
  • Prepare robust transfer pricing analysis in relation to intercompany financial transactions
  • develop practical insights to determine the best way forward on the transfer pricing aspects of financial transactions


Who Should Attend:Professionals and Senior Executives who handle cross border transactions, tax, legal and compliance practitioners     



Date:16 Jul 2020
Time:3pm to 5pm
Venue:Webex Webinar
CPD Hours:

Attendees will be awarded with 2 hours (non-core) CPD


  • To be eligible for CPD hours and issuance of Certificate of Attendance (COA), participants shall be present for the entire programme and with records of SIGN-IN and SIGN-OUT. COA will be issued 5 days after the event.
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Event Secretariat


DID: 6305 5690


E: events@ibf.org.sg

IBF Masterclass - Transfer Pricing – application and impact on financial transactions

16 Jul 2020

Time Activity

Welcome Remarks


Overview of the Transfer Pricing Guidance on Financial Transactions
 Application of the Arm's Length Principle
 Guidance on specific financial transactions/ instrument
 Finance and Accounting Facets of Transfer Pricing and guidance provided by MAS          

Devising a plan of action for the best way forward
 Policy analysis and change
 Implementation and documentation work
 Efficient and practical steps      

Dr. Sowmya Varadharajan, Director, IC Advisors Pte Ltd