Summary of PKF Transfer Pricing webinar conducted on 04 June 2025

Topic: “ALP requirements for intercompany loans and importance of DEMPE analysis for intangibles”

With the emergence of various intercompany financial transactions over the last decade, most of the tax jurisdictions across the world have updated their local Transfer Pricing guidelines, with an increased and stringent focus on Arm’s Length Price compliance requirements for such transactions.

Moreover, intercompany sharing and transfer of intangibles has also gained significant momentum due to new business strategies being adopted, revised business models being thought of and due to the close integration of economies, which makes the concept of DEMPE analysis more relevant and critical for Transfer Pricing purposes.

Keeping into consideration the above, PKF Singapore recently hosted a webinar on 4th June 2025 to discuss and explain the key arm’s length price requirements for intercompany loans and for intangible related transactions, including the concept of DEMPE analysis along with the underlying concepts.  

The speaker - Mr. Sahil Seth (Director, Transfer Pricing – PKF Singapore) firstly explained the concept of an intercompany loan along with the 3-step detailed approach to appropriately delineate and analyze whether a purported loan is a loan or is a contribution to equity capital or any other payment.

He also explained the key issues involved, especially highlighting the point that with effect from January 2025, any interest-free related party loan will not be considered as an arm’s length transaction and what are the potential consequences if an intercompany loan is not at arm’s length.

Thereafter, Sahil also explained the definition of an intangible, types of intangibles involved in a Transfer Pricing context and what are the significant issues/challenges involved in the case of intangibles.

Moving forward, he then explained the nuances of DEMPE analysis and its importance in the case of intercompany transactions involving intangibles. 

Towards the end, he explained the Transfer Pricing compliance requirements for intercompany loans and intangibles while emphasizing on the key takeaways. 

Finally, the floor was open for a Q&A session and many of the attendees had several questions which were all addressed by the speaker before concluding the webinar.

At PKF, we have a dedicated team of global TP experts and specialists based out of all the major countries of the world, who have rich and significant experience spread across different industries and sectors. Our team can provide all the necessary assistance and support in terms of TP compliance, advisory, dispute prevention and dispute resolution, in accordance with the local rules and regulations as well as the global TP principles and standards prescribed by the OECD. 

Missed the webinar? Watch our webinar recording here