What You Need to Know About the New Singapore Transfer Pricing Guidelines (Sixth Edition)

Impact and challenges of the new TPG6

Impact and challenges of the new TPG6

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While the gaze of the world is fixed on the OECD and the rapid international developments brought about by BEPS 2.0, national tax authorities are also updating their local transfer pricing guidance to keep pace. Three and a half years after the last edition was published, the Inland Revenue Authority of Singapore (“IRAS”) released the latest edition of the Singapore Transfer Pricing Guidelines (Sixth Edition) (“TPG6”) on 10 August 2021.
 
TPG6 takes into account some of the major OECD developments as well as IRAS’ audit experience over the last few years. It reinforces IRAS’ commitment to the arm’s-length principle and the concept of aligning transfer pricing outcomes with value creation. In particular, TPG6 builds on the previous guidelines by providing expanding coverage on numerous areas, including the following:
 
  • Ongoing focus that taxpayers need to have on their transfer pricing documentation;
  • Expanded guidance on intra-group services including the treatment for OECD low value adding services;
  • Extensive enhancements on the guidance for intra-group financial transactions (which incorporates the concepts from the OECD paper on financial transactions) as well as introducing the concept of quasi-equity;
  • New detailed guidance on Cost Contribution Arrangements;
  • Clarification on the application/remission of the IRAS surcharge on transfer pricing adjustments;
  • Guidance on arbitration as a form of dispute resolution; and
  • General FAQs on preparing transfer pricing documentation and applying for Advance Pricing Arrangements.

Join us for a discussion on the new guidance and the impact on MNCs operating in Singapore. In addition, we will also discuss the importance and the challenges of reviewing existing/new transfer pricing policies, given the expanded requirements in TPG6 and the international changes on the horizon.

We hope you will be able to join us at this live webinar and we thank you for your support.


Date
Thursday, 02 September 2021

Time
10:30 am - 12:00 pm

Duration
1 hour 30 minutes

Venue
Live Webinar

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