The threshold for related party transactions to be exempted is:
- Where the taxpayer transacts with a related party in Singapore, and such local transactions (excluding related party loans) are subject to the same Singapore tax rates for both parties;
- Where a related domestic loan is provided between the taxpayer and a related party in Singapore, and the lender is not in the business of borrowing and lending;
- Where a taxpayer applies the indicative margin for a related party loan not exceeding SG$ 15 million;
- Where the taxpayer applies a 5% cost mark-up for routine services in relation to the related party transactions concerned;
- Where the related party transactions are covered by an agreement under an Advance Pricing Agreement. In such a situation, the taxpayer will keep the relevant documents for the purpose of preparing the annual compliance report, in order to demonstrate compliance with the terms of the agreement and the critical assumptions remain valid;
- Where the value or amount of the related party transactions (excluding the value or amount in sub-paragraphs (a) to (d) above) that have been disclosed in the current year’s financial accounts do not exceed the thresholds shown in the following table:
Category of transaction | Value (S$ million) |
Purchase of goods from a related party/ related parties | 15 |
Sale of goods to a related party/ related parties | 15 |
Loan to a related party/ related parties | 15 |
Loan from a related party/ related parties | 15 |
All other related party transactions | 1 |