The OECD guidance emphasised that, besides interest rates, all terms and conditions of the financing transactions (including the volume of debt) should be tested against the arm’s length principle.
Are your controlled transactions in line with the transfer pricing legislation? Mistakes in pricing will roll over from year to year. It is crucial to identify mispricing as soon as possible to better manager the transfer pricing risk.
A US multinational company with subsidiaries around the world, including Singapore, recently prepared new US transfer pricing documentation.
The company applies their transfer pricing policies on a global basis. The US tax director instructs the Singapore tax director to use this documentation. Is the US documentation acceptable in Singapore?