The Inland Revenue Authority of Singapore (IRAS), on September 1, issued proposed guidelines on transfer pricing documentation for public comment.
The new guidelines specify that documentation is required at both the group level and entity level, and an annex lists the types of information that should be included in the documentation package.
Transfer pricing documentation must be contemporaneous, namely, prepared no later than the date of submission, the guidance states.
Moreover, the guidance provides for exemptions from documentation requirements for transactions subject to the safe harbor mark-up of 5 percent for routine services, and for domestic transactions between a small or medium sized entity and a related party subject to Singapore tax rates.
Comments on the proposed rules are due by September 24. The IRAS specifically requests comments on whether contemporaneous documentation requirements are burdensome, whether information listed in the annex is difficult to obtain, on the frequency of required documentation updates, and whether any other low risk situations should be exempted from the transfer pricing documentation requirements. Consultation
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