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19 Nov

2024 Updates on Global Minimum Tax

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.


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4 Nov

Understanding the Basics of Global Minimum Tax

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.


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21 Oct

The Evolution of Global Minimum Tax Policies: A Historical Perspective

This article will explore the history of global minimum tax policies, from their origins to the latest developments, including the recent OECD/G20 agreement.


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1 Oct

The Role of Technology in Global Minimum Tax Compliance

This article will discuss how technology can help multinational corporations streamline their global minimum tax compliance.


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23 Sep

The Implications of Global Minimum Tax on Multinational Corporations

This article will discuss how global minimum tax policies affect multinational corporations, including changes to their tax planning strategies and compliance requirements.


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2 Sep

Key Considerations for Compliance with Global Minimum Tax

This article will provide practical advice for multinational corporations on how to navigate the complexities of global minimum tax compliance.


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26 Aug

Navigating the Legal and Regulatory Landscape of Global Minimum Tax

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.


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5 Aug

Global Minimum Tax and the Future of International Taxation

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.


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22 Jul

Challenges and Opportunities for Developing Countries

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.


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2 Jul

BEPS 2.0 - Pillar One - Amount B - is it really a simplified approach to Transfer Pricing?

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.


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21 Mar

Adriana Calderon appointed to SCTP Transfer Pricing Roundtable Representative

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.


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11 Jan

2024 IRAS Indicative Margins for Related Party Loan

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.


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9 Mar '22

All you need to know about the OECD Transfer Pricing Guidelines 2022 Update

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.


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11 Feb '21

Malaysia Transfer Pricing Update

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.


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12 Aug '20

ATO issues COVID-19 guidance on AU Transfer Pricing

Thec Covid-19 pandemic has triggered the most severe recession and is causing enormous damage to the world economy. The economic downturn will impact a group’s transfer prices, analysis and documentation, more so with the BEPS Action Plans in place and the high level of transfer pricing scrutiny across the globe.


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16 Jul '20

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?


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16 Jul '20

JobKeeper Payments - Impact on Your Clients' Transfer Pricing

The ATO expect that Australian entities will retain the benefit of the JobKeeper payment they receive. So how do you treat the JobKeeper payments for transfer pricing purposes?


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13 Jul '20

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.


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26 Jun '20

Transfer Pricing Solutions is finalist of ITR Asia Tax Awards 2020

We are thrilled to announce that Transfer Pricing Solutions is shortlisted for the International Tax Review Asia Tax Awards 2020 with several nominations!


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24 Jun '20

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.


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22 Jun '20

Transfer Pricing Solutions is winner of Australian Accounting Awards 2020

Transfer Pricing Solutions are thrilled to have won the Fast-Growing Firm of the Year award at the Australian Accounting Awards 2020! 




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24 Apr '20

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 related parties.


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22 Apr '20

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 transactions.


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15 Apr '20

The #TPSWAY of Doing Business, how can companies benefit?

Our firm has been a pioneer in using technology that allows our team of experts to work from anywhere and at any time.


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9 Apr '20

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.


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7 Apr '20

Transfer Pricing for Commodity Trading Entities

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


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17 Mar '20

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.   


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13 Mar '20

Digital Economy and Transfer Pricing

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.


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24 Feb '20

Taxpayer Alert of DEMPE Analysis Australia

Intangible properties (“IPs”) has become the main driver of business profits within Multinational Enterprises (“MNEs”) especially in the digital economy ecosystem.


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13 Feb '20

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.


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21 Jan '20

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.


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16 Dec '19

Interest Deductibility Restrictions in Malaysia

The introduction of Earning Stripping Rules (“ESR”) limiting the interest deduction for financial assistance between related persons were announced in the Budget 2018.


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25 Nov '19

ISCA Continuing Professional Development 2020

Equip your employees with relevant skills imparted by our team of professional trainers. 


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17 Oct '19

Updates on Malaysian Transfer Pricing Guidelines

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”)


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10 Oct '19

Overview of Profit Split Method

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.


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6 Oct '19

New Transfer Pricing Regime in Hong Kong

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.


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20 Sep '19

TP Minds Asia 2019, Singapore, 25 - 26 September 2019

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.


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29 Jul '19

TPMinds Asia, Singapore, 24-26 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. 


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13 Jul '19

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.


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10 Jun '19

Wrap up to our wonderful week in Australia

The transfer pricing team's trip to Australia has been amazing and productive. 


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6 Jun '19

An eventful beginning to our trip in Australia

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. 


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13 May '19

Transfer Pricing Solutions Malaysia is winner of ITR Tax Awards 2019

We are so proud to deliver you the good news! Our firm won the prestigious Asia Best Newcomer of the Year award at the ITR Asia Tax Awards 2019. 


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7 May '19

ITR Asia Tax Forum, Singapore, 8-9 May 2019

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.


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3 May '19

Happy Anniversary

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 


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30 Apr '19

Labuan Malaysia Country-by-Country Reporting Guidelines 2019

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.


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10 Apr '19

PCG 2017/1: ATO’s Self-Assessment Risk Framework for Offshore Hubs

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.


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10 Apr '19

Overview of Development, Enhancement, Maintenance, Protection and Exploitation (DEMPE) analysis

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.


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12 Mar '19

Transfer Pricing Solutions is finalist to Australian Tax Awards 2019

"Teamwork makes the dream work!"

Our nominations for 2019 are Australian Transfer Pricing Firm of the Year, Singapore Transfer Pricing Firm of the Year, Asia's Transfer Pricing Practise Leader of the Year - Shannon Smit and Asia's Best Newcomer of the Year - Transfer Pricing Solutions Malaysia


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22 Feb '19

To CUP or Not To CUP Commodities

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.


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21 Feb '19

All you need to know about Australia’s Simplified Transfer Pricing Record Keeping

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.


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19 Feb '19

Do you have a spare $525,000 for FAILURE TO LODGE PENALTY? Our accounting firm client didn't......

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!


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11 Feb '19

First Year of Singapore Mandatory Transfer Pricing Documentation, are you prepared?

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?


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17 Jan '19

Why is Transfer Pricing Important For Entrepreneurs, Start-ups and SMEs?

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


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21 Aug '18

How Does Transfer Pricing Affect Malaysian Companies?

Is your Company subject to transfer pricing in Malaysia? Our article summarises key considerations to ensure compliance with transfer pricing in Malaysia


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31 Jul '18

Is Your Transfer Pricing Pizza 73% Delicious, 27% Also Delicious?

The challenge has been thrown down. How do we best simplify key points around transfer pricing? We think we’ve found the answer. Pizza. (Stay with us!) If transfer pricing was a pizza, what would be the main ingredients to consider?


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10 Jul '18

Is your transfer pricing benchmarking reliable?

The benchmarking analysis is the backbone of a transfer pricing analysis, benchmarking analysis that is reliable and defendable is key when preparing transfer pricing documentation.
Is your benchmarking analysis reliable? 


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26 Jun '18

#5Minutes TP Episode 4

Need a coffee break? Take a five minute and watch #5MinutesTP Episode 4.
Part two about #transferpricing and services transactions, how to price intra-group services


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12 Jun '18

#5Minutes TP Episode 3

Need a coffee break? Take a break and watch #5MinutesTP Episode 3, #transferpricing for services, trips and traps on how to price services transactions


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16 Apr '18

TPMinds Sydney, Australia, 29-31 May 2018

Do you want to hear from key transferpricing leaders the latest transfer pricing trends? Come and join TPMinds Australia the largest TP Conference in the region.


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8 Feb '18

All you need to know about Indonesia New Transfer Pricing Rules

The Indonesian transfer pricing landscape continues in turmoil, where Companies are struggling to understand and comply with the latest released regulation No. 213/PMK.03/2016 (“PMK-213”).


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19 Dec '17

Australia extends lodgement date of Country-by-Country reporting, Master File and Local File, is your Company prepared?

Lodgement date for CbC Reporting has been extended to February 2018, does your Company need to complete CbC Report, Master File, Local File in Australia?


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13 Jun '17

Singapore IRAS warning on misuse of the services cost-plus 5% mark-up concession

Unsure on whether your company is pricing services transactions correctly? This article will give key insights on how to price services correctly


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31 May '17

All you need to know about BEPS and Country by Country Reporting in Australia

Unsure where to start with BEPS Country by Country Reporting? This article explains all you need to know about CbC reporting requirements in Australia.


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12 May '17

Transfer Pricing Solutions is winner in the Asia Tax Awards 2017

Good news! Two prestigious awards won - Asia Best Newcomer of the Year and Asia Transfer Pricing Practice Leader of the Year.


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1 May '17

Transfer Pricing Solutions is finalist to Australian Accounting Awards 2017

Our nominations for 2017 are Boutique Firm of the Year, Partner of the Year (Boutique) - Shannon Smit, and Thought Leader of the Year - Shannon Smit


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26 Apr '17

Pricing Intra-Group Services, is it only about the mark-up?

Intra-group service transaction is an easy target for transfer pricing adjustment. Two steps to make sure you price them correctly.


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18 Apr '17

ISCA Journal published a unique article about benchmarking and transfer pricing

Want to know more about how to perform a benchmarking? Read this excellent article published by ISCA Journal, March 2017 edition. Get a copy now, link to article is available in the blog.


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14 Mar '17

All you need to know about Australia’s Simplified Transfer Pricing Record Keeping

New Guidance from the ATO about Australia’s Simplified Transfer Pricing Record Keeping Options, how does it impact your Company?


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10 Mar '17

Transfer Pricing Solutions is finalist to Asia Tax Awards 2017

Australia Transfer Pricing Firm of the Year • Singapore Transfer Pricing Firm of the Year • Best Newcomer of the Year, Transfer Pricing Solutions Asia • Asia Transfer Pricing Practice Leader of the Year, Shannon Smit


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7 Mar '17

To CUP or Not To CUP: A Transfer Pricing Dilemma

Traditionally a preferred transfer pricing method as it is the most direct and reliable way to apply the arm's length principle. But what are the Pros/Cons of applying the CUP method?


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24 Feb '17

Singapore Budget 2017, how does it impact your related party transactions?

On Monday 20 February, the Finance Minister Heng Swee Keat delivered in Parliament Singapore’s 2017 budget. With the tax authorities currently focusing on transfer pricing and the implementation of BEPS action plan, a few of the new measures will impact taxpayers and their related party dealings during 2017.


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31 Jan '17

ATO’s New Transfer Pricing Guidelines on Marketing, Sales, and Distribution Hubs, What Actions Should I Take Now?

On January 2016, the ATO released new compliance approach to transfer pricing issues related to centralised operating models (hubs) involving procurement, marketing, sales, and distribution functions. This Practical Compliance Guideline (“PCG”) 2017/1 comes into effect from 1 January 2017 and will apply to existing and newly created hubs.


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20 Jan '17

Singapore IRAS Released 4th Edition of Transfer Pricing Guidelines, what does it mean for you?

On 12 January 2017, the IRAS released the 4th edition of its Transfer Pricing Guidelines. We have summarised the key changes that can impact your Company.


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22 Nov '16

Transfer Pricing Pizza 73% Delicious, 27% Also Delicious

The challenge has been thrown down. How do we best simplify key points around transfer pricing? We think we’ve found the answer. Pizza. (Stay with us!) If transfer pricing was a pizza, what would be the main ingredients to consider?


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4 Nov '16

Accounting isn't all about the numbers

We are honored to be selected among many companies in Singapore to share our story; an excellent read about the human side of transfer pricing and why we love what we do.
 


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21 Oct '16

Transfer Pricing Solutions wins Accounting Awards 2016, Partner of the Year - Boutique Firm

We are delighted to announce Shannon Smit, Lead Partner of Transfer Pricing Solutions, as the winner of Partner of the Year – Boutique Firm at the Australian Accounting Awards 2016 organised by Accountants Daily.


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4 Oct '16

Do you know why do we play Pokemon Go daily in transfer pricing?

As we see the Pokemon Go fever going up around the world, we were interested in knowing why is the world so excited about this game.


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30 Aug '16

Why are the Olympic Games and Transfer Pricing Similar?

We all recovering from the Rio 2016 Olympic Games fever and coping with ‘the Olympic blues’ by following another sportive event or anxiously waiting for the next four years to go by and see our world athletes in Tokyo 2020.


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