On or about 4 Jan 2021, the Inland Revenue Authority of Singapore (IRAS) has published an Income Tax Advance Ruling Summary No. 1/2021 with regards to “Related party for Singapore transfer pricing purposes”.
The subject was whether Company A (“Co A”) is considered a related party, within the meaning of sections 34D, 34F and 13(16) of the Income Tax Act, to either Company X (“Co X”), Company Y (“Co Y”) or Company Z (“Co Z”).
The Fact and Organization Chart
It was ruled that Co A is not regarded as a related party to either Co X, Co Y or Co Z for the purposes of sections 34D, 34F and 13(16) of the SITA because:
- neither Co X, Co Y nor Co Z has control over Co A; and
- Co A and either Co X, Co Y or Co Z are not under the control of a common person.
For more information about the ruling, please go to the IRAS website.
Source: IRAS, 6 Jan, 2021