International review for September 2021

Transfer pricing

New transfer pricing guidelines published by the Inland Revenue Authority of Singapore (IRAS) consolidate four earlier tax guides. In addition there are also some new important updates that those with operations in Singapore should take note of. Of particular note is the change from the previous transfer pricing ‘consultation’ process to a transfer pricing audit. The move from ‘consultation’ to audit suggests that IRAS may take a stricter approach to non-compliance going forward; something that groups should make sure they are well prepared for and ensure they have adequate defence files in place.

Also new is guidance on benchmarking interest rates on intercompany loans and further guidance on the levy of a surcharge where transfer pricing adjustments are made following a transfer pricing audit. According to the new guidance a surcharge will be imposed...