Transfer pricing legislation in Singapore | KPMG | GLOBAL

Singapore: Draft transfer pricing legislation

Transfer pricing legislation in Singapore

Draft legislation has been proposed to amend Singapore’s tax law, to reflect certain transfer pricing requirements.

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Among the proposals are measures that would:

  • Clarify the definition of arm’s length conditions, and allow for a re-characterization of related-party transactions if parties that are at arm’s length would not have entered into similar arrangements
  • Codify requirements that taxpayers maintain contemporaneous and adequate transfer pricing documentation
  • Revise the statute of limitations for the tax authorities to make additional assessments for cases under the mutual agreement procedure (MAP)
  • Clarify that any appeal of an assessment based on a transfer pricing adjustment must be supported by contemporaneous and adequate transfer pricing documentation

The proposed legislation also would provide for a 5% penalty (surcharge) on transfer pricing adjustments made by the tax authorities (beyond existing penalties).

 

Read a June 2017 report [PDF 424 KB] prepared by the KPMG member firm in Singapore

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