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.
From November 2020 to April 2021, there have been three reported decisions by the High Court and Court of Appeal involving tax controversies with the Inland Revenue Authority of Singapore. Two of these decisions involved disputes under the Income Tax Act. The final case relates to a decision concerning the assessment of property tax, and the interpretation of certain terms under the Property Tax Act.
From November 2020 to April 2021, there have been three reported decisions by the High Court (HC) and Court of Appeal (CA) involving tax controversies with the Inland Revenue Authority of Singapore (IRAS). Two of these decisions by the HC involved disputes under the Income Tax Act (ITA). The first case pertained to the application of the general anti-avoidance provision in s 33 of the ITA, and the second case concerned the taxability of an employee’s severance payment under s 10(2)(a) of the ITA.
In brief On 15 June 2020, the Economic Expansion Incentives (Relief from Income Tax) (Amendment) Act 2020 came into force. Among other legislative changes, the key amendments provide an avenue for the Pioneer Industry, Pioneer Service and Development and Expansion Incentive awards previously approved and granted to a company to…