Singapore: Where Transfer Pricing has become a transparent area of focus

SINGAPORE LEGISLATION AND BEPS PROJECT Singapore has committed to the global implementation of the BEPS Project proposed by the OECD. Particularly, a lot of attention has been given to Actions 8-10, pertaining Transfer Pricing (TP). More precisely, the cornerstone for TP law in Singapore comprises the Income Tax Act. The Income Tax Rules of 2018 … Read more

Malaysia: An obvious will for Transfer Pricing deep scrutinization

BEPS AND MALAYSIA TRANSFER PRICING RULES The widely known Base Erosion and Profit Swifting (BEPS) OECD initiative has drastically affected the Transfer Pricing (TP) landscape, globally, as it constitutes a crucial denominator for corporate taxation. Malaysia, being an OECD member, shows an admirable adherence to the said rules. Therefore, Malaysian TP legislation merits a brief … Read more

Tax Department: Circular 3 for Back to Back Financial Arrangements

REPUBLIC OF CYPRUS MINISTRY OF FINANCE Ref. No.: 05.13.001 Interpretative Circular 3 — Income Tax June 30th, 2017 To all Assessing Staff Tax treatment of intra-group back-to-back financial arrangements 1. Definitions 1. This Circular applies to any company carrying out group financing transactions (hereinafter referred to as a group financing company) meaning any entity that … Read more