A Singapore transfer pricing documentation file should explain the company’s related-party transactions and how their prices are supported. Start by assessing the documentation requirement, then connect the analysis to contracts, accounts and the actual work performed. This guide focuses on preparing an organised, usable file, rather than leaving the evidence scattered across a group report and several spreadsheets.
Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.
Does your company need statutory transfer pricing documentation?
IRAS identifies two starting conditions: gross revenue from the trade or business exceeds S$10 million for the relevant basis period, or documentation was required for the preceding basis period. Exemptions for specified transactions must then be assessed. Do not use company size alone to decide the position, or assume an exemption from documentation removes the need to consider arm’s-length pricing.
What must the documentation explain?
The prescribed information includes a relevant group-business overview and details of the Singapore taxpayer and its related-party transactions, with functional and transfer pricing analysis. A group report is useful only if it adequately supports the Singapore company’s actual transactions and the required information.
A practical working-file layout
The following is an organisational suggestion, not a substitute for the statutory content requirements or a complete transfer pricing study.
- Transaction map: identify each related party, the legal entities involved and the type of transaction.
- Contracts and operating evidence: keep signed terms, amendments and records showing what was actually supplied or performed.
- Financial schedules: link transaction totals to the ledger and explain allocations, adjustments and differences.
- Business explanation: record who does the work, makes decisions and bears the relevant commercial responsibilities.
- Pricing support: keep the analysis, information sources and explanations relied upon, including the basis for material assumptions.
- Review trail: identify the preparer, reviewer, version and unresolved questions.
Reconcile the figures before finalising the report
Give each transaction category a clear reference that appears in both the report and supporting schedules. Ask the accountant to trace the totals to the company’s accounts, rather than assuming that a group spreadsheet uses the same period or classification.
Explain differences such as foreign exchange movements, year-end adjustments and costs allocated across several entities. Keep the supporting calculation for an adjustment alongside the approval and accounting entry. A reviewer should be able to reproduce the reconciliation without guessing which spreadsheet was the final version.
When must the file be ready, and when is it submitted?
IRAS requires completion by the Income Tax Return filing due date. The documentation is not routinely submitted with the return, but must be supplied within 30 days when IRAS requests it. Retain it for at least five years from the end of the basis period in which the transaction occurred.
A practical example
Illustration: A Singapore company pays an overseas group entity for support services. Its file contains the agreement and a group report, but the annual charge cannot be matched to the services or accounting entries. The preparation work should resolve that gap: identify the services received, collect operating evidence, explain the allocation calculation and reconcile the charge to the ledger. This example is not a conclusion that a particular price or method is acceptable.
What should you do when IRAS requests the documentation?
- Read the request and identify the relevant periods, transactions and due date.
- Locate the completed report and the supporting records for those periods.
- Check that the report and schedules are consistent and that attachments are clearly indexed.
- Identify gaps honestly and seek advice promptly on the response.
- Keep the submitted version and evidence of submission together.
Do not backdate a study or imply that a document existed earlier than it did. If the file is incomplete, give the adviser the actual records and timeline. A clear reconstruction of the facts is more useful than an unsupported assurance that the group has always complied.
Related guides
- Related-party transactions and transfer pricing for SMEs
- Advance pricing arrangements in Singapore
- Singapore tax guides
Official guidance
Consult IRAS’s current transfer pricing guidance and its linked documentation rules and guidelines when assessing your company’s circumstances.
Would you like tax advice?
If you would like tax advice or help with your company's tax obligations, email [email protected] or WhatsApp +65 8501 7133.
Our accounting and tax advisers can assist. Where legal advice is needed, advisers from our associated law firms can also assist.