All you need to know about transfer pricing documentation.
This article will provide an overview of what global minimum tax is, why it's important, and how it impacts multinational corporations and the global economy.
This article will explore the history of global minimum tax policies, from their origins to the latest developments, including the recent OECD/G20 agreement.
This article will discuss how technology can help multinational corporations streamline their global minimum tax compliance.
This article will discuss how global minimum tax policies affect multinational corporations, including changes to their tax planning strategies and compliance requirements.
This article will provide an overview of the legal and regulatory considerations that multinational corporations need to be aware of when dealing with global minimum tax.
This article will provide practical advice for multinational corporations on how to navigate the complexities of global minimum tax compliance.
This article will speculate on the future of international taxation in light of global minimum tax policies, including potential trends and challenges that may arise.
This article will examine the challenges and opportunities that global minimum tax policies present for developing countries, including their potential impact on tax revenue and economic development.
Are your financing terms optimized and aligned with the economic reality of your transactions?
Inland Revenue Authority of Singapore (“IRAS”) offers a Voluntary Disclosure Programme (“VDP”) help taxpayers rectify these errors and minimize potential penalties.
Not all services are created equal. Identifying low-value and high-value services within your intra-group transactions is a fundamental distinction.
The world of transfer pricing can be a complex and sometimes treacherous one, especially when disputes arise.
Global Minimum Tax (GMT) is one of the largest tax reformations as part of the initiative under Pillar 2 of the Base Erosion Profit-Shifting (BEPS) 2.0 project.
On 19 February 2024, OECD published the final report on Pillar One -Amount B, is designed to simplify and streamline the application of the arm’s length principle.
With increasing scrutiny, transfer pricing audits are becoming more common. Failure to comply with documentation requirements can lead to significant penalties.
We are thrilled to share that Adriana Calderon, Director of Transfer Pricing Solutions Asia, has been appointed by ISCA as a Transfer Pricing Roundtable Representative for SCTP.
The IRBM has recently issued a Frequently Asked Questions to address the questions taxpayers and tax professionals regarding the Transfer Pricing Surcharge.
The recently announced Singapore Budget 2024 tabled by Deputy Prime Minister and Finance Minister, Mr. Lawrence Wong on 16 February 2024.
The indicative margin recommended by IRAS are market interest rate to be adopted by Singapore taxpayers for related party loans not
exceeding SGD15 million.
Generally, the IRAS publishes the indicative margins at the beginning of each calendar year.
Be prepared for potential transfer pricing audits by tax authorities. Ensure that your transfer pricing documentation is readily available, organized, and easily accessible.
There is an increasing focus on transfer pricing documentation for intragroup loans in Malaysia. Tax authorities expect comprehensive documentation that demonstrates the arm's length.
In Singapore Taxpayers are required to review and update your transfer pricing documentation annually to ensure its accuracy and relevance.
The submission of corporate tax returns dateline in Singapore is around the corner with most companies having to submit their tax return by 30 November 2023.
TNMM is a widely used transfer pricing method by tax authorities and multinational companies because it is considered to provide a more accurate outlook of the profitability.
PSM is generally used when there is significant value contributed by each party to the transaction and should be resorted to when it has
been difficult to determine an arm's length.
Malaysia published its new transfer pricing (TP) rules in May and these are certainly creating a buzz on the ground, especially with many companies having related party transactions between both sides of the Causeway.
Intra-group service is one of the most common international related party transactions entered by Malaysian Taxpayers.
In this article we will explore the Resale Price Method (“RPM”) and see how this differs to the other traditional methods.
The CP method forms part of the traditional transfer pricing approach. Cost Plus means adding a markup to the actual cost incurred by a Company in producing or acquiring a product or service.
The CUP method is a well-established traditional transfer pricing approach. This method is used to determine the arm's length price for transactions between related parties, also known as controlled transactions.
Transfer Pricing Solutions Malaysia were delighted to present on the topic of Global Minimum Tax and Impact on transfer pricing at the Malaysian Institute of Accountants conference in June 2023.
Managing intragroup finance in Asia can come with several challenges from macroeconomic issues to tax and transfer pricing.
Multinational enterprises (MNEs) must not only navigate global transfer pricing regulations but also be aware of the economic climate to maintain tax efficiency and adhere to the arm's length standard.
Global minimum tax is a tax policy proposal that would require large multinational corporations to pay a minimum tax rate on their profits, regardless of where they are located.
In this first article we will discuss the differences between transactional and traditional methods and considerations to be taken into account.
Indicative margins were introduced by the Inland Revenue Authority of Singapore (“IRAS”) in 2017 to be used in related party loans.
The fundamental principles articulated in OECD’s and the Inland Revenue Authority of Singapore (IRAS)’, Transfer Pricing Guidelines (TPGs) are similar even though their approaches may vary.
Since the OECD’s base erosion and profit shifting (BEPS) project, transfer pricing (TP) rules and regulations worldwide have continued to grow in number and complexity.
As the OECD presses on with its two-pillar solution under the new BEPS 2.0 initiative, TP is set to dominate the international tax agenda for years to come.
From different thresholds for TPD to the general approach taken by the tax authorities, there are many differences between Singapore and Malaysia’s TP regimes.
Indicative margins were introduced by the Inland Revenue Authority of Singapore (“IRAS”) in 2017 to be used in related party loans. What is the impact for Singapore Taxpayers?
Whether you need to prepare a benchmarking study when entering into a related party transaction depends on the country's transfer pricing regulations and the specifics of the transaction.
This e-Tax Guide is relevant to any Singapore MNE group with international operations and annual group revenue of at least S$1,125 million.
Recently the tax authority issued a tax assessment regarding transfer pricing to Rio Tinto’s aluminium division according to which additional taxes in an amount of $86.1 million.
The submission of corporate tax returns dateline in Singapore is around the corner, with most companies having to submit their tax return by 30 November 2022.
If you are reading this article the chances are that you enjoy discussing about technical aspects of transfer pricing as much as we do. Any transfer pricing aficionado knows that changes to the OECD Transfer Pricing Guidelines are a reason for excitement in the tax and transfer pricing world.
Read the latest update released by IRAS on Indicative margins for related party loan for 2021 & 2022. Read our article with our views on the market interest rate recommended by IRAS to be adopted by Singapore Taxpayers.
Read the latest update by our Asia Director, Adriana Calderon. Adriana has extensive international experience with #BigFour and mid-tier firms advising #multinational companies in the areas of corporate and #international taxation across South America, the US, Australia and the Asia Pacific Region.
Singapore is often a preferred location for setting up headquarters as the door to conduct business in Asia. The IRAS has released its views on how Singapore HQ's should plan and implement their transfer pricing framework. Want to know more? Read our article with our views on IRAS TP Guidelines for Singapore HQs.
The Malaysian Finance Bill 2020 incorporates transfer pricing-related changes to the current Income Tax Act, 1967 (“ITA”). The changes permit significantly greater authority to the Malaysia Inland Revenue Board (“MIRB”) and re-emphasises the importance of transfer pricing compliance, with effect from 1 January 2021.
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
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