Singapore’s consultation paper on TP documentation proposes master file approach but overlooks CbCR

On September 1 2014, the IRAS issued a consultation paper relating to its transfer pricing (TP) documentation rules. The IRAS issued initial TP guidelines in 2006 and has released a number of e-Tax Guides since then. However, when finalised, the proposed guidelines will require a change in the way taxpayers consider TP compliance in Singapore.