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Shih Hui Lee

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Shih Hui Lee has advised on both regional and Singapore tax issues, with focus on advising MNCs on international tax aspects of cross-border transactions. Her practice includes advising clients on tax issues arising from mergers and acquisitions, indirect taxes, transfer taxes, foreign direct investment and cross-border tax planning issues. Prior to joining Baker McKenzie, Shih Hui worked in one of the Big Four accounting firms in Singapore. She has experienced being an in-house regional tax advisor in one of the multinational cable and satellite television channel.

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.

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 this recording of our introductory workshop, Baker McKenzie FinTech Legal Accelerator: Cracking the Legal Code, held as part of the Hong Kong FinTech Week 2020, our lawyers across Asia Pacific give an overview of key fintech issues that start-ups or scale-ups need to know as they grow and expand…

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…