Singapore Publishes Fifth Edition Transfer Pricing Guidelines and New Transfer Pricing Documentation Rules

The Inland Revenue Authority of Singapore (IRAS) has published the fifth edition of its transfer pricing guidelines. Changes include:

• The simplification of sections 1, 2, and 3 (introductory sections and definitions);
• The replacement of the term "treaty" used throughout the e-Tax guide with "DTA" to be consistent with IRAS e-Tax Guide on Avoidance of Double Taxation Agreements;
• New guidance on related parties for permanent establishment in Singapore – paragraphs 4.3 and 5.8;
• Enhanced guidanc…