Read the latest update by our Asia Director, Adriana Calderon. Adriana has extensive international experience with #BigFour and mid-tier firms advising #multinational companies in the areas of corporate and #international taxation across South America, the US, Australia and the Asia Pacific Region.
Singapore is often a preferred location for setting up headquarters as the door to conduct business in Asia. The IRAS has released its views on how Singapore HQ's should plan and implement their transfer pricing framework. Want to know more? Read our article with our views on IRAS TP Guidelines for Singapore HQs.
The Malaysian Finance Bill 2020 incorporates transfer pricing-related changes to the current Income Tax Act, 1967 (“ITA”). The changes permit significantly greater authority to the Malaysia Inland Revenue Board (“MIRB”) and re-emphasises the importance of transfer pricing compliance, with effect from 1 January 2021.
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?