All you need to know about transfer pricing documentation.
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?
Transfer Pricing is one of the key tax requirements to consider when expanding your business outside Singapore. Operations in more than one country (at least two countries) is sufficient for a business to be caught up under the transfer pricing regulations.
COVID 19 Singapore Transfer Pricing Guidelines will help taxpayers to manage their transfer pricing risks caused by COVID 19, we have summarised our key practical tips in this blog.
Achieving tax excellence is not just about practical insights to manage the complexities, it is also very much about having a strong grasp of fundamentals to ensure a strong foundation.
As Transfer Pricing (TP) continues to be at the frontline of tax issues that companies with related party transactions face, it is vital to have a solid grasp of TP fundamentals.
Did you know Singapore introduced compulsory transfer pricing documentation from the year of assessment (YA) 2019? A simple solution is to comply with the transfer pricing obligations in Singapore!
There are many misconceptions and myths with regards to transfer pricing practices around the world.
Singapore introduced compulsory transfer pricing documentation effective from the year of assessment (YA) 2019. A new penalty regime was also included for non-compliance with the TP documentation requirements.
We are thrilled to announce that Transfer Pricing Solutions is shortlisted for the International Tax Review Asia Tax Awards 2020 with several nominations.
The Inland Revenue Authority of Singapore (IRAS) recognises the diversity in the commodity marketing/trading (CMT) activities undertaken by CMT entities in Singapore and the wide-ranging values they could bring to their multinational enterprise (MNE) group.
Transfer Pricing Solutions are thrilled to have won the Fast-Growing Firm of the Year award at the Australian Accounting Awards 2020!
The COVID-19 crisis has provoked an unprecedented shift toward working from home (#WFH), and for businesses to implement tools and resources allowing employees to work from home and look after their customers as seamlessly as possible.
Due to the depth of its trading market and its close proximity to key markets, Singapore has been the preferred location for commodity marketing and trading activities.
The Organisation for Economic Co-operation and Development (OECD) has released in February 2020 the final Transfer Pricing Guidance on Financial Transactions (Guidance). With the Guidance in place, the OECD expects to see significant progress by multinationals in updating their existing transfer pricing policies on financial transactions to be in compliance with the Guidance.
Do you have business in the Philippines? In August 2019, the BIR issued Revenue Audit Memorandum Order No. 1-2019
(“the TP Audit Guidelines”) to introduce standardised audit procedures and techniques applicable to taxpayers with related party
transactions.
How do companies benefit from our business model? Why the #TPSWAY of doing business is different?
COVID 19 crisis provoked an unprecedented shift toward working from home (#WFH), and business is implementing tools and resources to allow the employees to work from home and look after their customers as seamless as possible.
Do you want to know about transfer pricing for commodity traders? This article will give you an overview about transfer pricing for commodity trading companies with operations in Singapore
In light of the recent outbreak of Covid-19, which is now known as a global pandemic threat, has jeopardized businesses significantly across the globe. Businesses of various industries are expected to lose billions of revenues.
In a digitalised era, businesses can develop an active and sustained engagement in a market jurisdiction, beyond the mere conclusion of sales, without necessarily investing in local infrastructure and operations. Hence, the allocation of taxing rights can no longer be exclusively circumscribed by reference to physical presence.
Intangible properties (“IPs”) has become the main driver of business profits within Multinational Enterprises (“MNEs”) especially in the digital economy ecosystem.
On 15 December 2019, the Malaysian Inland Revenue Board (“IRB”) issued the updated Tax Audit Frameworks including Transfer Pricing (“TP”) Audit Framework 2019. The updated tax audit frameworks take effect from 15 December 2019.
Inland Revenue Authority of Singapore (“IRAS”) has introduced the indicative margins for related party loans since the past few years whereby the indicative margins are updated at the beginning of each calendar year.
The introduction of Earning Stripping Rules (“ESR”) limiting the interest deduction for financial assistance between related persons were announced in the Budget 2018.
Equip your employees with relevant skills imparted by our team of professional trainers.
On 01 November 2018, the Inland Revenue Board of Malaysia (“IRBM”) had a dialogue session with the Chartered Tax Institute of Malaysia (“CTIM”)’s Technical Committee on the updated version (mainly from Chapters II to XI) of the Malaysian Transfer Pricing Guidelines (“TP Guidelines”)
With the recent focus on profit shifting around the world, guidance on profit split method has revised by Organisation for Economic Co-Operation and Development (“OECD”) in June 2018. OECD published the “Revised Guidance on the Application of the Transactional Profit Split Method” under Base Erosion Profit Shifting (“BEPS”) project - Action 10.
On 13 July 2018, Hong Kong’s new transfer pricing regime was enacted through the Inland Revenue (Amendment) (No. 6) Ordinance 2018 (“Amendment Ordinance”). This new law codifies transfer pricing rules in Hong Kong and is largely consistent with the OECD transfer pricing guidelines.
The TP Minds Asia is a leading independent #transferpricing forum in Asia Pacific region which is held in Singapore from 25 to 26 September 2019.
This year, TP Minds will be held for three days from 24-26 September 2019 in the Novotel Singapore Clarke Quay. The agenda is packed with a number of hot #transferpricing topics that will be discussed by key TP leaders.
On 16 May 2002, the Revenue Department introduced its transfer pricing guidelines in the form of Departmental Instruction (“DI”) No. Paw. 113/2545. The purpose of the transfer pricing guidelines is to assist taxpayers in setting arm’s-length prices for their transactions with related parties while providing direction to revenue officers in reviewing whether taxpayers’ related party transactions are in compliance with the arm’s-length principle.
The transfer pricing team's trip to Australia has been amazing and productive.
This time, the Transfer Pricing Solutions team flew from India, Malaysia and Singapore to our Head Office in Mornington, Australia. There were a number of activities/events arranged for us apart from the usual work routine.
International Tax Review (ITR) Asia’s Tax Forum is a leading independent tax forum in the Asia Pacific region. The 14th Asia Tax Forum organised by the International Tax Review, a premier event in the region for taxpayers, officials ad practitioners, will be held in Marina Mandarin Singapore on May 8th and 9th 2019.
Being associated with you makes us proud. Your contribution and your commitment to our work are unmatched. Without you, this journey would
have been impossible. Have a happy work anniversary!
From Transfer Pricing Solutions Staff Team
On 26 December 2017, Malaysia Inland Revenue Board (“IRB”) gazetted the Country-by-Country reporting (“CbCR”) regulations for
Labuan entities.
The implementation of CbCR will take effect for the financial year starting on and after 1 January 2017. On 1 January 2019, IRB published
CbCR Guidelines for Labuan entities.
ATO released the initial Practical Compliance Guide (PCG) 2017/1that sets out the ATO’s compliance approach to transfer pricing issues related to centralised operating models (known as "hubs") involving procurement, marketing, sales and distribution functions.
Digital transformation has contributed significant changes to the world, changing the nature of the business and the industry value chain, even the way people interact with each other. Intangible Properties ("IPs") have become the main driver of business profits within Multinational Enterprises ("MNEs") especially in the digital economy ecosystem.
I Love My Team Malaysia!
"Alone we can do so little; together we can do so much"
"The harder you work for something, the greater you will feel when you achieve it"
Transfer Pricing Solutions Asia made it to the ITR Tax Asia Awards 2019, we are nominated as Singapore Transfer Pricing Firm of the Year for
2019.
Tax authorities worldwide are increasing their focus on companies involved in commodity transactions as a result of the introduction of new guidance on commodity transactions by the OECD in 2015 and the number of court cases involving companies in the mining industry worldwide.
With the increasing scrutiny from the Australian Taxation Office (“ATO”) in transfer pricing matters over the recent years, the burden and cost of compliance are taking its toll on taxpayers, particularly, the small to medium businesses.
To all of our accounting firm clients and potential clients, we wanted to alert you to the round of "Failure to lodge" notices that the ATO is now issuing. We recently received one from an accounting firm who as you can imagine, called us in absolute panic! The failure to lodge was for $525,000 penalty!!! Ok, I think I have your attention now!
In 2018, the Inland Revenue Authority of Singapore amended the Income Tax Act to enforce Mandatory Transfer Pricing Documentation for Singapore Taxpayers. Is the new TP Documentation a real game changer?
With transfer pricing being the talk of the town, there is no time like the present to build up an arsenal of knowledge to power through TP documentation.
If you are an Entrepreneur, Start-Up or SMEs don’t disregard transfer pricing and fall under the trap of thinking that transfer pricing affects large MNEs only.
In today’s global business environment, it is commonplace for multinational enterprise (MNE) groups to provide a wide array of intra-group services for various strategic reasons. These services may range from routine administrative services to other specialised services such as financial, marketing, technical or research and development (R&D) services
Moving past the fundamentals, various myths on intra-group services transactions were busted. Participants attained valuable knowledge and insights through various illustrations, and walked away with the ability to better manage their organisation’s TP affairs.
Is your Company subject to transfer pricing in Malaysia? Our article summarises key considerations to ensure compliance with transfer pricing in Malaysia
The challenge has been thrown down. How do we best simplify key points around transfer pricing? We think we’ve found the answer. Pizza. (Stay with us!) If transfer pricing was a pizza, what would be the main ingredients to consider?
The benchmarking analysis is the backbone of a transfer pricing analysis, benchmarking analysis that is reliable and defendable is key when preparing transfer pricing documentation.
Is your benchmarking analysis reliable?
With the revised e-Tax guide published, SIATP also jointly organised a session with the Inland Revenue Authority of Singapore on possibly the topic that has been the talk-of-the-year for both tax professionals and business executives –TPD.
Grab a coffee and relax watching #5MinutesTP Episode 2 , All you need to know about #transferpricing documentation?
Bringing light to the many facets of business issues companies face that potentially pose a risk to their overall TP framework were the objectives of the Singapore Institute of Accredited Tax Professionals’ Tax Excellence Decoded session titled “Don’t Be Tripping Over Transfer Pricing Risks”.
Do you want to hear from key transferpricing leaders the latest transfer pricing trends? Come and join TPMinds Australia the largest TP Conference in the region.
Grab a coffee and relax watching #5MinutesTP Episode 1 , Why should companies care about #transferpricing?
The Indonesian transfer pricing landscape continues in turmoil, where Companies are struggling to understand and comply with the latest released regulation No. 213/PMK.03/2016 (“PMK-213”).
As tax authorities around the world continue to focus on transfer pricing (TP), companies must stand ready to defend their TP positions to avoid potential adjustments or penalties arising from TP audits. Maintaining adequate contemporaneous TP documentation is often the key.
Lodgement date for CbC Reporting has been extended to February 2018, does your Company need to complete CbC Report, Master File, Local File in Australia?
Unsure on whether your company is pricing services transactions correctly? This article will give key insights on how to price services correctly
Unsure where to start with BEPS Country by Country Reporting? This article explains all you need to know about CbC reporting requirements in Australia.
Good news! Two prestigious awards won - Asia Best Newcomer of the Year and Asia Transfer Pricing Practice Leader of the Year.
Our nominations for 2017 are Boutique Firm of the Year, Partner of the Year (Boutique) - Shannon Smit, and Thought Leader of the Year - Shannon Smit
Intra-group service transaction is an easy target for transfer pricing adjustment. Two steps to make sure you price them correctly.
Want to know more about how to perform a benchmarking? Read this excellent article published by ISCA Journal, March 2017 edition. Get a copy now, link to article is available in the blog.
Traditionally a preferred transfer pricing method as it is the most direct and reliable way to apply the arm's length principle. But what are the Pros/Cons of applying the CUP method?
New Guidance from the ATO about Australia’s Simplified Transfer Pricing Record Keeping Options, how does it impact your Company?
Australia Transfer Pricing Firm of the Year • Singapore Transfer Pricing Firm of the Year • Best Newcomer of the Year, Transfer Pricing Solutions Asia • Asia Transfer Pricing Practice Leader of the Year, Shannon Smit
On Monday 20 February, the Finance Minister Heng Swee Keat delivered in Parliament Singapore’s 2017 budget. With the tax authorities currently focusing on transfer pricing and the implementation of BEPS action plan, a few of the new measures will impact taxpayers and their related party dealings during 2017.
On January 2016, the ATO released new compliance approach to transfer pricing issues related to centralised operating models (hubs) involving procurement, marketing, sales, and distribution functions. This Practical Compliance Guideline (“PCG”) 2017/1 comes into effect from 1 January 2017 and will apply to existing and newly created hubs.
On 12 January 2017, the IRAS released the 4th edition of its Transfer Pricing Guidelines. We have summarised the key changes that can impact your Company.
The challenge has been thrown down. How do we best simplify key points around transfer pricing? We think we’ve found the answer. Pizza. (Stay with us!) If transfer pricing was a pizza, what would be the main ingredients to consider?
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