Transfer Pricing University (Singapore) - 2019 edition

 
Transfer Pricing University (Singapore) - 2019 edition
Transfer Pricing
University
(Singapore)
2019 edition
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)
Transfer Pricing University (Singapore) - 2019 edition
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)
Transfer Pricing University (Singapore) - 2019 edition
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)
Transfer Pricing University (Singapore) - 2019 edition
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)
Transfer Pricing University (Singapore) - 2019 edition
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)
Transfer Pricing University (Singapore) - 2019 edition
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)
Transfer Pricing University (Singapore) - 2019 edition
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)
Transfer Pricing University (Singapore) - 2019 edition
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)
Transfer Pricing University (Singapore) - 2019 edition
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 Henderson
Presenter 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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For more information about our organisation, please visit ey.com.

© 2019 Ernst & Young Solutions LLP.
All Rights Reserved.

APAC no. 12001709
ED None

Ernst & Young Solutions LLP (UEN T08LL0784H) is a limited liability partnership registered
in Singapore under the Limited Liability Partnerships Act (Chapter 163A)

           In line with EY’s commitment to minimise its impact on the environment, this
           document has been printed on paper with ahigh recycled content.

This material has been prepared for general informational purposes only and is not
intended to be relied upon as accounting, tax or other professional advice. Please refer to
your advisors for specificadvice.

www.ey.com/sg/tax

  Transfer Pricing University (Singapore)
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