17 September 2012 Report from Rachel Saw, IBFD Senior Research Associate The Inland Revenue Board has recently issued new Transfer Pricing Guidelines and Advance Pricing Arrangement Guidelines. Transfer Pricing Guidelines (TP Guidelines) The new TP Guidelines replace those previously issued in 2003. Whilst the 2003 TP Guidelines applied only to cross-border transactions, the 2012 TP Guidelines apply to both cross-border and domestic transactions. This brings the TP Guidelines in line with the introduction of transfer pricing legislation in 2009 under section 140A of the Act, and the Income Tax (Transfer Pricing) Rules 2012 (hereinafter referred to as the Rules). The...