Article by Belinda Lim, Associate Director, Transfer Pricing Tax Lead at CLA Global TS.
Similarities Between The Garfield Movie and Transfer Pricing
The school holidays are here, and this coincides with the very recent release of The Garfield Movie. Many of you must be wondering-ok, how is The Garfield Movie related to transfer pricing?
Aplenty! However, we will be focusing on key similarities only. For those who are planning to watch The Garfield Movie, please be warned of spoilers ahead.
Similarity 1: Highly Anticipated Release
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| The last Garfield movie was in 2006. That is almost 20 years ago!
So one can imagine the fans delight when the Garfield Movie was finally released. |
Similar to the long-anticipated release of the 2024 Garfield movie, Singapore transfer pricing professionals are similarly anticipating the seventh edition of the Transfer Pricing e-tax guide as the last update was in 2021.
From the sharing session by the Inland Revenue Authority of Singapore (“IRAS”) last year, it was announced that the e-tax guide is targeted to be released this year. It is now June and there is no release yet but we hope that the wait will not be too long. |
Similarity 2: New Feature
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| For those of us who are avid Garfield fans and who have been following the past movies and comics, Garfield’s dad has never been featured. In the new Garfield movie, Garfield’s dad appeared which is essentially the centre of the movie’s plot.
Indeed, everyone knows that Garfield must have a dad. However, it has not been featured and thus there was no buzz surrounding this before the Garfield Movie. |
We do not have crystal balls (though we wish we have) but we suspect with the many recent developments on BEPS Pillars 1 and 2 internationally and within Singapore itself, the new Transfer Pricing e-tax guide would feature BEPS Pillars 1 and 2.
Similar to the Garfield Movie, we are aware about BEPS Pillars 1 and 2. However, as the two pillars have not been featured specifically in the past e-tax guides, not much attention has been given to the impact of this. This is likely to change, when these are specifically featured in the e-tax guide and/or transfer pricing legislation. |
Similarity 3: Scratches from the past
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| The Garfield Movie plot is on Garfield’s dad’s past catching up with him whereby the villain cat wanted to seek revenge as Garfield’s dad allowed her to be captured and taken to the pound in the past. | Similar to the Garfield Movie, past decisions made on transfer pricing will eventually scratch you and have to be dealt with.
Thus, it is always best practice to not only be aware of the developments around us and possible impact to transfer pricing but to anticipate these and do the necessary to manage one’s transfer pricing risks now and not wait till these have been spelt out specifically by the IRAS. |
Similarity 4: Innovative Solutions
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| In the Garfield Movie, Garfield was very innovative, not only applying the lessons his father taught him on their milk heist but by using takeout drones to attack the villain cat. This eventually allowed him to pull off a successful and heartwarming rescue. | Similar to the Garfield Movie, in solving new and ever dynamic transfer pricing issues, we not only have to apply the past tried and tested solutions (i.e. transfer pricing documentations, benchmarking studies, operational transfer pricing, intercompany agreement etc) but also come up with innovative tweaks to successfully manage transfer pricing risks. |
View the full article in PDF here.
CONTACT US
Tax Advisory Specialists
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Edwin Leow Co-Advisory Leader Director, Head of Tax edwinleow@sg.cla-ts.com |
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Belinda Lim Associate Director, Transfer Pricing Tax Lead belindalim@sg.cla-ts.com |
