The Inland Revenue Authority of Singapore (IRAS) has published the fourth edition of its transfer pricing guidelines. The main changes include: Enhanced guidance on arm’s length principle and functional analysis, including: That profits should be taxed where the real economic activities generating the profits are performed and where value is created; and Amended guidance on risk analysis; Enhanced guidance on transfer pricing documentation, including: Reference to the e-Tax guide on Country-by-Country Reporting; and The addition of the requirement to include a list and brief description of advance pricing agreements (APAs) and other tax rulings with the Group Level transfer pricing...