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Tax & Transfer Pricing

As a business owner, every transaction you plan to make may have direct or indirect tax consequences. To achieve tax efficiency so as to enhance your return on investments, it is advisable that various tax issues be considered alongside the planning and structuring of your business. The tax landscape is changing at a rapid pace and expert advice is essential to mitigate tax risk and maintain profitability. We can assist you through our comprehensive tax compliance, tax advisory and transfer pricing services to minimise your effective tax burden. This includes keeping you abreast of the latest developments and updates on the changes in the Singapore tax regulations.

Our clientele come from a diverse range of industries, both local and international, and include:

  • Shipping
  • Trading and manufacturing
  • Engineering and construction
  • Technology
  • Investment holding

We can take care of your corporate tax compliance filing with the tax authorities, thereby allowing you to focus on your core business.

Our corporate tax services broadly include the following:

  • Monitoring the statutory deadlines and working closely with the company to meet the compliance filing deadlines
  • Assisting with the submission of Estimated Chargeable Income (ECI)
  • Preparing and filing of the corporate tax computation and tax return (Form C/C-S)
  • Preparing or reviewing current tax provision calculations based on the information provided and comment on the accuracy of the current tax provision
  • Verifying the Notices of Assessment raised by the IRAS that are in accordance to the tax returns submitted and advising the company accordingly
  • Assisting in analysing whether the company is required to complete and submit the Form for Reporting of Related Party Transactions (“RPT Form”) and assisting in the completion of the RPT Form
  • Assisting in the application of the Certificate of Residence (“COR”)
  • Managing and responding to IRAS’s queries and audit
  • Preparing and filing withholding tax returns (Form IR37)
  • Assisting with the application for waiver of shareholding test

Our tax advisory services are driven by your core business objectives and we are able to help you at a strategic business planning level to understand the effect your business strategies may have on your tax profile. We focus on building sustainable tax strategies that help your business achieve its ambitions.

We help marry your business transactions, both local and cross-border, with our in-depth expertise on application of the tax laws to help achieve a tax efficient structure which minimizes any adverse tax implications that could arise from your proposed transactions.

Our tax advisory professionals are also well suited to identify and pursue opportunities for Singapore tax incentives, grants and reliefs to maximise tax savings which include the following:-

  • Global Trader Programme (GTP);
  • Development and Expansion Incentive (DEI)
  • Finance and Treasury Centre (FTC)
  • Maritime Sector Incentive (MSI) – Singapore Registry of Ships (MSI-SRS) and Approved International Shipping Enterprise (MIS-AIS);
  • Training, innovation, growth and transformation related grants.

Our professionals have good rapport with the officers from various government agencies and vast experiences in dealing and liaising with the officers.

At CCS, we can assist you to make an application to the Comptroller of Income Tax to issue an advance ruling on the tax treatment for certain ambiguous transactions and technical issues that may arise from a proposed arrangement to help obtain certainty on the tax treatment for your proposed transactions.

The R&D tax incentives are targeted at encouraging businesses to build up their R&D capabilities in Singapore. Companies that undertake qualifying R&D activities may benefit from the R&D tax measures. At CCS, we provide the following services:

  • Assisting the business to identify the available R&D incentives and associated benefits, including the Enterprise Innovation Scheme
  • Identifying potential qualifying R&D expenditure
  • Producing technical reports to support R&D incentive claims
  • Liaising with authorities on the claims’ queries
  • Setting up protocols for the ongoing reviews of R&D expenditures

We understand that facing a tax audit or investigation and addressing tax issues dating back several years of assessment can be stressful without the proper support from tax professionals. At CCS, we aim to provide the necessary support to our clients when they receive a query letter from IRAS or an investigation is launched by IRAS. The penalties for evading income tax or negligence if there are errors without reasonable excuse in your tax submission can be hefty. At CCS, we want to take the stress away from you so that you can continue to focus on running and growing your business.

The IRAS provides for a Voluntary Disclosure Programme (“VDP”) to encourage companies to rectify any incorrect tax filing before IRAS begins any tax query, audit or investigation. The penalty imposed by the IRAS under the VDP is a fraction of that imposed under the IRAS tax investigation or audit. The company may engage us to review your past tax submissions for voluntary disclosure purposes.

IRAS has initiated the Tax Governance Framework (“TGF”) to encourage companies to adopt good tax governance and tax risk management.

TGF is a voluntary compliance initiative that a company may participate in to demonstrate that it has good tax governance and tax risk management. Companies that adopt the TGF are given a 2-year grace period for voluntary disclosure of corporate income tax, withholding tax and GST errors made within 2 years of IRAS’s approval of TGF application.

At CCS, we can work with you to design your TGF or review your current TGF for any enhancements and guide the company through the TGF application process.

At CCS, we can advise on all aspects of stamp duty applications. Our services include the following:-

  • Advising on stamp duty implications arising from proposed transactions
  • Assisting with compliance with stamp duty rules including computing stamp duty due and lodging applicable stamp duty forms on transfer of Singapore shares or sale of Singapore immovable properties
  • Analysing stamp duty relief conditions and advising on applicability of stamp duty relief to proposed transactions
  • Assisting with making an application for relief of stamp duty for transactions involving transfer of assets between Associated Permitted Entities and Reconstruction or Amalgamation of Companies

If you are acquiring any businesses or merging with another company, it is imperative to perform a due diligence exercise on the company to be acquired or merged (“Target”) for possible tax risks. Our dedicated tax team at CCS can help you achieve the following:

  • Identify and manage acquisition or merger risks associated with each transaction by carrying out pre-acquisition or pre-sale due diligence
  • Structuring an acquisition or disposition – advising on the tax consequences of individual acquisitions, joint ventures and divestments to help design tax-efficient deal structures
  • Undertaking a review of the tax clauses of the share and purchase agreement and other transaction documents
  • Advice on the most appropriate deal structure – share deal or asset deal – based on the circumstances and current positions of the buyer and seller
  • Financial modelling support – optimise the tax efficiency and cash flows of your structure
  • Post-deal restructuring – assist in post-deal integration to help realise the tax benefits and synergy as a result of the transaction

Our personal tax team can assist to manage the tax planning and compliance needs for Singapore-based expatriates, business owners and high net worth individuals. While ensuring that the local tax filing requirements are met, we help you understand the personal tax rules and apply the relevant reliefs and deduction to optimise tax savings.

Our personal tax services include:

  • Personal tax computation and tax return e-filing
  • Conduct tax briefing for newly arrived expatriate
  • Liaising with the Inland Revenue Authority of Singapore (“IRAS”) on personal tax related matters
  • Notify and obtain tax clearance from IRAS for foreign employees who ceased employment (Form IR21)
  • Tax planning and advisory for remuneration package

The Goods and Services Tax (GST) is applicable for local sale of goods and services made in Singapore, as well as importation of goods. A business is required to register for GST if its annual taxable turnover is S$1 million or more. With the implementation of Overseas Vendor Registration regime with effect from 1 January 2020, suppliers incorporated overseas that are making business-to-consumer transactions are required to register for GST in Singapore if certain thresholds are exceeded.

Our team can help to assess your business’ GST registration obligation, ease the process of regular GST filings, comply with statutory requirements, attend to GST queries and audit, provide GST advices on your planned business transaction as well as applying and renewing special your GST schemes via the Assisted Self-help Kit (ASK) process.

In addition, our associate firm, Moore Stephens LLP, is one of the few qualified reviewers to conduct the GST Assisted Compliance Assurance Programme (ACAP) review which would assist companies to endorse the effectiveness of the business’ GST controls and compliance with GST reporting requirement.

Our GST services include:

  • Application of GST registration / de-registration /exemption from GST registration
  • Review and e-filing of GST returns
  • Perform GST health check review
  • Conduct ASK / ACAP reviews for the application / renewal of GST schemes / voluntary disclosure of errors
  • Managing and responding to IRAS queries
  • Preparation of submission / ruling to the IRAS or tax concessions
  • Managing IRAS audits / investigations
  • Perform analysis on business transactions and advise of GST complication arising from such transaction
  • Conduct customised in-house GST trainings

Transfer pricing has emerged as one of the most important and critical areas of tax policy and administration, tax planning and tax controversy for global corporates in Singapore. We assist companies in decision making at various stages of their related-party transactions such as planning, policy making, strategy, implementation, compliance and defence.

Our Transfer Pricing professionals provide comprehensive solutions tailored to your business objectives after understanding the exact nature and the extent of the related party transactions undertaken by the company. We have a specialised transfer pricing team that is competent to assist you in the following areas of transfer pricing.

Transfer Pricing Documentation Services

Preparation of comprehensive OECD or local regulation / guideline compliant transfer pricing documentation for your Singapore and overseas entities, which includes: 

  • A fact-finding exercise to understand and document the:
    • Group and entity level information of your company relevant to the related-party transactions;
    • Nature of the industry in which your company and the related parties operate in; and
    • Functions performed, risks assumed and assets used by your company and/or the related parties.
  • Evaluate the internationally accepted transfer pricing methods and select the most appropriate transfer pricing for the related-party transactions.
  • Undertake a search for regional / local comparable companies / comparable transactions using databases and conduct economic and financial analyses on the selected comparables / transactions.
  • Prepare a comprehensive transfer pricing documentation incorporating the above steps.

Transfer Pricing Due Diligence, Advisory and Planning

  • Conduct transfer pricing health checks for related-party transactions to identify significant transfer pricing inconsistencies, gaps, and potential risk areas as well as providing risk mitigation options in line with your business objectives, for your consideration.
  • Undertake transfer pricing planning studies to determine the most appropriate transfer pricing policy for newly set up companies / new business lines or units / new related-party transactions.
  • Review or prepare your inter-company agreements from a transfer pricing perspective.

Transfer Pricing Dispute Resolution

  • Defend your transfer pricing policies against challenges from tax authorities.
  • Assist with the mutual agreement procedures (MAP) process to resolve double taxation.
  • Assist with the advance pricing arrangement (APA) process to ensure tax certainty for your future transfer prices.

Country-by-Country Reporting (CbCR)

Assist your group of companies’ CbCR obligations globally, which includes:

  • Identify CbCR notification requirement and the respective deadlines.
  • Support on the various CbCR concepts and definitions for data gathering purposes.
  • Review the data gathered to identify potential risk areas, if any.
  • Convert the data into the standardised electronic format for the exchange of CbC reports between jurisdictions in an encrypted format called XML.
  • File the CbC report with the relevant tax authority.
CONTACT PERSON
Lim Peng Huat
+65 6329 2741
Law Pei Serh
+65 6329 2726