Foreign Subsidiaries

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Foreign Subsidiaries

Do you have all the necessary transfer pricing policies and risk assessments in place for the intercompany related party transactions of your foreign subsidiaries?

Ask us how we can assist you with:

Transfer pricing planning and implementation of new business structures
Preparation of transfer pricing documentation, Master File and Local File
BEPS and Country by Country Reporting implementation
Development and review of transfer pricing policy
Transfer pricing risk reviews, APAs and audit defense
Benchmarking studies covering all types of transactions and regions with access to databases
Preparation and review of intercompany agreements
Fast-track intercompany agreement drafting
In-house transfer pricing workshops and training sessions
In-house transfer pricing advisory

10 Feb

US Headquartered MNEs Must Still Comply With Singapore’s Global Minimum Tax

US‑based multinational enterprises (MNEs) will continue to be subject to Singapore’s Qualified Domestic Minimum Top-Up Tax (QDMTT), even though they may not be subject to a top‑up tax under US rules.

Registration for Multinational Enterprise Top-up Tax and Domestic Top-up Tax

Starting May 2026, in-scope multinational enterprise (MNE) groups must register for Singapore’s Multinational Enterprise Top-up Tax (MTT), Domestic Top-up Tax (DTT), and the GloBE Information Return (GIR) under the Multinational Enterprise (Minimum Tax) Act 2024.

2026 IRAS Indicative Margins for Related Party Loans

For the year 2026, IRAS has updated its indicative margin, reaffirming its support for simplified, arm’s length transfer pricing practices.