TaxEdge Series

4 Feb 2025 | 1.30 p.m. to 5.00 p.m.

Navigating Intangible Asset Valuations for Financial Reporting, Tax, and Transfer Pricing purposes

In today’s knowledge-driven economy, intangible assets play a critical role in driving business success. However, valuing these assets can be challenging, especially when navigating the intricate interplay between accounting standards, tax regulations, and transfer pricing requirements.

Join Mr Richard Goh, Group Tax Specialist at IRAS and Ms Chua Ai Leng , Valuation, Modeling & Economics Partner for Strategy and Transactions services at Ernst & Young Solutions LLP as they decode essential interaction and gaps between different IA valuations. They will also discuss how to ensure compliance with relevant rules and minimising the risk of valuation issues.

This seminar is tailored to equip participants with an overview of the key valuation requirements for financial reporting, tax, and transfer pricing purposes.

Agenda

COMMON TYPES OF IA VALUATION FOR REGULATORY PURPOSES IN SINGAPORE

KEY DIFFERENCES IN THE TYPES OF IA AND HOW THEY ARE VALUED

A) Valuation of intangible assets for accounting purposes

i. Accounting standards

ii. Definition of IA

iii. Fair value

iv. PPA process and simple valuation examples for Multiple Period Excess Earnings Method (MPEEM) and Relief of Royalty Method (RfRM)

B) Valuation of intangibles for transfer pricing purposes

i. Transfer pricing guidelines

ii. Definition of intangibles

iii. Arm’s length price

iv. Simple valuation example for Residual Profit Method (RPM)

C) Valuation of intellectual property rights for tax purposes

i. S19B conditions

ii. Definition of IPRs

iii. Open market price

iv. Issues to consider when using MPEEM, RfRM, and RPM for tax purposes

Q & A

About the Speakers

Admin Details

  • This seminar will be held at Revenue House, Discovery Room@B1

  • Date: 4 Feb 2025

  • Time: 1.30pm to 5pm

  • Fees: SGD163.50 (incl. 9% GST)

  • Registration is on first-come-first served.

  • Registration Form

22 Jan 2025 | 2.00 p.m. to 5.00 p.m.

Update on recent U.S. inbound tax developments and tax policy outlook

Join us for an essential US tax update session led by Mr Andy Baik, Tax Partner at KPMG. Don't miss this opportunity to gain valuable insights from a leading expert in US taxation, this session will equip you with the knowledge to navigate the complex US tax environment.

Key topics include:

  • Recent tax law changes impacting foreign investments in the US

  • Corporate Alternative Minimum Tax (CAMT)

  • Clean energy related credits

  • Inbound-into-US "effectively connected income" issues

  • BEPS Pillar Two interplay with US tax considerations

  • Potential tax policy shifts post US Presidential election

About the Speaker

Andy is a principal in KPMG’s US member firm on a long term secondment in Singapore. He currently serves as a tax partner/leader in KPMG Singapore’s BEPS Centre of Excellence (CoE) and also as the lead partner of the US tax desk group based in Singapore/Asia.  Andy also co-leads KPMG’s BEPS Pillar 2 Global Think Tank.  Andy has advised various private funds, sovereigns/pension funds, asset managers, family offices and MNCs on BEPS Pillar 2 related technical tax, planning and implementation issues.

Andy has an all-around, cross border tax background with a focus on US, Asian and international tax systems. His practice focuses on the asset management sector and works closely with private equity, real estate and sovereign/pension funds on all aspects of their tax matters, including cross border structuring, tax controversy and policy issues. He regularly advises fund and MNC clients on various tax matters relating to their investments into Asia (e.g., treaty planning, financing and exit related structuring) and Singapore/Asia based funds/MNCs on their inbound-into-US investments (real estate, private equity, infrastructure, lending, LP interests, etc.).  He currently serves as the global lead tax partner to one of the world’s largest sovereign funds and works closely with another on many of its strategic, global tax matters. 

Andy has primarily worked in the international tax area and has worked in Washington DC, New York, San Francisco and various Asian locations during his 25 plus year career. He has spent 13 plus years working in Singapore and Korea -- serving in various roles including as the Asia Pacific region international tax practice leader, tax managing partner of a Big 4 firm in Korea, Asia-Pacific sovereign and pension fund tax leader, global tax leader on several top global sovereign investment funds, US tax desk leader, and Asia Pacific regional tax partner on many large US and European MNC accounts. He has also worked as a senior tax partner at a global top 20 law firm. 

Admin Details

  • This webinar will be conducted via Zoom

  • Date: 22 Jan 2025

  • Time: 2pm to 5pm

  • Fees: SGD 163.50 (incl. 9% GST)

  • Registration is on first-come-first served.

  • Registration Form

13 Jan 2025 | 3.00 p.m. to 5.00 p.m.

Legal Documentation for Transfer Pricing of Intangibles

Join Mr Paul Sutton, Founder and Partner at LCN Legal and Mr Richard Goh, Group Tax Specialist, IRAS as they decode the critical elements of legal documentation for transfer pricing of intangibles in IP-related transactions. This webinar will explore best practices for aligning documentation with the arm's length principle, ensuring economic substance, and maintaining consistency with regulatory standards.

Tax, legal, and finance professionals will gain valuable insights to strengthen their transfer pricing strategies and documentation approaches. Don't miss this opportunity to enhance your understanding of this complex and crucial area.

Agenda:

Review of intercompany transactions involving intangibles

  • Overview of Singapore’s TP guidance on intangibles

  • Transfer pricing and valuation issues in IP-related arrangement

  • Common gap

Best practices for legal documentation for intercompany transactions

  • Typical transactions involving intangibles

  • Intangibles vs IP

  • Aligning legal and transfer pricing aspects

  • Case study on designing transaction flows

Q & A

About the Speakers

Paul Sutton is a corporate lawyer with over 30 years' international experience. He specialises in intercompany agreements and legal structures for multinational groups and financial institutions. He is author of “Intercompany Agreements for Transfer Pricing Compliance – A Practical Guide” which is published by Law Brief Publishing. Through his consulting firm LCN, Paul works alongside leading international tax and transfer pricing professionals globally, helping to make sure that the transfer pricing policies of the groups concerned have legal substance and are implemented through appropriate intercompany agreements - which are kept up to date, and tax audit-ready and due diligence-ready.

Richard is a Group Tax Specialist at the Inland Revenue Authority of Singapore. He is a Chartered Valuer and Appraiser and a certified Master Tax Specialist in IP Law, IP Management and IP Commercialisation. He has over 10 years of experience dealing with tax and transfer pricing valuation issues involving acquisitions and transfers of IP and other intangibles across various sectors. He also speaks regularly in seminars and workshops and has written articles on the valuation of intangibles for accounting, tax and transfer pricing purposes.

Admin Details

  • This webinar will be conducted via Zoom

  • Date: 13 Jan 2025

  • Time: 3pm to 5pm

  • Fees: SGD109 (incl. 9% GST)

  • Registration is on first-come-first served.

  • Registration Form