International Tax: Transfer Pricing

Key requirements

Perform comparability analysis, choose the appropriate method and tested party, and determine an arm’s length result. Contemporaneous documentation should support the facts and method, with mandatory preparation and exemptions checked under the detailed rules. IRAS may adjust understated Singapore profit and impose a 5% surcharge on the adjustment even without additional tax. Branch and head-office dealings are included in related-party considerations. Transfer pricing can also generate double taxation if jurisdictions take different positions. The source links to APAs for prevention and MAP for treaty dispute resolution; neither replaces the need for supportable pricing in the first place.