Transfer Pricing

What is Transfer Pricing?

Transfer pricing is the pricing of goods, services and intangibles between related parties.

Related parties are parties who control one another, or who are under the common control of another party, whether directly or indirectly. They include branches and head offices.

Related parties must deal with each other at arm's length.

Singapore Transfer Pricing 

IRAS require that a company prepare and keep contemporaneous transfer pricing documentation.

Transfer pricing documentation refers to the records kept by taxpayers to show that their related party transactions are conducted at arm's length.

The preparation and maintenance of transfer pricing documentation will facilitate reviews by tax authorities and therefore help resolve any transfer pricing issues that may arise.  Without transfer pricing documentation to show that the transfer prices are at arm's length, taxpayers may not be able to deal with transfer pricing enforcement actions by tax authorities and double taxation arising from those actions.

Contemporaneous transfer pricing documentation refers to documentation and information that a company has relied upon to determine the transfer price prior to or at the time of undertaking the transactions. IRAS will also accept transfer pricing documentation as contemporaneous when it has been prepared not later than the filing due date of the tax return for the financial year in which the transactions took place.

In preparing contemporaneous transfer pricing documentation, a taxpayer must use the latest available information and data to establish its transfer pricing.  

What business need to do?

With effect from the Year of Assessment 2019, companies who have met certain conditions are required to prepare transfer pricing documentation under Section 34F of the Income Tax Act unless exemption for specified transactions applies. Taxpayers who are not required to prepare transfer pricing documentation under Section 34F of the Income Tax Act are nonetheless encouraged to do so to better manage their transfer pricing risks. 

Read IRAS transfer pricing documentation guidelines which gives a detail explanation of the requirements for companies. 

What we can offer? 

Assist to prepare Transfer Pricing Documentation as per Income Tax (Transfer Pricing Documentation) Rules 2018.


Evaluate the existing Transfer Pricing policies and the supporting TP documentation being maintained by the Group.


Recommend improvements to the existing Transfer Pricing policies keeping in view the local rules and regulations, OECD Guidelines and BEPS Action Plans.

Transfer pricing fees

Depending on the scope of work, fees starts from SGD 5,000. 

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