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 Shareho…