Foreign Subsidiaries

IndustriesForeign Subsidiaries

Foreign Subsidiaries

Do you have all the necessary transfer pricing policies and risk assessments in place for the intercompany related party transactions of your foreign subsidiaries?

Ask us how we can assist you with:

  • Transfer pricing planning and implementation of new business structures
  • Preparation of transfer pricing documentation, Master File and Local File
  • BEPS and Country by Country Reporting implementation
  • Development and review of transfer pricing policy
  • Transfer pricing risk reviews, APAs and audit defense
  • Benchmarking studies covering all types of transactions and regions with access to databases
  • Preparation and review of intercompany agreements
  • Fast-track intercompany agreement drafting 
  • In-house transfer pricing workshops and training sessions
  • In-house transfer pricing advisory


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2 Jul

OECD Rewrites the Rules on Intra-Group Services

On 1 June 2026, the OECD released a public consultation draft revising Chapter VII of the OECD Transfer Pricing Guidelines – the chapter dealing with intra-group services. The draft is extensive but does not change the underlying arm’s length principles.


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2 Jul

Updates to the Singapore ETax Guide - 9th Edition

The Inland Revenue Authority of Singapore (IRAS) released the 9th Edition of the Singapore Transfer Pricing Guidelines (TPG) on 4 June 2026. The update introduces targeted clarification on the treatment of share‑based compensation (SBC) in the context of intercompany services arrangements remunerated on a cost‑plus basis.


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3 Jun

IFA APAC Conference Tokyo, Japan 2026

Adriana Calderon, Managing Partner - Asia & Malaysia at Transfer Pricing Solutions, shares insights from the IFA APAC Conference in Tokyo, highlighting key trends in transfer pricing across Asia. She explores regional differences in approach, increasing regulatory complexity, and rising audit activity, while reflecting on the importance of global networks in fostering collaboration and shaping the future of international tax.


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