1. IFA Korea 2016 Intra Group Services SINGAPORE

2. Singapore System Semi territorial: Only Singapore sourced income and foreign sourced income that is brought into Singapore can be taxed. (Section 10 SITA) Permanent establishment rules: Under domestic Singapore legislation the PE concept is broadly defined, however does not include the recognition of a service PE. (Section 2 (1) SITA) Withholding tax rules: For income to be subjected to Singapore withholding tax, it should be Singapore sourced, or deemed Singapore sourced (Section 12 SITA) Transfer pricing rules: Section 34D SITA IRAS e-Tax Guide Transfer Pricing Guidelines (Third Edition), 4 January 2016 Follows largely the OECD guidance.

3. Singapore Position in the Global economic scene Type of economy: Fully open economy with free flow of capital. Incentive system: Acknowledging being a small country with no natural resources, Singapore understands the importance of being a facilitator for international business in a stable political environment. Incentives are offered to bring real business activity to Singapore. Mostly recipient of income: With the relatively low tax rate, but more importantly, limited tax base, Singapore is mostly a recipient of intra group income. Position towards BEPS: Singapore fully supports the BEPS initiative, and in the recent update of the TP guidance, the BEPS report has been factored in. Having said that, Singapore also clearly takes the position that countries have their autonomous rights, and their right to protect their own position in the global economy.

4. Specific issues related to intra-group services Base erosion: Section 14 SITA; For the purpose of ascertaining the income of any person for any period from any source chargeable with tax under this Act (referred to in this Part as the income), there shall be deducted all outgoings and expenses wholly and exclusively incurred during that period by that person in the production of the income Section 33 SITA; Anti-abuse rule Section 34D SITA; Transfer Pricing section Transfer pricing: Low value add or routine services; 5% mark up Service PE; No intention shared to introduce the service PE concept under domestic law. Withholding tax: Applies (subject to further conditions) when (management) services are performed in Singapore Services performed in low-labor cost countries: Singapore is high cost/ low tax, so pressure is on the other side