Tax Bulletin


OECD issues beta version of the Matching Database for the Multilateral Convention to Implement Tax Treaty Related Measures

On 11 July 2017, the Organisation of Economic Co-operation and Development (OECD) issued the beta version of the matching database for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI”). This comes on the back of widespread support of the MLI, with Mauritius and Cameroon signing the treaty in early July, bringing the total number of signatories to 70. 

Singapore signed the MLI on 7 June 2017, as an early adopter, and lodged with the OECD a provisional list of reservations and notifications. Consistent with its commitments as a member of the inclusive framework for implementing measures to counter base erosion and profit shifting (BEPS), Singapore has adopted the MLI articles relating to preventing treaty abuse (adopting the principal purpose test) and enhancing dispute resolution. It has also adopted the mandatory binding arbitration (choosing the final offer option). At the same time of signing, 68 of Singapore’s 82 in-force double tax agreements (DTAs) have been identified as the covered tax agreements to be updated through the MLI. It should be noted that while Mauritius has signed the MLI, the Singapore-Mauritius DTA has not been listed by Mauritius as a covered tax agreement.
 

Previous issues

Roundup of Singapore’s 2016 BEPS Developments and what these mean for enforcement efforts beyond?

2016 marked several major developments in the Singapore’s tax landscape arising from the Organisation for Economic Co-operation and Development’s (“OECD”) Base Erosion and Profit Shifting (“BEPS”) Project. Aligning with international tax practices aside, these developments also show Singapore’s resolve in protecting its tax base in the face of an increasingly volatile international tax environment.

Singapore’s latest Transfer Pricing Guidelines released on 12 January 2017 incorporate further BEPS Actions developments

The Inland Revenue Authority of Singapore (“IRAS”) released its 4th edition Transfer Pricing Guidelines (“4th Edn TPG”), reflecting the IRAS’ approach to regularly update, generally on an annual basis, its transfer pricing guidance to align with international tax developments and accepted practices, including those emanating from the Organisation for Economic Co-operation and Development (OECD)’s BEPS1 initiative.

Singapore tax authorities issue long-awaited Singapore Country-by-Country Reporting (CbCR) implementation guidance

The Inland Revenue Authority of Singapore (“IRAS”) released the e-Tax Guide on Country-by-Country Reporting which aims to provide practical guidance on CbCR implementation in Singapore. This comes as part of Singapore’s commitment to implement the four minimum standards under the inclusive framework under the Organisation for Economic Co-operation and Development (“OECD’s”) BEPS Project.

Singapore tax authorities tighten APA process in latest Transfer Pricing Guidelines

On 4 January 2016, the Inland Revenue Authority of Singapore (“IRAS”) published its latest third edition of Transfer Pricing Guidelines (“3Edn TPG”). This came barely a year following release of the second edition of Transfer Pricing Guidelines (“2Edn TPG”) on 6 January 2015, which introduced contemporaneous transfer pricing documentation requirements in Singapore for the first time.

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