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ARTICLE · 17 FEBRUARY 2016

Paying No Interest On A Related-Party Loan

Withers LLP
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The Inland Revenue Authority of Singapore published the 3rd edition of its Transfer Pricing Guidelines on the second working day of the New Year.

SingaporeTax

The 2016 Singapore Transfer Pricing Guidelines on related-party loans

The Inland Revenue Authority of Singapore published the 3rd edition of its Transfer Pricing Guidelines on the second working day of the New Year. In this new edition, the IRAS’ expectations concerning related-party loans have been slightly elaborated. The guidelines now state that a debtor should apply the arm’s-length principle when borrowing from a related party. In other words, a borrower is required to pay a related lender an arm’s-length rate of interest. The previous guidelines only mentioned charging arm’s-length interest when lending. They did not specifically address borrowing.

'When a taxpayer makes a loan to or becomes a creditor of a related party, it should apply the arm’s-length principle and charge the related party for the use of the funds as an arm’s-length interest rate.'

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