Home        About Us        Our Services        TP News        Contact Us
IC Advisors Transfer Pricing Newsletter



Jan 2018
Feb 2018

Singapore’s transfer pricing regime.

IC Advisors Transfer Pricing Newsletter
March 2018

Singapore releases the 5th edition of its Transfer Pricing Guidelines

The Inland Revenue Authority of Singapore (“IRAS”) released the 5th revision of the Singapore Transfer Pricing Guidelines on 23rd February 2018.  These revised guidelines provide the Singapore tax community with further understanding of the implementation of the amended transfer pricing legislation, which came about as a result of the Income Tax (Amendment) Bill 2017 and as well as the gazetted Income Tax (Transfer Pricing Documentation) Rules, hereafter referred to as the Rules 2018.  These guidelines and legislation are effective from Year of Assessment (“YA”) 2019. 

For additional information, please refer to our dedicated Singapore Transfer Pricing Update.

OECD announces the release of additional guidance on implementation of country-by-country (CbC) BEPS Action 13.

The OECD released further guidance on Country-by-Country reporting, addressing the definition of total consolidated revenue and issues relating to confidentiality and the appropriate use of information. It also compiled the approaches adopted by member jurisdictions of the BEPS Inclusive framework in dealing with issues that arise when the guidance allows for alternative approaches.

The Inclusive Framework for BEPS also approved updates to the results for “preferential tax regime” reviews by the Forum on Harmful Tax Practices (FHTP) in connection with BEPS Action 5.

Malaysia updates APA and MAP Rules to meet the latest BEPS Standards

The Malaysian Inland Revenue Board (MIRB) released an amendment to the 2012 Advance Pricing Arrangement, known as the Income Tax (Advance Pricing Arrangement) (Amendment) Rules 2017. The rules have come into operation from 1st January 2018. They key amendment is the insertion of Rule 23, which allows MIRB to charge an application fee and any expenses as the Director General may determine over the course of the APA arrangement.

MRIB has also released an updated version of the Mutual Agreement Procedure (MAP) Guidelines. The first guidelines were announced in January 2015, and subsequently updated to meet BEPS Action Plan 14 minimum standards. The updated guidelines provide procedural updates for taxpayers looking to file for an MAP, for example, the need for a pre-filing meeting, circumstances where the MAP would not be eligible, etc.

The revised updates provide additional guidance to taxpayers who may be interested in obtaining an APA/ MAP.  However, taxpayers are required to carefully consider the additional expenses that they may incur as a result of Rule 23. 

Upcoming seminars:

Dr Sowmya Varadharajan will be presenting at the following full day seminars:

  1. Transfer Pricing – A regional perspective, on 15th February 2018, organised by Singapore Business Federation
  2. Managing Transfer Pricing, on 19th April 2018, organised by Takx Solutions Pte Ltd
  3. Singapore Transfer Pricing Guidelines: Recent Updates and Compliance Management, on 26th April 2018, organised by CCH – Wolters Kluwer

If you would like to attend any of these seminars, please send an email to sowmya@icadvisorsasia.com

Home    |    About Us    |    Our Services    |    TP News    |    Contact Us
Hand-crafted by the Breworks Design & Communications
© 2013 IC Advisors / All rights reserved / Privacy Policy