Singapore Publishes Fourth Edition Transfer Pricing Guidelines

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 Countr…