The Inland Revenue Authority of Singapore (IRAS) published the third edition of the e-Tax Guide on the transfer pricing guidelines on 4 January 2016.
The latest changes are summarized as follows:
- Amended guidance on the cost-plus method (CPM); and
- Guidance on developments in the mutual agreement procedure (MAP) and advance pricing arrangement (APA) process.
There are also various amendments to the e-Tax Guide to reflect the enriched APA process:
- Taxpayers should submit a formal application to the IRAS within 3 months from the receipt of IRAS’ indication that the APA application can be submitted; and
- For bilateral and multilateral APAs, where the filing deadline imposed by a foreign competent authority is earlier than that of IRAS, taxpayers should observe the earlier filing deadline.
The earlier filing deadline will not, however, affect IRAS’ consideration and observation of the timeline under its APA process.
