The Inland Revenue Authority of Singapore (IRAS) publishes revised transfer pricing (TP) guidelines on 6 January 2015.

The 2015 TP Guidelines are generally in line with the OECD Transfer Pricing Guidelines (2010) as well as some relevant areas of the Base Erosion and Profit Shifting (BEPS) initiative.

This e-Tax Guide contains the following main parts:

Part I – Transfer pricing principles and fundamentals which provide guidance on the arm’s length principle and transfer pricing documentation requirements.

Part II – Transfer pricing administration

The section on TP Consultation (TPC) has been updated to include a flowchart of the TPC process, and the “outdated” TP Questionnaire has been removed. The TP Guidelines also provide detailed step-by-step procedures for the mutual agreement procedure (MAP) and advance pricing agreement (APA) processes. Samples of documents such as the letter of authority and an APA are available in the annexes, as well as the minimum information required for pre-filing meetings and guidance on the annual compliance report for APA purposes.

Part III – Other following issues:

(a) TP adjustments and also Part III includes a section on IRAS’ position on the various types of adjustments relating to TP;

(b) Related party services;

 (c) Related party loans and

 (d) Attribution of profit to permanent establishment.

The 2015 e-Tax guide has a new section on IRAS’ position regarding the attribution of profits to a permanent establishment (PE).