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Singapore Publishes Fifth Edition Transfer Pricing Guidelines and New Transfer Pricing Documentation Rules

27 February 2018

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Approved Changes

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Singapore

The Inland Revenue Authority of Singapore (IRAS) has published the fifth edition of its transfer pricing guidelines. Changes include: The simplification of sections 1, 2, and 3 (introductory sections and definitions); The replacement of the term "treaty" used throughout the e-Tax guide with "DTA" to be consistent with IRAS e-Tax Guide on Avoidance of Double Taxation Agreements; New guidance on related parties for permanent establishment in Singapore – paragraphs 4.3 and 5.8; Enhanced guidance on comparability analysis – paragraphs 5.15 to 5.25, 5.31 to 5.34, 5.40 and 5.51; Enhanced guidance on transactional profit split method – paragraphs 5.80 and 5.81;...