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 Transfer pricing dispute and resolution in Luxembourg: an overview from Philippe Neefs,

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PostSubject: Transfer pricing dispute and resolution in Luxembourg: an overview from Philippe Neefs,   Wed Oct 11, 2017 4:17 pm

Transfer pricing dispute and resolution in Luxembourg: an overview from Philippe Neefs,

Heike Weber and Sophie Boulanger of KPMG.



Tax authorities







Inland Revenue Authority of Singapore (IRAS)





55 Newton Road, Revenue House, Singapore 307987





Tel: +65 6356 8622



Fax: +65 6351 4360



Website: [Only admins are allowed to see this link] and







[Only admins are allowed to see this link]



Deloitte



EY



KPMG



PwC





2 Baker & McKenzie.Wong & Leow









Firm to watch







RSM



Transfer pricing has been a big focus and a concern



for multinationals in Singapore in the past year.



Reflecting the developing global standards recommended



by the BEPS project, the Singapore transfer



pricing regime has experienced significant changes



and reforms in the past few years. The Singapore TP



rules were updated in 2015 and 2016 with new documentation



requirements as well as access to formal



advance pricing agreements (APA) and mutual agreement



procedure (MAP) programmes.



“To assist taxpayers in coping with the changes,



the authorities in Singapore have taken an approach



of close engagement and consultation with affected



taxpayers and the professional community. It is also



clear that the Inland Revenue Authority of Singapore



has really ramped up enforcement of its TP regime,



including a marked increase in transfer pricing consultations,



where they evaluate how businesses



establish and implement their TP policies and manage



their compliance,” said Mike Nixon, director of



economics at Baker & McKenzie.Wong & Leow.



Singapore has committed to adopt the four minimum



standards under the BEPS project, which are the



adoption of Action 5 on harmful tax practices, Action



6 on treaty abuse, Action 13 on country-by-country



reporting (CbCR), and Action 14 on dispute resolution.



The common reporting standard will also be implemented



with effect from January 1 2017 and automatic



exchange of information will commence in 2018.



On June 16 2016, the Ministry of Finance



announced that Singapore will implement CbCR for



fiscal years beginning on or after January 1 2017 for



Singapore-headquartered multinationals. Specific



guidelines are expected to be released in September



2016.



“This move reinforces Singapore’s commitment to



the BEPS Project, which is important in maintaining



Singapore as an attractive business location and a



jurisdiction which does not tolerate treaty abuse or



tax evasion,” said Low Hwee Chua, regional managing



partner of Deloitte.



The transfer pricing industry is expecting more TP



related regulation updates on top of more stringent



administration by the authorities. “There is a notable



increase in clients’ interest in assessing and conducting



‘health checks’ on the readiness of existing tax



models and structures in the post-BEPS environment,”



said See Jee Chang, head of transfer pricing at



Deloitte.



Furthermore, there is a strong level of interest in



APAs, as more taxpayers are willing to invest in APAs



for certainty given the anticipated harsher tax audit



environment. “We also observed an increasing



amount of audit activities in Singapore, from transfer





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