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.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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