Mega Offer Avail 65% Off in CA IPCC and 50% Off in all CA CS CMA subjects.Coupon- IPCEXAM65 & EXAM50. Call: 088803-20003

CA Final Online Classes
CA Classes

Share on Facebook

Share on Twitter

Share on LinkedIn

Share on Email

Share More

Key Takeaways from the guidelines issued by the Singaporean Tax Authorities

Atishay Jain 
on 12 April 2021

LinkedIn


1) Singapore is the preferred destination for the MNC's / MNE groups for setting up hub or HQs for APAC regions. The said guidelines provide for the determination of remuneration for such hubs/ HQs on arm's length basis;

2) Services provided by such hubs/HQs are critical to the operations carried on by the subsidiaries or fellow AE's. Accordingly, while determining the Arms length remuneration due consideration should be given to the HQ's/ Hub's contribution to the value creation. Such contribution should not be merely based on Functions, Assets and Risk (FAR) carried, but also on the economic significance of those functions performed;

Key Takeaways from the guidelines issued by the Singaporean Tax Authorities

3) The Guidelines discuss 4 types of centralized activities undertaken by HQs

(i) Principal in distribution, manufacturing or research and development arrangements;

(ii) Activities relating to core business processes;

(iii) Activities relating to administrative, technical, financial, commercial, management, coordination and control functions; and

(iv) Shareholder activities;

 

For each type of transaction, an indicative FAR analysis, as well as appropriate TP methodology, has been prescribed.

 

Hope you will find the above useful!

The IRAS e-Tax Guide has been enclosed below

The author can also be reached at atishayjain1882@gmail.com


Tags :



Category Income Tax
Other Articles by -
Atishay Jain 

Report Abuse

LinkedIn



Comments


update