The Inland Revenue Authority of Singapore (“IRAS”) has issued transfer pricing guidance for centralized activities of multinational enterprise (“MNE”) groups in Singapore to assist taxpayers in analysing such activities between related parties and identifying factors that may affect transfer prices for these activities and the transfer pricing methods that may be appropriate.

The guidance (in the form of a so called e-Tax Guide, which the IRAS issues from time to time in order to express its views and policies on certain matters to taxpayers) is important considering that Singapore is being adopted as a destination by a significant number of MNEs for housing their global as well as regional headquarters (“HQ”). The e-Tax Guide aims to analyse potential inter-company transactions that may be carried out by MNEs through their Singapore-based HQ and discusses the approach to determine the arm’s length price in respect of such transactions.


Continue Reading Singapore’s Transfer Pricing Guidance for Centralized Activities of MNEs

The Inland Revenue Authority of Singapore (“IRAS”) has issued transfer pricing guidelines for companies affected by the COVID-19 pandemic, which includes guidance on documentation requirements, term-testing for related party transactions and Advance Pricing Arrangements (“APA”).

Continue Reading Singapore’s Transfer Pricing Guidelines for COVID-Affected Businesses