The Ministry of Finance on 16 June 2016 announced that Singapore has become the latest participant to the OECD’s inclusive framework for the implementation of measures against base erosion and profit shifting (BEPS). By joining the inclusive framework, Singapore’s participation puts a spotlight on transfer pricing with its announcement to implement country-by-country (CbC) reporting.
Singapore’s CbC reporting requirements will apply to multinational entities whose ultimate parent entity is in Singapore, and whose group turnover exceeds SGD 1.125 billion (equivalent to the threshold of €750 million specified by the OECD). These entities will be required to file their CbC report with the Inland Revenue Authority of Singapore within 12 months from the last day of the financial year. The CbC reporting requirements will apply to multinational entities whose financial years begin on or after 1 January 2017, with the first wave of Singapore CbC reports due by 31 December 2018.
Singapore has consistently advocated the use of the internationally sanctioned arm’s length principle as the foundation for transfer pricing. The implementation of CbC reports strengthens Singapore’s commitment to the transparency required, and is intended to determine that multinational entities’ profits are taxed in the jurisdiction where economic activities take place and value is created. Taxpayers with group turnovers exceeding or nearing the specified threshold need to be “CbC-ready” given the lead time before implementation. As a starting point, taxpayers need to review and consider whether the information required in the CbC reporting template (as released by the OECD) is readily available. Due to the complexities of business structures and differences in accounting standards/systems, there may be challenges in gathering the required information. Taxpayers need to consider starting the process as early as possible, such as conducting a “dry run” of the CbC report to identify any difficulties upfront.
Read a June 2016 report [PDF 241 KB] prepared by the KPMG member firm in Singapore