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Taxation Agreement
"Need a Taxation Agreement for our Singapore subsidiary that covers transfer pricing arrangements with our parent company in Japan, to be effective from January 2025, ensuring compliance with both IRAS guidelines and international tax treaties."
1. Parties: Identification of the contracting parties including tax residency status
2. Background: Context of the agreement and relationship between parties
3. Definitions: Key terms used in the agreement including technical tax terminology
4. Scope of Taxation: Types of taxes covered under the agreement
5. Tax Treatment: Specific provisions for various types of income and gains
6. Compliance Obligations: Requirements for tax reporting and documentation
7. Dispute Resolution: Procedures for resolving tax-related disputes
1. Transfer Pricing Provisions: Specific provisions for related party transactions and transfer pricing methodologies
2. Tax Credits: Methods and procedures for avoiding double taxation between jurisdictions
3. Anti-Avoidance Provisions: Specific measures and clauses to prevent tax avoidance schemes
1. Schedule of Tax Rates: Detailed breakdown of applicable tax rates for different types of income
2. Documentation Requirements: Comprehensive list of required supporting documents and records
3. Calculation Methods: Agreed methodologies for calculating taxable income and adjustments
4. Compliance Calendar: Timeline of tax filing and payment obligations throughout the year
Authors
Applicable Tax Rate
Assessment Period
Beneficial Owner
Competent Authority
Connected Person
Contracting Parties
Effective Date
Financial Year
GST
Income
IRAS
Permanent Establishment
Related Party
Reportable Transaction
Singapore Dollar (SGD)
Tax Liability
Tax Period
Tax Resident
Taxable Income
Taxable Supply
Taxation Laws
Transfer Pricing
Withholding Tax
Year of Assessment
Tax Residency
Calculation of Tax
Payment Terms
Withholding Obligations
Reporting Requirements
Record Keeping
Transfer Pricing
Double Taxation Relief
Information Exchange
Compliance Obligations
Audit Rights
Dispute Resolution
Confidentiality
Force Majeure
Anti-Avoidance
Amendment Procedures
Governing Law
Termination
Notices
Indemnification
Severability
Assignment
Entire Agreement
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