Regulators have updated guidelines regarding a little-known area of tax accounting that has become a political hot potato in recent years.
Transfer pricing, as the process is called, refers to the price paid by one unit of a company to another for goods, services, intellectual property or financial transactions such as interest.
Because these units are within the same group, they can control how much they charge each other for such transactions.
This very common procedure has come under political scrutiny, especially in the West, in recent years.
Regulators have accused multinationals such as Apple and Starbucks of taking advantage of transfer pricing to shift their profits from units in high-tax jurisdictions to units in countries with lower tax rates, such as Singapore, to reduce their tax bills.
The Organisation for Economic Co-operation and Development (OECD) has even launched an action plan to curtail firms moving funds abroad to avoid high taxes.
The Inland Revenue Authority of Singapore (Iras) has responded to that initiative by issuing its first update on transfer pricing rules since the guidelines were issued in 2006.
Iras’ update, which was uploaded on Monday to its e-Tax Guide, makes it one of the first tax regulators in the world to adopt the transfer pricing documentation format advocated by OECD.
It is certainly a step in the right direction, said PwC Singapore transfer pricing leader Nicole Fung.
She said: “The guidelines will help Singapore enterprises face an increasingly transparent global tax world.
“The main challenge of the guidelines will be to continue to raise the level of awareness of Singapore enterprises in this environment, particularly small and medium-sized enterprises, which are expanding their businesses regionally or globally.”
The most significant change is an explicit requirement for Singapore taxpayers to prepare up-to-date transfer pricing documents, said Deloitte Singapore transfer pricing leader See Jee Chang.
Such documents have to be submitted no later than the tax return filing date for the financial year in which the transaction takes place.
EY transfer pricing services partner Henry Syrett said: “The format of the documentation is different from what companies currently use, so companies which have transfer pricing studies in place will need to consider whether these still meet the new standard.”
Transfer pricing transactions also have to be benchmarked against comparable transactions in the market to prove that they have been undertaken as if the company had been dealing with an external party.
“This can be a resource-intensive exercise, particularly in the first year that documentation is being prepared,” said Mr Syrett.
Mr See said the new guidelines call on companies to provide more information at the group level – a process that will require more time and effort to document.
Still, he added, the updated guidelines should not result in a complete overhaul of current business procedures or increase compliance costs too significantly.
“In fact, the new guidelines, with their detailed coverage on various areas not previously covered in the original 2006 guidelines, should provide much more clarity and guidance for companies,” he said.