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Singapore Publishes Ruling Summary on Determination of Related Parties for Transfer Pricing Purposes

07 January 2021

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Approved Changes

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Singapore

The Inland Revenue Authority of Singapore has published Advance Ruling Summary No. 1/2021, concerning the determination of related parties for transfer pricing purposes in cases involving a joint venture without majority control. The main parts of the ruling summary are as follows: Relevant background and facts: Co A is a Singapore incorporated company and tax resident of Singapore. It is a joint venture set up by Co X, Co Y and Co Z (collectively known as the "Shareholders"). The Shareholders were incorporated outside Singapore. The formation of the joint venture was implemented as follows: The Shareholders established Company B ("Co...