Transfer Pricing University (Singapore) - 2019 edition
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Transfer Pricing University (Singapore) 2019 edition
Overview Welcome to the Singapore edition of the EY Transfer Pricing University. Conducted by the EY Transfer Pricing leadership in Singapore, this signature transfer pricing series aims to provide tax, accounting and finance professionals with a solid understanding of transfer pricing concepts, practical aspects of transfer pricing documentation and leading practices in transfer pricing. The three-day programme consists of three modules: Modules Dates Module 1: Transfer pricing fundamentals and latest developments 2 April 2019 Key transfer pricing concepts that are essential for a basic understanding of transfer pricing and recent developments in the international tax landscape *27 August 2019 Module 2: Transfer pricing documentation 3 April 2019 Key aspects of transfer pricing documentation, including preparation of the factual and technical sections from a practical perspective *28 August 2019 Module 3: Operational transfer pricing and risk management strategy 4 April 2019 Key aspects of identifying appropriate application of transfer pricing practices and development and use of transfer pricing risk management strategies *29 August 2019 *Registration is not open for August 2019. Dates are provided as reference only. Registration is open for April 2019. Visit www.ey.com/sg/seminars to register your participation! You can choose to attend all or selected modules. Continuing professional education (CPE) credit is given for each module completed. Registration is on a first-come-first-served basis. Whilst we hope to accommodate you at your preferred session, please note that this is subject to space availability. A confirmation email will be sent to you if your registration is successful, together with payment details. Please note that we can only allow replacement of participant upon confirmation. Transfer Pricing University (Singapore)
Modules
The programme for each module is outlined below. Please note
that the details of the programme are subject to change.
Day 1: Transfer pricing fundamentals and latest developments
Time Sub-topic Description
9:00 a.m. Transfer pricing The Organisation for Economic Cooperation and Development
frameworks: (OECD) has and continues to provide significant direction on
OECD, United Nations, transfer pricing through the release of transfer pricing guidelines
key Asia-Pacific countries and more recently through the Action Plan on Base Erosion and
and Singapore Profit Shifting (BEPS). The United Nations has also provided
guidance on transfer pricing. We will outline key developments
under the Action Plan on BEPS, the key components of the OECD
transfer pricing guidelines, and provide an overview of the United
Nations’ approach to transfer pricing, and provide country specific
overviews of the transfer pricing regulatory frameworks for key
Asia-Pacific countries and Singapore.
10:30 a.m. Coffee and tea break
11:00 a.m. Key concepts and transfer Discussion of the basic building blocks for a comprehensive
pricing methods understanding of transfer pricing, covering key transfer pricing
concepts that you will hear in transfer pricing discussions with
revenue authorities and tax practitioners including:
► The arm’s length principle and arm’s length behaviour
► How descriptions of value chain processes and the
functions performed, assets developed and used, and
risks assumed in the value chain are used to define the
transfer pricing approach
► Transfer pricing methods
► Transfer pricing documentation compared to other
types of documentation
Detailed discussion on the five recognised transfer pricing
methods:
► Comparable uncontrolled price method
► Resale price method
► Cost plus method
► Profit split method
► Transactional net margin method
Explanation of the key characteristics of each method, the reasons
why such methods are used and examples of how such methods
are correctly and incorrectly used.
Transfer Pricing University (Singapore)
Day 1: Transfer pricing fundamentals and latest developments
Time Sub-topic Description
12:15 p.m. Lunch break
1:15 p.m. Case study The case study will focus on identifying the related party
transactions and key value chain drivers, and forming views on
the type of transfer pricing characterisations and methods that
should apply around the circumstances of the case study.
2:15 p.m. OECD’s Action Plan Highlights on the relevant actions from OECD’s Action Plan on
on BEPS BEPS, and the impact these actions have on businesses.
► BEPS Action 4 – Interest deductions and other financial
payments
► BEPS Action 8 to 10 – Transfer pricing aspects
► BEPS Action 13 – Transfer pricing documentation and
Country-by-Country Reporting (CbCR)
3.15 p.m. Coffee and tea break
3:45 p.m. OECD’s Action Plan on Highlights on the relevant actions from OECD’s Action Plan on
BEPS (cont’d) BEPS, and the impact these actions have on businesses.
► BEPS Action 5 – Harmful tax practices
► BEPS Action 6 – Preventing treaty abuse
► BEPS Action 7 – Artificial avoidance of permanent
establishment (PE) status
► BEPS Action 14 – Dispute resolution
► BEPS Action 15 – Multilateral instrument
5:00 p.m. Day 1 wrap-up session
Transfer Pricing University (Singapore)
Day 2: Transfer pricing documentation
Time Sub-topic Description
9:00 a.m. Transfer pricing Outline of the transfer pricing regulatory framework and the key
framework in Singapore developments in Singapore.
9:30 a.m. Preparation of Master file Three-tiered approach to transfer pricing documentation -
(MF) and Local file (LF) and focusing on the preparation of MF and LF, highlighting the key
factual sections of transfer issues and practical considerations, as well as contrasting the
pricing reports OECD approach versus the Singapore approach.
Discussion on key components of the factual sections in detail,
with reference to the current and future content recommended by
the OECD. Explanation on content included in the industry,
company and functional analyses, as well as additional content
that is prescribed under the OECD’s Action Plan on BEPS. These
requirements will be contrasted with Singapore and other country
specific requirements.
10:15 a.m. Coffee and tea break
10:45 a.m. Preparation of MF, LF and Three-tiered approach to transfer pricing documentation -
factual sections of transfer focusing on the preparation of MF and LF, highlighting the key
pricing reports (cont'd) issues and practical considerations, as well as contrasting the
OECD approach versus the Singapore approach.
Discussion on key components of the factual sections in detail,
with reference to the current and future content recommended by
the OECD. Explanation on content included in the industry,
company and functional analyses, as well as additional content
that is prescribed under the OECD’s Action Plan on BEPS. These
requirements will be contrasted with Singapore and other country
specific requirements.
11:15 a.m. Case study (part 1) The case study will cover the practical aspects of how the factual
sections are prepared - working through the various processes,
which include how to identify and use source information, key
messages that should be included in the factual sections and
drafting of the factual sections.
Transfer Pricing University (Singapore)
Day 2: Transfer pricing documentation
Time Sub-topic Description
11:45 a.m. Preparation of technical Key components of technical sections – including how you should
sections of transfer pricing document the reasons for selecting a particular transfer pricing
reports method and how that transfer pricing method has actually been
applied.
12:15 p.m. Lunch break
1:15 p.m. Case study (part 2) This case study will focus on working through the process of
conducting a benchmarking analysis in order to establish a set of
arm’s length financial results.
1:45 p.m. Loans and other financing Key characteristics of loans and other financing transactions such
transactions as guarantees, transfer pricing requirements, potential focus areas
of tax authorities, and practical transfer pricing approaches in
relation to such transactions.
3:00 p.m. Preparation of technical This session will cover the factual content that is typically
sections of transfer pricing important, and the types of transfer pricing methods and
reports (loans and other approaches to conducting the benchmarking analysis for other
types of intercompany categories of related party transactions, including related party
transactions) services, royalty fees and loans.
3:45 p.m. Coffee and tea break
4:15 p.m. Preparation of technical This session will cover the factual content that is typically
sections of transfer pricing important, and the types of transfer pricing methods and
reports (loans and other approaches to conducting the benchmarking analysis for other
types of intercompany categories of related party transactions, including related party
transactions) (cont’d) services, royalty fees and loans.
4:45 p.m. Practical approaches to Practical approaches for documentation of new or existing related
transfer pricing party transactions not previously documented, and address the
documentation update of existing related party transactions previously
documented, from a Singapore transfer pricing perspective.
5:15 p.m. Day 2 wrap-up session
Transfer Pricing University (Singapore)
Day 3: Operational transfer pricing and risk management strategy
Time Sub-topic Description
9:00 a.m. Risk assessments, Different approaches taken to manage transfer pricing risk,
advance pricing including:
arrangements, mutual ► Initial reviews of intercompany transactions to identify the level
agreement procedure and of transfer pricing risk
transfer pricing audit and ► Approach that should be taken to comply with transfer pricing
preparedness rules (risk assessment)
► Use of transfer pricing risk management “tools” such as
advance pricing arrangements (used to obtain certainty over
transfer pricing practices) and mutual agreement procedure
(used to manage exposure to double taxation after a transfer
pricing adjustment has been made)
10:30 a.m. Coffee and tea break
11:00 a.m. Risk assessments, Different approaches taken to manage transfer pricing risk,
advance pricing including:
arrangements, mutual ► Initial reviews of intercompany transactions to identify the
agreement procedure and level of transfer pricing risk
transfer pricing audit and ► Approach that should be taken to comply with transfer pricing
preparedness (cont’d) rules (risk assessment)
► Use of transfer pricing risk management “tools” such as
advance pricing arrangements (used to obtain certainty over
transfer pricing practices) and mutual agreement procedure
(used to manage exposure to double taxation after a transfer
pricing adjustment has been made)
11:30 a.m. Case study – formulating a Case study to identify the transfer pricing risk management
transfer pricing risk strategy in an example covering various types and amounts of
management strategy intercompany transactions.
12:00 p.m. Lunch break
1:00 p.m. Singapore CbCR This session will focus on Action 13 Country-by-Country Reporting
implications and CbCR (CbCR), as well as implications for taxpayers in Singapore.
tools
Presentation on the ways in which the CbCR information may be
interpreted by tax authorities as well as typical areas of concern
based on our experience. Highlights on leading practices in terms
of being CbCR-ready and practical considerations in data collation
and management.
Transfer Pricing University (Singapore)
Day 3: Operational transfer pricing and risk management strategy
Time Sub-topic Description
2:10 p.m. Operational transfer pricing Nature and importance of operational transfer pricing, covering the
challenges and practical aspects associated with identifying your
intercompany transactions and how they are applied and monitored
appropriately.
Highlight leading practices associated with appropriate application
of a transfer pricing set-up for intercompany transactions, and
ongoing monitoring of the transfer pricing practices and set-up,
with examples on true-up adjustments and considerations.
3:30 p.m. Coffee and tea break
4:00 p.m. Case study – operational Case study to draw on the content presented in operational
transfer pricing transfer pricing considerations that should apply in the
circumstances of the case study.
4:30 p.m. Q&A
5:00 p.m. Day 3 wrap-up session
Transfer Pricing University (Singapore)
Venue and schedule
The Transfer Pricing University programme will be held at:
Carlton Hotel Singapore
76 Bras Basah Road, Singapore 189558
Each module is conducted from 9:00 a.m. to 5:30 p.m. daily.
Registration starts at 8:30 a.m.
Lunch and refreshments will be provided.
Registration fees
Options For clients, EY alumni, and SIATP members Public
(Fees per person) (Fees per person)
Attending one module S$600 S$700
Attending two modules S$800 S$900
Attending three modules S$900 S$1000
Transfer Pricing University (Singapore)
Who should attend
This programme is suitable for tax directors, in-house transfer pricing managers, tax executives,
finance managers and corporate accountants.
Training materials (i.e., presentation material and applicable case studies) will be provided for
each module.
Throughout the three-day programme, you will learn about:
Day 1: Transfer pricing fundamentals and latest developments Day 3: Operational transfer pricing
Module 1 covers the key transfer pricing concepts that are and risk management strategy
essential for a basic understanding of transfer pricing: Module 3 covers the key aspects of
► The arm’s length principle identifying that transfer pricing
► Economic concepts that are used to explain transfer pricing practices are applied appropriately
practices and that appropriate transfer pricing
► Transfer pricing methods risk management strategies are
► Transfer pricing risk factors used.
► The components of transfer pricing documentation
This includes:
After attending this module, you will be able to identify basic ► How to apply and monitor a
transfer pricing issues and explain basic transfer pricing transfer pricing set-up
concepts. ► Other supporting documents
that should be considered when
applying and monitoring a
transfer pricing set-up
Day 2: Transfer pricing documentation ► The factors that are relevant
for identifying the level of
Module 2 explains the details of transfer pricing documentation
transfer pricing risk
and will show you how the factual and technical sections of
► The risk management practices
transfer pricing documentation are prepared from a practical
used in various situations to
perspective.
manage transfer pricing risk,
This will include: such as risk assessments,
► Detailed explanation about the factual and technical sections of transfer pricing audit preparedness,
transfer pricing documentation identifying when to use advance
► Examples of the extent of documentation in various cases pricing arrangements or mutual
► How to prepare key factual sections of transfer pricing agreement procedures and how to
documentation such as company, industry and functional or manage the processes relating to
process analyses the same
► How transfer pricing methods are selected
► How transfer pricing methods are applied and documented
After attending this module, you
through preparation of benchmarking analyses should be able to identify the
appropriate transfer pricing risk
After attending this module, you will understand how transfer management strategy for your
pricing documentation is prepared, the key aspects that should related party dealings and
be considered when reviewing transfer pricing documentation understand the key aspects required
and the basis used for selecting transfer pricing methods and to appropriately apply transfer
using benchmarking analysis to apply the selected transfer pricing practices.
pricing method.
Transfer Pricing University (Singapore)Presenter
profiles
Luis Coronado
The Singapore edition of the
Chai Sui Fun
EY Transfer Pricing University Stephen Bruce
will be conducted by leaders Stephen Lam
from the EY Transfer Pricing Jonathan Belec
services in Singapore. Wong Hsin Yee
Hoonseok (Warren) Chung
Jow Lee Ying
Anju Singh
Sharon Tan
Rajesh Bheemanee
Molvin Yiu
Vinay Sudhakar
Koji Hisada
Matilda Kee
Tan Wen Hui
Adam HendersonPresenter profiles
Background
• Luis is a Partner in an EY member firm based in Singapore and is also the EY
Asia-Pacific Transfer Pricing Leader.
• Luis has more than 20 years of advisory experience in international tax and
transfer pricing issues.
• He has worked in Asia since 2005, including in Shanghai and Singapore,
where he is currently based.
• He is a member of the International Fiscal Association and has been voted
numerous times into Euromoney’s Guide to the World’s Leading Transfer
Luis Coronado Pricing Advisers and Best of the Best. He is also a member of Bloomberg BNA
Partner Transfer Pricing Advisory Board.
EY Asia-Pacific Transfer
Pricing Leader Key experience
Ernst & Young Solutions LLP • Before relocating to Asia, Luis spent several years serving domestic and
luis.coronado@sg.ey.com
multinational companies in Latin America, namely his native Mexico, Brazil,
Argentina, Colombia, Peru and Venezuela. He has advised companies on the
negotiation of bilateral Advance Pricing Arrangements (APA) and competent
authority resolutions with Singapore, China, Japan, Mexico and the US.
He has also served many German multinational companies and is fluent
in German, having lived in Düsseldorf as a student. He has also worked in
Amsterdam, Washington D.C. and Shanghai.
• Luis is a frequent speaker at tax seminars and universities in the Americas,
Asia, and Europe. He has been an instructor at the International Bureau of
Fiscal Documentation’s programme for introducing transfer pricing to Latin
American governments, as well as in their programmes in Amsterdam, Kuala
Lumpur and Singapore. He has also taught at the Yangzhou Taxation Institute
of China’s State Administration of Taxation. He frequently advises the Inter-
American Development Bank on tax policy issues throughout Latin America,
especially in the area of transfer pricing legislation.
Transfer Pricing University (Singapore)Presenter profiles
Background
• Sui Fun recently joined Ernst & Young Solutions LLP (EY Singapore) with
focus on international tax policy and controversy matters.
• Sui Fun has more than 30 years of tax experience in the capacity of senior tax
administrator, in-house global tax director and tax adviser.
• Sui Fun holds a Masters in Public Administration and International Tax
Programme from Harvard University and a Bachelor of Accountancy (Hons)
from the National University of Singapore.
Key experience
Chai Sui Fun
Partner • Before returning to professional practice, Sui Fun was the assistant
EY Asean International commissioner for tax policy and international tax at the Inland Revenue
Tax Policy and Authority of Singapore (IRAS). In this role, Sui Fun actively supported the
Controversy Leader Singapore government in formulating and implementing tax policies, tax
Ernst & Young Solutions LLP changes and programmes.
sui.fun.chai@sg.ey.com
• Sui Fun has also served as a Competent Authority of Singapore and
represented the Singapore government in tax treaty negotiations, Competent
Authority discussions to resolve cross-border tax disputes (through Mutual
Agreement Procedure and APA) and other international tax matters.
• Since returning to professional practice in 2013, Sui Fun has worked closely
with many multinational corporations on managing complex cross-border
tax controversies and mitigating related tax exposures. These include
addressing tax issues that arise from business transformation, establishing
robust transfer pricing policies and practices, and formulating and helping to
implement tax risk mitigation and tax defence strategies.
• Combined with her tax administration and in-house tax experience, Sui Fun
provides clients with a balanced and pragmatic perspective in managing tax
issues and exposures.
Transfer Pricing University (Singapore)Presenter profiles
Background
• Before joining EY Singapore, Stephen was the global head of transfer pricing
for a global investment bank where he spent three years in London
undertaking that role.
• He has worked in multiple jurisdictions within Asia in addition to New Zealand
and the UK and has more than 20 years of tax advisory experience.
• Stephen has a Bachelor’s degree in Management Studies (Accounting and
Finance major) from the University of Waikato.
Key experience
Stephen Bruce
Partner • Stephen has been involved in the full spectrum of transfer pricing projects
Transfer Pricing Services, within investment banks including the review of the global treasury
Financial Services Tax function, sales, trading and execution functions of equities and fixed income
Ernst & Young Solutions LLP businesses, investment banking deal origination and execution, shared
stephen.bruce@sg.ey.com service arrangements and headquarter service arrangements. In addition, he
has covered transfer pricing arrangements within the asset management and
private banking arms of the same organisation.
• He has experience in designing transfer pricing policies, applying these
policies in an efficient and effective manner and has been involved in the
successful defence of these policies across multiple jurisdictions.
• Prior to his focus on transfer pricing, he was responsible for the overall
management of the investment bank’s tax position across Greater China,
India and Korea. As such, he has extensive knowledge of the business
operational structures and regulatory issues associated with Asian banking
and capital markets.
Background
• Relocated to EY Singapore from London, Stephen spent over nine years
advising European multinational corporations (MNC) based in Belgium,
France, Germany, the Netherlands, Republic of Ireland, Sweden and the UK.
He has also worked on a number of transactions between these European
companies and their operations in Asia.
• Other than holding previous roles in the fund management industry in
Australia and the UK, Stephen has also been involved in the audit defence for
a European Bank in Taiwan.
Stephen Lam • Stephen has a Bachelor’s degree in Finance and a Bachelor of Accountancy
Partner from the University of Adelaide (Australia).
Transfer Pricing Services
Ernst & Young Solutions LLP
stephen.lam@sg.ey.com
Key experience
• Stephen’s experience includes the design, implementation and support of
tax and transfer pricing models in a variety of industries including apparel,
e-commerce, fast moving consumer goods, financial services, high-tech,
logistics, pharmaceutical and shipping. His experience also includes the
design of a cash pooling structure for a UK-based MNC, as well as cash
repatriation analysis.
• Stephen was also previously involved in the valuation of a loan guarantee
(expected loss approach) given by a parent to its subsidiary, incorporating
thin capitalisation rules.
• Stephen also has experience in intragroup lending structures, which involves
the arm’s length evaluation of interest rates for intercompany loans between
subsidiary companies.
Transfer Pricing University (Singapore)Presenter profiles
Background
• Before entering private practice in 2004, Jonathan served as a tax policy
advisor for the Canadian Department of Finance.
• Jonathan has more than 15 years of transfer pricing experience in Singapore,
China and Canada having worked for EY member firm offices in Shanghai and
Montreal prior to joining EY Singapore.
• Jonathan is a Chartered Financial Analyst (CFA) charter holder and has a
Master’s degree in Economics from the Queen’s University in Ontario, Canada.
Key experience
Jonathan Belec
Partner • Jonathan’s transfer pricing experience includes advising clients on transfer
Transfer Pricing Services pricing controversies, APA, operating model effectiveness, shared services
Ernst & Young Solutions LLP centres, centralised procurement and intellectual property models in Asia and
jonathan.belec@sg.ey.com North America.
• Jonathan has extensive experience in the development and application
of transfer pricing policies and the preparation of global transfer pricing
documentation studies involving intercompany sales of goods, provision of
services, financing and licensing of intangible properties.
• Jonathan also has experience advising clients with Country-by-Country
Reporting (CbCR) requirements.
• Jonathan has worked for clients in a variety of industries including
apparel, automotive, chemical products, consumer products, engineering
procurement and construction (EP&C), electronics, financial institutions,
logistics, marketing, oil and gas, real estate and telecommunications.
Transfer Pricing University (Singapore)Presenter profiles
Background
• Hsin Yee is a Partner in EY Singapore International Tax Services practice.
• She has experience gained in Corporate and International Tax practices in
Singapore and New York.
• Hsin Yee has a Bachelor of Accountancy (Honours) degree from the Nanyang
Technological University of Singapore.
• She is a Non-Practising Member of the Institute of Singapore Chartered
Accountants, a Member of the Singapore Institute of Accredited Tax
Professionals and a Certified Public Accountant of the State of New York.
Wong Hsin Yee
Partner
International Tax Services Key experience
Ernst & Young Solutions LLP
• Hsin Yee has more than 18 years of experience in international tax,
hsin-yee.wong@sg.ey.com
seasoned in legal entity rationalisation, mergers & acquisition, cross border
restructuring and operating model effectiveness planning.
• She services multinational corporations as well as Singapore headquartered
companies across various sectors, with special focus on corporations in e-
commerce, technology and life sciences.
• She advises clients on legal entity rationalisation, cross border structuring,
mergers & acquisitions planning, intellectual property planning as well as
international tax issues associated with operating model planning. She also
assists clients to review their legal and operating structures in light of Base
Erosion Profit Shifting (BEPS) and the current tax environment.
• She was based in New York from 2006 to 2012, where she advised US
multinational corporations expanding into Asia-Pacific, on legal entity and
financial restructuring, holding company planning as well as operating
model planning ranging from feasibility through to implementation.
• Hsin Yee has managed the Asia post acquisition restructuring of a
multibillion pharmaceutical company and the Asia restructuring of a global
manufacturer of commercial products. She has also been involved in several
legal entity restructuring and operating model re-design projects involving
corporations looking to expand in Asia, with Singapore as the Asia-Pacific
headquarter.
Transfer Pricing University (Singapore)Presenter profiles
Background
• Hoonseok (Warren) is a director in EY Singapore.
• He has a Bachelor of Business Administration degree from the Yonsei University
and a Master degree in Taxation from the University of Seoul.
• He was one of the International Tax Services leaders in Ernst & Young Han
Yong (EY Korea), one of the "Big 4" organisations, for Korean multinational
entities. His transfer pricing team was also ranked as Tier 1 Transfer Pricing
Advisory Group in Korea by International Tax Review 2012.
• Hoonseok started his CPA career as a financial services auditor at KPMG in
Hoonseok (Warren) Chung 2004 and with his international career in US and Japan, he has led the transfer
Director pricing practice since 2008.
Transfer Pricing Services
Ernst & Young Solutions LLP Key experience
hoonseok.chung@sg.ey.com • He successfully concluded the first transfer pricing valuation case and lots of
bilateral and unilateral APA cases (among those represented by an external
adviser) and TP planning for outbound as well as in-bound industries. His
experience also includes working in the Korean government.
• As a core member of the Ministry of strategy and finance (MOSF) TF for the
amendment of the AITA (the Adjustment of International Taxes Act), he
handled multinational TP regulations and the Korean TP regulation. Hoonseok
continues to hold lectures for the EY group as well as Korean multinational
companies on TP related issues.
• His experience also includes working in the Korean government.
Background
• Lee Ying is a Director in EY Singapore.
• She is also a faculty member of the Nanyang Business School, Nanyang
Technological University where she lectures on tax and transfer pricing
issues. She is a regular speaker at public seminars organised for the tax
industry.
• Lee Ying has extensive experience in a wide spectrum of international
tax work including APA, Mutual Agreement Procedure (MAP), Avoidance
of Double Taxation Agreements (DTA), transfer pricing consultation and
Jow Lee Ying audits, transfer pricing documentation and review, and corporate tax policy
Director formulation.
Transfer Pricing Services • Lee Ying is an accredited tax advisor (ATA) with the Singapore Institute of
Ernst & Young Solutions LLP
Accredited Tax Professionals (SIATP), holds a Master’s degree in International
lee-ying.jow@sg.ey.com
Taxation from the University of Sydney and graduated with First Class
Honours from the National University of Singapore.
Key experience
• Prior to joining EY Singapore, Lee Ying was a senior tax specialist at the
IRAS. Whilst at the IRAS, Lee Ying was involved in the successful conclusion
of APA and MAP cases with several of Singapore’s tax treaty partners,
including Japan, Australia and France. Lee Ying participated in the
development of Singapore’s transfer pricing policies and took part in the
IRAS’ transfer pricing consultations and audits.
• Lee Ying was also directly involved in negotiating and interpreting
Singapore’s Avoidance of DTA with numerous countries.
• Lee Ying has previous working experience at the Singapore Economic
Development Board, where she advised multinational corporations on setting
up regional headquarters in Singapore. She was also involved in corporate tax
policy formulation at the Singapore Ministry of Finance.
Transfer Pricing University (Singapore)Presenter profiles
Background
• Anju is a Director in EY Singapore.
• She has a Bachelor of Engineering degree from India in Electrical Engineering
and an MBA from Babson College in Massachusetts, US.
• She is a licensed CPA in California and is currently a member of the American
Institute of Certified Public Accountants and the California CPA society.
• Anju is a regular speaker on transfer pricing matters at associations and
seminars. She has also written articles in various publications on operational
transfer pricing and other tax model effectiveness topics.
Anju Singh
Director Key experience
Transfer Pricing Services • Anju has more than 20 years of diversified Consulting and Tax experience.
Ernst & Young Solutions LLP
• Prior to joining EY Singapore in May 2017, she practised in one of the Big 4
anju.singh@sg.ey.com
organisations in the US for over 19 years.
• She is experienced in managing numerous highly complex technology
and performance improvement projects for intercompany transaction
flows, transfer pricing and the allocation of management
fee arrangements.
• She has managed numerous highly complex technology and performance
improvement projects, improving financial and tax operations, and
impacting business growth for clients in the financial services and
technology industries.
• She has also helped in restructuring projects involving full value chains or
parts of the value chain from a tax and transfer pricing perspective.
operational structures and regulatory issues associated with Asian banking
and capital markets.
Background
• Sharon is a Director in EY Singapore.
• Sharon is an accredited tax advisor (ATA) with the Singapore Institute of
Accredited Tax Professionals (SIATP), and graduated from the National
University of Singapore with a Second Class Upper Honours in Economics.
Key experience
• Sharon has more than 10 years of transfer pricing experience.
• Prior to joining EY Singapore in May 2009, she practised transfer pricing in
Sharon Tan Houston, US, focusing on advising mostly Fortune 500 companies on transfer
Director pricing issues in the Americas.
Transfer Pricing Services • She has helped to manage numerous multi-jurisdictional transfer pricing
Ernst & Young Solutions LLP
planning and documentation projects including the analysis of tangible and
sharon.tan@sg.ey.com
intangible transactions, intercompany service fees and other transactions for
companies operating in the oil and gas, biotechnology, financial services, fast
moving consumer goods, electronics and telecommunications industries.
• She has participated in the negotiation of APA with competent authorities,
including Bilateral Advance Pricing Arrangements (BAPA) with Australia,
Japan, Korea, Switzerland and Thailand, as well as Singapore Unilateral
Advance Pricing Arrangements (UAPA).
Transfer Pricing University (Singapore)Presenter profiles
Background
• Rajesh is a Director in EY Singapore.
• Rajesh is a transfer pricing professional with over 13 years of transfer pricing
experience in OECD, Asia and India, and more than one year of Indian
corporate tax compliance experience.
• Prior to joining EY Singapore, Rajesh was based in the Financial Services
Transfer Pricing Team in Ernst & Young Tax Co. (EY Tokyo) for three years.
Prior to joining EY Tokyo office, Rajesh was an in-house transfer pricing
specialist with a global investment bank.
Rajesh Bheemanee • Rajesh has a Bachelor’s degree in Commerce and Economics from Mumbai
Director University, India and is a fellow member of the Institute of Chartered
Transfer Pricing Services Accountants of India (ICAI).
Ernst & Young Solutions LLP
rajesh.bheemanee@sg.ey.com Key experience
• Rajesh has extensive knowledge of the business arrangement and regulatory
issues associated with Asian Capital Market, Asian Investment Banking, Asset
Management, Insurance and Private Equity business.
• He has been involved in a variety of transfer pricing projects for financial
services transaction including equity execution, investment banking deal
origination and execution, asset management, intercompany financing,
global treasury functions, insurance, shared service arrangements,
headquarter service arrangements, and fixed income product.
• He has assisted clients in planning their transfer pricing policies (which
includes fee split and cost plus type arrangements), documentation of
these policies (including benchmarking analyses), risk assessment, audit
defence preparation and advising on the pros and cons of different types
of arrangements.
• Rajesh has prepared regional master file and country specific transfer pricing
documentation (local file) for various locations in Asia including Australia,
India, Indonesia, Japan, Korea, Taiwan, Thailand and Singapore.
Background
• Molvin is an Associate Director in EY Singapore.
• Molvin has extensive transfer pricing and economic consulting experience in
Asia, Japan and the Greater China Region.
Key experience
• Before joining EY Singapore in 2012, Molvin spent three years in Tokyo and
six years in the Greater China region advising clients on a number of transfer
pricing and regulatory matters.
Molvin Yiu • Prior to his current position, he had working experience in a US-based
Director economic consulting company and another advisory firm.
Transfer Pricing Services
• Molvin has extensive project experience in a number of industries, including
Ernst & Young Solutions LLP
molvin.yiu@sg.ey.com information technology, pharmaceuticals, automobiles, real estate,
distribution, fashion retail.
• The types of project that he worked on include market premium and location
savings analysis relating to emerging markets such as China and Asean,
complex residual profit split analysis between Asia and the US or Europe,
valuation of royalty and patents, repatriation of cash, joint venture partner
negotiations support, controversy support in transfer pricing disputes, and
application of UAPA and BAPA.
• He is fluent in Cantonese, English, Japanese and Mandarin.
Transfer Pricing University (Singapore)Presenter profiles
Background
• Vinay is an Associate Director in EY Singapore with more than 12 years of
transfer pricing experience in the Asia-Pacific region, including India,
Indonesia and Singapore.
Vinay holds an Advanced Diploma in International Taxation (ADIT) awarded
by the Chartered Institute of Taxation, London. He also holds a Bachelor’s
degree in Commerce (B. Com) from the University of Madras and a Post
Graduate Diploma in Business Administration (MBA) from the Symbiosis
Centre for Distance Learning, India.
Vinay Sudhakar Key experience
Associate Director
Transfer Pricing Services • Vinay specialises in full value chain of undertaking transfer pricing
Ernst & Young Solutions LLP engagements ranging from cross border structuring and operating model
vinay.sudhakar@sg.ey.com effectiveness, transfer pricing policy design, global documentation and
CbCRs. Having worked in aggressive transfer pricing audit jurisdictions, he
has gained significant experience in audit defense, dispute resolution
(including MAP and APA projects. He has assisted multinationals in their MAP
and APA cases involving predominantly the Singapore-India and Singapore-
Indonesia corridors.
• His multi country stint has enabled him to work with clients in multiple sectors
– Notably he has significant experience in the Technology, Media and
Telecommunications sector and the Mining sector
Background
• Matilda Kee is a Senior Manager in EY Singapore and has more than nine
years of experience working in the Transfer Pricing and Operating Model
Effectiveness (OME) arenas.
• Matilda was also previously seconded to the Ernst & Young (EY Australia)
Transfer Pricing practice from February 2016 to August 2017, and had 18
months of experience in Australian specific transfer pricing or tax
controversy cases.
• Matilda graduated from the Singapore Management University with a
Matilda Kee Bachelor’s degree in Accounting and Finance (Honours). She is also a
Senior Manager member of the Institute of Chartered Public Accountants of Singapore.
Transfer Pricing Services,
Operating Model Effectiveness Key experience
Ernst & Young Solutions LLP
• Matilda’s experience includes the preparation of transfer pricing analysis for a
matilda.kee@sg.ey.com
wide range of projects including documentation, controversy, planning and
OME. This relates to work in both the Singapore and Australian tax
jurisdictions.
• Matilda has been involved in preparing the transfer pricing analysis and
planning studies for numerous projects in various industries, in particular,
having a focus in the high-tech industries, service industries, and apparel and
consumer goods industries.
• Matilda was also directly involved in the submission of several BAPA and
MAP for clients in various industries and countries.
• Matilda has also been involved in various OME engagements, assisting
clients in the high-tech and apparel industry from start to finish (i.e.
assistance with feasibility assessments, detailed design of transactional and
operational model, implementation support and sustainability of the
designed model).
Transfer Pricing University (Singapore)Presenter profiles
Background
• Koji is a Senior Manager in the Transfer Pricing practice based in Singapore.
• Since January 2014, Koji has been assigned to Singapore as a member of
Transfer Pricing team and Japan Business Services Group.
• Koji is CPA admitted in the State of Delaware (US CPA) and an associate
member of the Institute of Singapore Chartered Accountants.
Key experience
• Koji has several years of transfer pricing experience in Japan at EY. Since Koji
Koji Hisada has joined EY, he has assisted in a number bilateral APAs, Japanese
Senior Manager documentations as well as other services.
Transfer Pricing Services
Japan tax desk • Koji has assisted clients in such industries as and automotive parts, heavy
Ernst & Young Solutions LLP equipment and trucks, electronic parts, chemicals, medical equipment,
Koji-k.hisada@sg.ey.com maritime trade, trading companies, securities companies, investment bank,
rating companies and e-commerce companies.
Background
• Wen Hui is a Senior Manager in the Transfer Pricing services based in
Singapore.
• Wen Hui has a Bachelor’s degree in Information Technology from the
University of Wollongong, Australia.
Key experience
• Wen Hui has more than seven years of transfer pricing and OME experience
in the Asia-Pacific region, including China and Singapore. She has worked in
Shanghai, China for more than three years before moving back to
Wen Hui Tan
Singapore.
Senior Manager
Transfer Pricing Services • Wen Hui has worked on a number of transfer pricing engagements including
Ernst & Young Solutions LLP transfer pricing analysis, planning and documentation projects for tangible
wen-hui.tan@sg.ey.com and intangible property, provision of services, transfer pricing controversy
as well as unilateral and bilateral APA. She has also been involved in
providing business restructuring and operating model effectiveness advice,
identifying areas of transfer pricing concerns and designing risk mitigating
options for her clients.
Transfer Pricing University (Singapore)Presenter profiles
Background
• Adam is a Singapore-based Financial Services Tax Manager with
experience in transfer pricing.
• Prior to joining EY Singapore to focus on financial services transfer pricing in
the region, Adam spent four years with the financial services transfer pricing
team in an EY member firm in London.
• He has a Master’s degree in Economics from the University of Edinburgh.
• Adam has over five years of transfer pricing experience in both the UK and
Singapore and is skilled in various areas of the field including treasury,
Adam Henderson planning, documentation and audit defence.
Senior Manager
Transfer Pricing Services Key experience
Ernst & Young Solutions LLP • Adam has experience in advising multinational institutions from a number of
adam.henderson@sg.ey.com industries on a range of cross-border transactions. Seasoned in financial
institutions in the banking and asset management industries, he also has
transfer pricing experience in insurance, professional services, commodities,
real estate, renewable energy and payment processing industries.
• His transfer pricing experience includes policy design and documentation
related to risk transfer arrangements, globally integrated trading, intra-
group funding, intra-group support services, origination, capital raising and
discretionary investment functions.
• Adam also has direct involvement in transfer pricing controversy experience
in the UK, Singapore, Australia and Switzerland in addition to discussions
with a number of tax authorities on thin capitalisation and APA matters.
Transfer Pricing University (Singapore)Frequently asked questions (FAQ) 1. How do I register for the programme? Please click here to register. 2. When will I be informed of my confirmed placement? Registrations will be processed within five days upon receipt of your registration. This is subject to space availability for the requested date or module. We will contact you via email or phone if alternative date or space is not available. 3. How do I pay for the programme? You can pay the fees through cheque or Interbank GIRO (IBG). Payment details will be provided to you in the confirmation email. 4. When should I make payment? Payment should be made after you receive the confirmation email for of your registration. Payment should reach us at least seven days prior to the programme commencement date. 5. Can I attend modules separately (i.e., across multiple sessions), if I am unable to attend the entire programme in the same session? Yes, you can register for the remaining modules in the next available session. Transfer Pricing University (Singapore)
6. I have registered for the programme but I am unable to attend.
a. Can I transfer my placement to a colleague?
Yes, please inform us of any changes at least one week prior to the programme commencement date.
You may email the replacement details to Liew Wan Ying at wan-ying.liew@sg.ey.com.
b. Can I get a refund?
We only allow replacement upon confirmation of registration. No refunds can be made for
cancellations upon receipt of the confirmation email.
c. Can I opt for alternative modules that you will be conducting?
Please email Liew Wan Ying at wan-ying.liew@sg.ey.com.
7. Can I change the modules that I have signed up for?
Yes. Please note that this is subject to the available space for the requested module.
Please email Liew Wan Ying at wan-ying.liew@sg.ey.com.
8. What will I learn from this three-day programme?
Depending on the modules you register for, you will be able to:
• Identify basic transfer pricing issues (Day 1)
• Explain basic transfer pricing concepts (Day 1)
• Understand how transfer pricing documentation is prepared (Day 2)
• Identify transfer pricing risk management strategy (Day 3)
• Apply transfer pricing practices (Day 3)
Please click here for more information.
9. Is the content Singapore-specific, or general?
The course content covers a mix of Singapore, Asia-Pacific, and Organisation for Economic Co-operation
and Development (OECD) transfer pricing practices. Potential attendees could be anyone
interested in learning about transfer pricing in the Asia-Pacific region.
For more information, please click here
10. Will I be able to prepare transfer pricing documentation on my own if I only complete Day 2 of
the programme?
Day 2 (together with Day 1) of the Singapore edition of the Transfer Pricing University is designed to
provide a broad introduction to the content included in transfer pricing documentation and the processes
followed to prepare the documentation.
Attending Day 2 (along with Day 1) will provide a significant starting point from which you should be able
understand the nature and objectives of transfer pricing documentation, aspects of transfer pricing
documentation that should considered if you are reviewing the transfer pricing documentation and the
overall processes that are required to prepare transfer pricing documentation.
However, preparation of transfer pricing documentation usually involves many years of experience, given
the judgements and skills required to address the unique nature of each business and its related party
transactions, as well as the ever-changing transfer pricing regulatory and technical frameworks.
11. Are food and drinks provided during the breaks?
Yes, lunch and refreshments will be provided. The menu includes vegetarian items.
Please email ask.tp@sg.ey.com if you have further questions. Thank you.
Transfer Pricing University (Singapore)Contact us Luis Coronado Chai Sui Fun Jow Lee Ying EY Asia-Pacific Transfer Pricing EY Asean International Tax Policy Director Leader and Partner, International and Controversy Leader and Transfer Pricing Services Tax Services Partner Ernst & Young Solutions LLP Ernst & Young Solutions LLP Ernst & Young Solutions LLP +65 9692 3671 +65 6309 8826 +65 6718 1128 lee-ying.jow@sg.ey.com luis.coronado@sg.ey.com sui.fun.chai@sg.ey.com Stephen Lam Wong Hsin Yee Rajesh Bheemanee Partner Partner Director Transfer Pricing Services International Tax Services Transfer Pricing Services Ernst & Young Solutions LLP Ernst & Young Solutions LLP Ernst & Young Solutions LLP +65 6309 8305 Tel: +65 6309 8138 +65 6309 8274 stephen.lam@sg.ey.com hsin-yee.wong@sg.ey.com rajesh.bheemanee@sg.ey.com Jonathan Belec Sharon Tan Anju Singh Partner Director Director Transfer Pricing Services Transfer Pricing Services Transfer Pricing Services Ernst & Young Solutions LLP Ernst & Young Solutions LLP Ernst & Young Solutions LLP +65 6309 6175 +65 6309 6375 +65 6309 6712 jonathan.belec@sg.ey.com sharon.tan@sg.ey.com anju.singh@sg.ey.com Stephen Bruce Hoonseok (Warren) Chung Molvin Yiu Partner Director Director Financial Services Tax Transfer Pricing Services Transfer Pricing Services Ernst & Young Solutions LLP Ernst & Young Solutions LLP Ernst & Young Solutions LLP Tel: +65 6309 8898 +65 6718 1072 +65 6309 6478 stephen.bruce@sg.ey.com hoonseok.chung@sg.ey.com molvin.yiu@sg.ey.com Transfer Pricing University (Singapore)
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in Singapore under the Limited Liability Partnerships Act (Chapter 163A)
In line with EY’s commitment to minimise its impact on the environment, this
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This material has been prepared for general informational purposes only and is not
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