The Singapore Transfer Pricing (TP) system has its roots in the year 2006, with the introduction of the first set of TP guidelines. An evolutionary process has followed since then, and one could say that the system has come a long way in aligning itself with the Organization of Economic Co-operation and Development’s (OECD) Base Erosion and Profit-Shifting (BEPS) recommendations, especially in relation to the application of the arm’s length principle (as covered in Actions 8-10) and the maintenance of TP Documentation (as covered in Action 13).
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