Menu
  • Locations
  • About Us
  • Services
  • Experts
  • News & Knowledge
  • Hot Topics
  • Culture & Career
  • Locations
  • Search
  • Press
  • Events & Webinars
  • CI Guide
  • Contact
  • Albania
  • Angola
  • Argentina
  • Armenia
  • Australia
  • Austria
  • Bangladesh
  • Belgium
  • Benin
  • Bolivia
  • Bosnia & Herzegovina
  • Botswana
  • Brazil
  • Bulgaria
  • Burkina Faso
  • Burundi
  • Cambodia
  • Cameroon
  • Canada
  • Chile
  • China
  • Colombia
  • Costa Rica
  • Croatia
  • Cyprus
  • Czech Republic
  • Denmark
  • Dominican Republic
  • Ecuador
  • Egypt
  • El Salvador
  • Estonia
  • Finland
  • France
  • Georgia
  • Germany
  • Ghana
  • Gibraltar
  • Greece
  • Guatemala
  • Guinea
  • Honduras
  • Hong Kong
  • Hungary
  • Iceland
  • India
  • Indonesia
  • Iran
  • Iraq
  • Ireland
  • Israel
  • Italy
  • Ivory Coast
  • Japan
  • Kazakhstan
  • Kenya
  • Korea
  • Kyrgyzstan
  • Laos
  • Latvia
  • Lithuania
  • Luxembourg
  • Macao
  • Madagascar
  • Malaysia
  • Mali
  • Malta
  • Mauritius
  • Mexico
  • Moldova
  • Mongolia
  • Montenegro
  • Morocco
  • Mozambique
  • Myanmar
  • Namibia
  • Nepal
  • Netherlands
  • New Zealand
  • Niger
  • Nigeria
  • North Macedonia
  • Norway
  • Pakistan
  • Panama
  • Paraguay
  • Peru
  • Philippines
  • Poland
  • Portugal
  • Puerto Rico
  • Romania
  • Rwanda
  • Saudi Arabia
  • Senegal
  • Serbia
  • Seychelles
  • Singapore
  • Slovakia
  • Slovenia
  • South Africa
  • Spain
  • Sri Lanka
  • Sweden
  • Switzerland
  • Taiwan
  • Tanzania
  • Thailand
  • Togo
  • Trinidad and Tobago
  • Tunisia
  • Turkey
  • Turkmenistan
  • Uganda
  • Ukraine
  • United Arab Emirates
  • United Kingdom
  • Uruguay
  • USA
  • Uzbekistan
  • Venezuela
  • Vietnam
  • Zambia
  • About Us
  • Our CEO
  • Our Supervisory Board
  • Our Global Executive Team
  • Quality, Process & Risk Management
  • Sustainability & Tax at WTS Global
  • Customs
  • Financial Services
  • Global Mobility
  • Indirect Tax
  • International Corporate Tax
  • Mergers & Acquisitions (M&A)
  • Private Clients & Family Office
  • Sustainability & Tax
  • Tax Certainty & Controversy
  • Tax Technology
  • Transfer Pricing & Valuation
  • Real Estate
  • Digital Tax Law
  • European Tax Law
  • Latest News
  • Brochures
  • Newsletters
  • Surveys & Studies
  • Pillar Two
  • FIT for CBAM
  • Tax Sustainability Index
  • ViDA - VAT in the Digital Age
  • EU WHT Reclaims
  • AI playground
  • Culture and Leadership
  • Diversity
  • WTS Global Academy
  • Career
  • Pillar Two Team
  • Pillar Two - Implementation Status Wordwide
  • Press
  • Events & Webinars
  • CI Guide
  • Contact
WTS worldwide
  • Albania
  • Algeria
  • Angola
  • Argentina
  • Armenia
  • Australia
  • Austria
  • Bangladesh
  • Belgium
  • Benin
  • Bolivia
  • Bosnia & Herzegovina
  • Botswana
  • Brazil
  • Bulgaria
  • Burkina Faso
  • Burundi
  • Cambodia
  • Cameroon
  • Canada
  • Cape Verde
  • Central African Republic
  • Chad
  • Chile
  • China
  • Colombia
  • Congo Brazzaville
  • Costa Rica
  • Croatia
  • Cyprus
  • Czech Republic
  • Democratic Republic of Congo
  • Denmark
  • Dominican Republic
  • Ecuador
  • Egypt
  • El Salvador
  • Equatorial Guinea
  • Estonia
  • Eswatini
  • Ethiopia
  • Finland
  • France
  • Gabon
  • Gambia
  • Georgia
  • Germany
  • Ghana
  • Gibraltar
  • Greece
  • Guatemala
  • Guinea
  • Guinea-Bissau
  • Honduras
  • Hong Kong
  • Hungary
  • Iceland
  • India
  • Indonesia
  • Iran
  • Iraq
  • Ireland
  • Israel
  • Italy
  • Ivory Coast
  • Japan
  • Kazakhstan
  • Kenya
  • Korea
  • Kyrgyzstan
  • Laos
  • Latvia
  • Liberia
  • Libya
  • Lithuania
  • Luxembourg
  • Macao
  • Madagascar
  • Malawi
  • Malaysia
  • Mali
  • Malta
  • Mauritania
  • Mauritius
  • Mexico
  • Moldova
  • Mongolia
  • Montenegro
  • Morocco
  • Mozambique
  • Myanmar
  • Namibia
  • Nepal
  • Netherlands
  • New Zealand
  • Niger
  • Nigeria
  • North Macedonia
  • Norway
  • Pakistan
  • Panama
  • Paraguay
  • Peru
  • Philippines
  • Poland
  • Portugal
  • Puerto Rico
  • Romania
  • Rwanda
  • São Tomé and Príncipe
  • Saudi Arabia
  • Senegal
  • Serbia
  • Sierra Leone
  • Singapore
  • Slovakia
  • Slovenia
  • Somalia
  • South Africa
  • South Sudan
  • Spain
  • Sri Lanka
  • Sudan
  • Sweden
  • Switzerland
  • Taiwan
  • Tanzania
  • Thailand
  • Togo
  • Trinidad and Tobago
  • Tunisia
  • Turkey
  • Turkmenistan
  • Uganda
  • Ukraine
  • United Arab Emirates
  • United Kingdom
  • Uruguay
  • USA
  • Uzbekistan
  • Venezuela
  • Vietnam
  • Zambia
  • Zimbabwe
  • About Us
    About Us

    Here you will find more information on our organization’s structure, experts and global reach.

    Read more
    About Us Our CEO Our Supervisory Board Our Global Executive Team Quality, Process & Risk Management
    Sustainability & Tax at WTS Global
  • Services
    Services

    Learn more about our network partners and their services.

    Read more
    Customs Financial Services Global Mobility Indirect Tax International Corporate Tax
    Mergers & Acquisitions (M&A) Private Clients & Family Office Sustainability & Tax Tax Certainty & Controversy Tax Technology
    Transfer Pricing & Valuation Real Estate Digital Tax Law European Tax Law
  • Experts
    Experts

    With a representation in over 100 countries, our team offers local expertise on a global scale. Learn more about our experts.

    Read more
  • News & Knowledge
    News & Knowledge

    Welcome to WTS Global Insights. Here you will find news and updates from our worldwide network.

    Read more Newsletter Subscription
    Latest News Brochures Newsletters Surveys & Studies
  • Hot Topics
    Hot Topics

    Overview of the current "Hot Topics" in the tax industry and how we can support with individual questions.

    Read more
    Pillar Two FIT for CBAM Tax Sustainability Index ViDA - VAT in the Digital Age EU WHT Reclaims
    AI playground
  • Culture & Career
    Culture & Career
    Read more
    Culture and Leadership Diversity WTS Global Academy Career
  • Locations
  • Search
05.07.2024

Singapore: Transfer Pricing Guidelines Update

Key Facts
The Inland Revenue Authority of Singapore (IRAS) released the 7th edition of its Transfer Pricing Guidelines on 14 June 2024.
The new TP Guidelines reflects an easing of the compliance burden for taxpayers, where related party transactions fall below the increased thresholds for TPD preparation.
However, if your company has related party financing transactions, a transfer or sale of fixed assets, or if you have received government assistance, then you may well be impacted by the changes in the TP Guidelines.
Author
Christine Schwarzl
Associate Partner
Singapore
View Profile

The Inland Revenue Authority of Singapore (IRAS) released the 7th edition of its Transfer Pricing Guidelines on 14 June 2024. To assist taxpayers to understand the changes and assess their impacts, WTS Taxise Associate Principal Christine Schwarzl summarises, in this article, the main changes to the guidelines, including:

I.    Financing transactions

  • Changes to TP Documentation (“TPD”) preparation exemption for domestic related party loans entered into from January 2025;
  • Inclusion of Frequently Asked Questions (FAQ) and TPD guidance for long-term loans; and
  • Guidance on the application of base reference rates in determining interest rates.
     

II.    Capital transactions

  • Clarifications of IRAS’s view on the transfer or sale of fixed assets between RPs; and
  • Documentation is not mandatory (but is preferred).
     

III.    Economic analysis

  • Guidance on making working capital (“WC”) adjustments (interest rates to be used, etc.);
  • Guidance on conditions relating to strict pass through costs; and
  • The TP treatment of government assistance.
     

IV.    Audits, surcharges, TPD and other changes:

  • Elaboration on the TP audit process;
  • Clarification on the conditions under which IRAS will disregard an actual RP transaction;
  • An understanding of partial or full remission of S34E surcharges;
  • Increase of thresholds and clarification on transaction category aggregation; and
  • Date requirement for completion of simplified TPD.
     

The new TP Guidelines reflects an easing of the compliance burden for taxpayers, where related party transactions fall below the increased thresholds for TPD preparation. However, if your company has related party financing transactions, a transfer or sale of fixed assets, or if you have received government assistance, then you may well be impacted by the changes in the TP Guidelines.

To read the full article, click here to download a copy.

Author
Christine Schwarzl
Associate Partner
Singapore
View Profile
New TP Guidelines Singapore
View TP Guidelines
Articles you might be interested in

News on tax developments affecting the international Financial Services industry.

WTS Global Financial Services Newsletter #2/2025 is now available
Read more

Budget 2025 introduced tax measures to encourage domestic listings and investments and support the growth of insurance companies, Registered Business Trusts (“RBTs”), S-REITs, and other segments of the financial ecosystem.

Singapore: Budget 2025: Tax Measures for Financial Services
Read more

News on tax developments affecting the international Financial Services industry.

WTS Global Financial Services Newsletter #1/2025 is now available
Read more

Explore recent updates to Singapore's tax incentive schemes for funds. Singapore continues to refine its tax incentive schemes for both offshore and onshore funds managed by Singapore-based fund managers.

Singapore: Updates to Singapore’s Tax Incentive Schemes for Funds
Read more

The Inland Revenue Authority of Singapore (IRAS) released the 7th edition of its Transfer Pricing Guidelines on 14 June 2024. To assist taxpayers to understand the changes and assess their impacts, this article summarizes the main changes to the guidelines for Singapore taxpayers.

Singapore: Transfer Pricing Guidelines Update
Read more

Indonesia's new transfer pricing guidelines are enshrined in the Minister of Finance Regulation 172/2023 ("MoFR-172").

Singapore: Comparative analysis of Indonesia's new Transfer Pricing guidelines against Singapore's Transfer Pricing guidelines
Read more

Singapore Budget 2024: Navigating Economic Challenges with Strategic Business Support

Singapore: Singapore Budget 2024 - Navigating Economic Challenges with Strategic Business Support
Read more

Ship pooling arrangements have become more common as shipowners seek greater efficiencies in the deployment of their vessels.

Singapore: Tax treatment of ship pooling arrangements
Read more

Asia has been actively entering into Free Trade Agreements (“FTAs”) since the 1980s. This trend shows no sign of abatement.

Asia’s FTA Spree: benefits galore for businesses but caveat emptor
Read more

Moving to Singapore: 5 areas we can help with

Moving to Singapore: 5 areas we can help with
Read more

The new Singapore-Indonesia Double Tax Agreement (DTA) took effect as of 1 January 2022, thirty years after the previous DTA entered into force.

New Singapore-Indonesia Double Tax Agreement takes effect
Read more

To ensure that Singapore’s Goods and Services Tax (‘GST’) system remains fair and resilient as the digital economy grows, Singapore’s tax authority (‘IRAS’) will extend the application of GST 

Singapore: Expanding the scope of application of GST
Read more

To ensure that Singapore’s Goods and Services Tax (“GST”) system remains fair and resilient as the digital economy grows, Singapore’s tax authority (“IRAS”) will from 1 January 2023 extend the application of GST to: (i) low value goods worth S$400 or less (approximately US$295 or EUR 250) imported into Singapore by air or post; and (ii) imported B2C non-digital services.

Singapore will extend the scope of GST to imported B2C non-digital services and low-value goods
Read more

Tax executives lead the way to resilience and recovery.

Through Resilience to Recovery in Asia Pacific
Read more

Watch the acceptance speech of the co-founder and managing director of WTS Taxise here. 

Eugene Lim wins International Trade Lawyer of the Year Award 2021
Read more

Taxise Asia LLC proudly announces that principal and co-founder, Eugene Lim, has been shortlisted for the International Trade Lawyer of the Year award category at The Asia Legal Awards 2021.

Eugene Lim, principal & co-founder of Taxise Asia, shortlisted for The Asia Legal Awards 2021
Read more

Budget 2021 was delivered on 16 February 2021 and signals a shift from containing COVID-19 to restructuring and preparing Singapore’s economy and workforce for the post-pandemic world.

Singapore Budget 2021 - Emerging Stronger Together
Read more

New regimes have been implemented in domestic and foreign service supply.

Singapore: Levying GST on imported services
Read more

Starting January 1 2020, Singapore provides for Goods and Services Tax (GST) exemptions for digital payment tokens that satisfy certain criteria.

Singapore: Exempting digital payment tokens from GST
Read more

A Simplified Regulatory Regime for Managers of Venture Capital Funds

Singapore: Venture Capital Fund Management Regime (“VCFM Regime”)
Read more
Singapore Work Pass Update & Upcoming Regulation of Hong Kong Corporate Service Providers
Read more

The Companies (Amendment) Act 2017 introduced an inward re-domiciliation regime in Singapore, allowing foreign corporate entities (FCE) to transfer their registration to Singapore.

Singapore's new inward re-domiciliation regime now in operation
Read more
Show more

Get in contact

If you have any questions about WTS Global or our global services, please get in touch.
We will respond to you as soon as possible.

Contact
About Us
  • About Us
  • Our CEO
  • Our Supervisory Board
  • Our Global Executive Team
  • Quality, Process & Risk Management
Services
  • Customs
  • Financial Services
  • Global Mobility
  • Indirect Tax
  • International Corporate Tax
  • Mergers & Acquisitions (M&A)
  • Private Clients & Family Office
  • Sustainability & Tax
  • Tax Certainty & Controversy
  • Tax Technology
  • Transfer Pricing & Valuation
Latest News
  • News & Knowledge
  • Brochures
  • Newsletters
  • Newsletter Subscription
  • Surveys & Studies
Hot Topics
  • Pillar Two
  • Digital Tax Law
  • European Tax Law
Culture & Career
Exclusive Cooperation With
© 2024 WTS Company Information Data Protection Disclaimer