Singapore: Revised transfer pricing guidelines | KPMG | US

Singapore: Discussion of revised transfer pricing guidelines

Singapore: Revised transfer pricing guidelines

Legislative requirements concerning the transfer pricing rules were expanded in Singapore’s income tax law in October 2017, and then followed by the introduction of transfer pricing documentation rules and the release of the fifth edition of an “e-tax guide” from the Singapore Inland Revenue Authority (IRAS).

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Changes in the fifth iteration of the e-tax guide on transfer pricing concern:

  • Expanded arm’s length conditions
  • Enhanced guidance on conducting comparability analysis
  • Authority granted to IRAS to characterize transactions and make transfer pricing adjustments
  • Transfer pricing documentation rules
  • Surcharges and penalties for noncompliance

The guidance also provides clarity on the transfer pricing rules for permanent establishments, on the availability of the mutual agreement procedure (MAP) process, and the treatment of re-financing arrangements. It is clearly stated that the transactional profit split method is not to be applied when the contribution of at least one party to the transaction can reliably be evaluated through another transfer pricing method.

 

Read a March 2018 report [PDF 141 KB] prepared by the KPMG member firm in Singapore

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