On May 24, 2019, the Inland Revenue Authority of Singapore
("IRAS") released the transfer pricing guidelines for
commodity marketing and trading activities (the "e-Tax
Guide"), which outlines various factors that may affect the
economic value attributed to such activities. These include
discussions on appropriate application of transfer pricing methods
and highlights common functions and benefits relating to various
commodity marketing/trading activities in Singapore.
In summary, the e-Tax Guide addresses the following main
points:
- Characterization of commodity
marketing/trading entities
The e-Tax Guide provides general descriptive/categorizing
information for entities of various types such as service
providers, agents, distributors or full risk-taking entrepreneurs.
This is done through attributing various levels of activities and
key functions that each functional category should assume.
Additionally, the e-Tax Guide discusses the assets utilized (i.e.
to
