The Inland Revenue Authority of Singapore (‘IRAS’) updated its transfer pricing guidelines on 10 August 2021, with the release of the IRAS e-Tax Guide: Transfer Pricing Guidelines (Sixth Edition).. IRAS has provided additional guidance and clarification with respect to TP documentation compliance, surcharges on TP adjustments, advanced pricing arrangements and mutual agreement procedure requests.

Due to the strategic location and the business-friendly environment that Singapore offers, many multinational enterprise (MNE) groups have centralized operations in Singapore, and they often function as the global/regional headquarters (HQ) of the MNEs. With increasing focus on these structures and the associated transfer pricing arrangements (both domestically and overseas), the Inland Revenue Authority of Singapore (IRAS) published an e-tax guide entitled “Transfer Pricing Guidelines Special Topic – Centralized Activities in Multinational Enterprise Groups” (“Guide”) on 19 March 2021 to provide administrative guidance on determining an arm’s length remuneration for centralized activities in Singapore.

In this alert, we discuss the Guide, and provide transfer pricing insights for HQs located in Singapore.

In brief The State Administration of Foreign Exchange (SAFE) recently released the Service Trade Foreign Exchange Management Policy Q&A (part 2)1. SAFE provided clarifications on the bank procedures for processing foreign exchange payments and receipts for transfer pricing (TP) adjustments (hereinafter referred to as “Clarification”). Contents Key takeaways Background Overview…

In brief The State Administration of Foreign Exchange (SAFE) recently released the Service Trade Foreign Exchange Management Policy Q&A (part 2)1. SAFE provided clarifications on the bank procedures for processing foreign exchange payments and receipts for transfer pricing (TP) adjustments (hereinafter referred to as “Clarification”). Contents Key takeaways Background Overview…