Observations, comments and key takeaways on the expanded requirements under TPG2.
On 6 January 2015, Inland Revenue Authority of Singapore (IRAS) released revised transfer pricing guidance in the form of a substantive e-Tax Guide -- Transfer Pricing Guidelines (Second Edition) ("TPG2"). TPG2 is an amalgamation and expansion of various aspects of IRAS’ position with regard to various transfer pricing items and concepts as detailed in IRAS’ previous transfer pricing guidance. These include amongst others, the definition of "contemporaneous documentation", insights on the use of various transfer pricing methods and profit level indicators (e.g. Berry Ratio), transfer pricing audit and selection of taxpayers for audit, etc.
In February 2015, KPMG in Singapore organized a series of breakfast seminar sessions on TPG2 . The following is the link to the presentation slides for the breakfast seminar sessions. The slides include KPMG Singapore’s observations, comments and key takeaways on the expanded requirements under TPG2.
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