Contemporaneous documentation
Can we prepare TP documentation only if IRAS asks?
The situation
No. Required TP documentation must be prepared by the filing due date of the tax return for the year.
The law
- Secs 34D and 34F, Income Tax Act 1947: Related party transactions at arm's length; transfer pricing documentation when thresholds are met
What it means for you
Preparing it later is not contemporaneous and can lead to fines and loss of some benefits, such as IRAS support in dispute resolution. Keep it for the record-keeping period.
What to do
- Plan TP work before the return.
- Finish by the filing date.
- Keep signed copies.
- Update yearly.
We can do this for youTransfer pricing documentation: SGD 5,000