Dear Readers,

With the holiday season approaching, we would like to take this opportunity to thank you for your continuous partnership and support.

The TPS family wishes you a joyous Merry Christmas and a Happy New Year! 2019 is going to be an even more exciting  year.

Our offices will be closed from 21 December to 7 January 2019 during the Christmas break to allow our team a well-deserved rest after working hard during 2018.

Transfer Pricing Highlights

Together, we witnessed key changes in the transfer pricing arena during 2018. The buzz words of the year include 'Digital Tax' 'Profit Split', 'Substance Over Form', 'Country by Country Reporting', 'Local File', and 'Master File'.

2018 was full of transfer pricing excitement, our highlights include: 

Australia

• The second year of Country by Country (CbC) Reporting lodgements. The good news for all taxpayers is that the ATO granted an extension to lodge the CbC reporting documents by 15 January 2019. This extension applies to companies required to lodge by 31 December 2018. If you need help with your CbC reporting, Master File or Local File.  Feel free to contact our team for assistance.
• 2018 was the 'PCG' year. Yes, the  ATO released a series of  Practical Compliance Guidelines covering the ATO compliance approach on different key transfer pricing topics including:

1. PCG 2017/4 compliance approach to cross-border related financing arrangements.  
2. PCG 2017/1 updated compliance approach to transfer pricing issues related to centralized operating models involving procurement, marketing, sales and distribution functions.
3. PCG 2018 D8 transfer pricing issues related to inbound distribution arrangements

Singapore

• New legislation released In February 2018! that implements mandatory transfer pricing documentation for Companies with significant related party transactions from 2018 (Year of Assessment 2019). Start preparing early to make sure your documentation is ready by the time you lodge the  tax return. You can find in this link the e -tax guide released by the IRAS. 
• Additional requirements to be included in transfer pricing documentation including evidence of the 'substance over form' principle. 
  
• First year of the related party form required to be completed as part of the Company's tax return from Yeas of Assessment 2018  for Companies with significant related party transactions. 

Our New TPS Malaysia Office

We are delighted to announce the opening of our new office, Transfer Pricing Solutions Malaysia. Our new office will help us to better assist all our current and new Malaysian clients or any MNE with operations in Malaysia.  We are excited about our new office located in KL, The Gardens. We are currently working towards launching the TPS Malaysia website in early 2019, stay tuned!

Transfer Pricing Knowledge Sharing

We had a busy year with more than 15 transfer pricing workshops presented in Singapore and Australia. We had more than 300 participants from all over Asia that led to very productive and insightful discussions.  Thanks to all participants that attended our workshops and stay tuned  with more transfer pricing workshops coming in 2019, visit our event page for more information. 

We also participated in Virtual Tax Summit. If you missed our session, you can hear the recording in the following link  https://www.virtualtaxsummit.com/financialtransactions?utm_source=TPS

If you missed any of the events, the ISCA Journal has published summaries of our workshops with the key highlights, you can access the summaries in the links below, happy reading!  

• Busting Services Transactions Myths 
• SIATP Drums to the Beat of Transfer pricing
• Classic TP Hits and Contemporaries
• Don't Trip Over Transfer Pricing Risks
• Rising High Above TP Risks
• Sense and Sensibility of TP Methods

New Team Members

 
As our firm grows, our team is expanding. We welcome three new members of our team from Transfer Pricing Solutions Malaysia our awesome achievement in the year 2018. 

	MunYee was a Transfer Pricing Senior in BDO Malaysia and Crowe Malaysia. She played a role in working closely with the clients in developing the transfer pricing practices in Malaysia. She specialises in the area of transfer pricing where she handles various transfer pricing engagements for companies from a broad range of industries such as mining; electrical and electronics; construction and property development; hotels; real estate; oil and gas; food and beverages amongst others. She has prepared transfer pricing documentation (Master File and Local File) for the Asia Pacific region, in particular, Australia, Malaysia, Singapore and the Philippines. Mun Yee spent her free time playing the piano and practicing yoga. She speaks and writes well in Mandarin, Cantonese and Malay.
	Kaval has more than four years of experience in transfer pricing. Before joining Transfer Pricing Solutions, she was part of the transfer pricing and investigation group in PwC Malaysia and Grant Thornton Malaysia. She has been exposed to various areas of transfer pricing assignments such as transfer pricing documentation, comparability studies, shared costs allocation and Mutual Agreement Procedure (MAP). In her spare time, she enjoys socialising, reading and playing badminton.
	Samuel has two years of experience in transfer pricing. Prior to joining Transfer Pricing Solutions Asia, Samuel was a Transfer Pricing Associate in BDO Malaysia and RSM Malaysia. He has experience with preparation of transfer pricing documentation for Malaysia and has conducted benchmarking studies for a wide array of industries. Samuel is fluent in Mandarin and Malay. In his spare time, he enjoys reading and playing table tennis.