Final OECD Transfer Pricing Guidelines on Financial transactions, What are the key changes?
The Organisation for Economic Co-operation and Development (OECD) has released in February 2020 the final Transfer Pricing Guidance on
Financial Transactions (Guidance). The Guidance provides an insight on the arm’s length treatment of various financial transactions among
Philippines’ new transfer pricing guidelines may impact you
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
Transfer Pricing for Commodity Entities - What type of trader is your company?
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.
The #TPS WAY of Doing Business – What can we learn from COVID 19 crisis?
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.
What can companies do to manage their Transfer Pricing Risks in time of crisis?
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.
Singapore Compulsory Transfer Pricing Documentation and Non-Compliance Penalties
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.
Did you know that Malaysia increased penalties for taxpayers that do not prepare Transfer Pricing Documentation?
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.