Transfer Pricing Adjustments on Imports
Learn how to handle transfer pricing adjustments for imported goods, including dutiable motor vehicles, documentary requirements and GST treatment.
What Transfer Pricing Means
Transfer pricing (TP) refers to how prices are determined for transactions between related parties.
These prices must follow the arm’s length principle, meaning they should reflect the price that independent parties would have been agreed under similar conditions.
For TP adjustments involving other dutiable goods (except for motor vehicles), non-dutiable goods, or GST treatment, refer to the IRAS e-Tax Guide on TP adjustments.
TP Adjustments for Dutiable Motor Vehicles
For TP relating to dutiable motor vehicles, companies must:
Allocate TP adjustments (upward or downward) on a per-unit basis for each vehicle.
Report the adjustments to Singapore Customs for verification before:
Declaring any short-payment permit(s) for underpaid excise duties, or
Submitting a refund claim for overpaid excise duties.
Documents Required for Customs Verification
Companies must submit the following:
TP Policy and Study
Explanation of how the adjustment results in an arm’s length value
Invoice(s) showing the TP adjustment amount
List of affected vehicles, including:
Make and model
Engine and chassis numbers
Corresponding permit number
Original customs value
TP adjustment amount
Final customs value
Any other supporting documents requested by Customs
You may submit these documents through the Singapore Customs Voluntary Disclosure Programme.
After TP Adjustments Are Accepted by Customs
Upward Adjustments
Upward adjustments mean that the vehicle value increases.
Companies shall:
Pay the additional duties and GST short-paid
Report to the Land Transport Authority (LTA) to pay the extra Additional Registration Fee (ARF)
Companies may wish to check with IRAS on whether the company satisfies IRAS’ conditions for input tax claim on GST.
Downward Adjustments
Downward adjustments mean that the vehicle value decreases.
Companies may:
Apply for a refund of duties and GST
Check with Check with on how to treat the GST overpaid in the GST return
Check with LTA on how to claim a refund for overpaid ARF
