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ARTICLE · 29 NOVEMBER 2020

Singapore's Transfer Pricing Guidelines For COVID-Affected Businesses

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Generally, companies are required to consult the IRAS before applying term-testing.

SingaporeTax
Pieter De Ridder
Pieter De Ridder
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The Inland Revenue Authority of Singapore ("IRAS") has issued transfer pricing guidelines for companies affected by the COVID-19 pandemic, which includes guidance on documentation requirements, term-testing for related party transactions and Advance Pricing Arrangements ("APA").

Affected companies should include the following information, among others, in the transfer pricing documentation:

  • a broad analysis of how the company's industry was affected by the pandemic;
  • the direct impact of the pandemic to the company's business;
  • who and which entity within the group made decisions to manage risks related to COVID-19;
  • the functional analysis of the company and related parties before and after COVID-19;

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