The Inland Revenue Authority of Singapore has published an updated version of the country’s transfer pricing guidelines.
The seventh edition of the transfer pricing guidelines, which was published on June 14, 2024, incorporates frequently asked questions (FAQs) regarding the making of working capital adjustment.
The updated transfer pricing guidelines include new exemption rules for related party domestic loans entered into on or after January 1, 2025. Additionally, there is an increase in the threshold for exemption from transfer pricing documentation for certain transactions from SGD 1 million to SGD 2 million.
Updated guidelines include new FAQs regarding transfer pricing documentation for long term loans and provision of information to supplement an existing transfer pricing documentation.
The tax authority has updated the transfer pricing audit carried out to review the transfer pricing and transfer pricing documentation of taxpayers.
Section 8 of the transfer pricing guidelines explains when IRAS would make transfer pricing adjustment or disregard an actual related-party transaction. The section has been amended to include guidance on transfer pricing adjustment relating to capital transactions.
Finally, section 11 of the transfer pricing guidelines has been amended to remove the requirement for pre-filing meeting for mutual agreement procedure (MAP) application.