Corporate Income Tax: Transfer Pricing

Key requirements

IRAS recommends comparability analysis, selection of the appropriate method and tested party, and determination of an arm’s length result. Contemporaneous documentation supports that analysis, while the detailed rules set out when documentation is mandatory and when exemptions apply. A price that understates Singapore profit can be adjusted under section 34D. From YA 2019, the adjustment may attract a 5% surcharge on the adjustment amount, even if no additional tax becomes payable; remission is separately considered. The rule also covers branch/head-office dealings. Review service charges, goods, loans and intangibles consistently, retain the factual basis and consider APA or MAP procedures for cross-border uncertainty rather than relying on a group policy alone.