Singapore legislation
Regulation 2
Regulation 2
Definitions
In these Rules, unless the context otherwise requires —“advance pricing arrangement” means an agreement on the transfer pricing criteria to be used in relation to one or more transactions between an applicable entity and one or more related parties of the entity over a specified period, being an agreement —
that is made between the Comptroller and an authority of a country outside Singapore, and in accordance with a procedure under an avoidance of double taxation arrangement between the Government and the government of that country; or
that is made between the applicable entity and the Comptroller;“applicable entity” means a company or firm mentioned in section 34F(2) of the Act, or a trustee of a trust that is a trust mentioned in that provision;“avoidance of double taxation arrangement” means an arrangement having effect under section 49 of the Act;“group”, in relation to an applicable entity, means a group of entities all of which are related parties, that includes —
the applicable entity; or
if the applicable entity is a partnership, a partner of the partnership;“indicative margin” means the indicative margin for related party loans published on the Inland Revenue Authority of Singapore’s website at http://www.iras.gov.sg;“IRAS e‑tax guide” means the IRAS e‑tax guide entitled “Transfer Pricing Guidelines” published on 23 February 2006, as amended from time to time;“routine support services” means the services specified in the First Schedule;“transfer pricing method” means a method used to determine arm’s length prices between related parties, and further explained in the IRAS e‑tax guide.
Definition
“advance pricing arrangement” means an agreement on the transfer pricing criteria to be used in relation to one or more transactions between an applicable entity and one or more related parties of the entity over a specified period, being an agreement —
that is made between the Comptroller and an authority of a country outside Singapore, and in accordance with a procedure under an avoidance of double taxation arrangement between the Government and the government of that country; or
that is made between the applicable entity and the Comptroller;
Definition
“applicable entity” means a company or firm mentioned in section 34F(2) of the Act, or a trustee of a trust that is a trust mentioned in that provision;
Definition
“avoidance of double taxation arrangement” means an arrangement having effect under section 49 of the Act;
Definition
“group”, in relation to an applicable entity, means a group of entities all of which are related parties, that includes —
the applicable entity; or
if the applicable entity is a partnership, a partner of the partnership;
Definition
“indicative margin” means the indicative margin for related party loans published on the Inland Revenue Authority of Singapore’s website at http://www.iras.gov.sg;
Definition
“IRAS e‑tax guide” means the IRAS e‑tax guide entitled “Transfer Pricing Guidelines” published on 23 February 2006, as amended from time to time;
Definition
“routine support services” means the services specified in the First Schedule;
Definition
“transfer pricing method” means a method used to determine arm’s length prices between related parties, and further explained in the IRAS e‑tax guide.