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Government Links
Inland Revenue Authority of Singapore (IRAS)
IRAS Circulars
Transfer Pricing Guidelines for Related Party Loans and Related Party
Services
This
supplementary circular addresses (i) whether interest free loans or
interest-bearing loans not supported by transfer pricing analysis are
acceptable; (ii) whether the application of a 5% mark-up on costs can be
accepted for services rendered to related parties; and (iii) whether
payments for services purchased from another service provider can be passed
through to related parties at no mark-up.
October 21,
2008
Supplementary Administrative Guidance on Advance Pricing Arrangements
This supplementary circular
provides further considerations and procedures that an APA applicant should
observe to facilitate the acceptance by IRAS of an APA application.
October 20, 2008
Transfer Pricing Consultation Circular
This circular states
that taxpayers must "exert reasonable efforts to undertake sound transfer
pricing analysis to ascertain arm’s length pricing and demonstrate that such
efforts have been undertaken.” Lays out steps that IRAS will take to
ensure that companies are complying with the arm's length standard,
including sending out questionnaires to selected taxpayers with related
parties overseas and following up on the questionnaires and determining if a
transfer pricing consultation is required (which includes a field visit to
the taxpayer's location and a review of documentation).
July 30, 2008
Transfer Pricing Guidelines Circular
Circular provides
comprehensive guidance on transfer pricing, including documentation
requirements and advance pricing agreements (APAs). The transfer pricing
guidance in the circular concerns both local and cross-border transactions
between a Singapore taxpayer and its related parties. The guidance on
mutual agreement procedures and APAs pertains to related-party transactions
when at least one party is resident in Singapore or a jurisdiction with
which Singapore has a comprehensive double tax agreement.
February 23, 2006
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