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JobKeeper Impact on Transfer Pricing for Companies
JobKeeper forms part of taxable income in the tax return. Makes sense, it is a subsidy against wages, so I am sure there are no surprises
there, but how do you assess the arm’s length financial outcomes of the entity for transfer pricing purposes?
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.
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.
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
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.
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.
Transfer Pricing IRAS Update - Indicative margins for related party loan
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.
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
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.
This year, TP Minds will be held for three days from24-26 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.
Do you have operations in Thailand? Thailand’s new transfer pricing legislation may impact you!
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.