Transfer pricing (TP) has been a mainstay in the international tax scene ever since it was catapulted into the limelight by the
Organisation for Economic Co-operation and Development (OECD)’s Base Erosion and Profit Shifting (BEPS) project back in 2013.
As the OECD presses on with its two-pillar solution under the new BEPS 2.0 initiative, TP is set to dominate the international tax agenda for years to come.
Earlier this year, the Inland Revenue Authority of Singapore (IRAS) published a specific guidance for multinational enterprise (MNE) groups with centralised activities in Singapore, and subsequently updated its TP guidelines.
At a webinar organised by the Singapore Chartered Tax Professionals, Adriana Calderon, Director, Transfer Pricing Solutions Asia, zoomed in on the key TP issues that Singapore-based headquarters (HQs) should take note of.
TP Methods, Documentation and Disputes
Against the challenging international backdrop, the TP environment is no doubt tougher than ever and will only get more intense going forward. It is therefore crucial for MNE groups and Singapore HQs to actively manage their growing TP risks by reviewing their existing TP processes and practices, as well as evaluating the adequacy of their TP documentation.
This article is intended for general guidance only. It does not constitute professional advice and may not represent the views Transfer Pricing Solutions Asia, the facilitator or the SCTP. While every effort has been made to ensure the information in this article is correct at time of publication, no responsibility for loss to any person acting or refraining from action as a result of reading this article or using any information in it can be accepted by Transfer Pricing Solutions Asia, the facilitator or the SCTP.
We can assist your clients with the planning and preparation of transfer pricing documentation, country by country (CbC) reporting, comprehensive transfer pricing policy, performing global and local benchmarking comparable searches, providing training designed for CFOs and tax teams and performing transfer pricing controversy and audits.
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The transfer pricing landscape in Asia is expected to undergo significant changes in the coming years.