Articles

AI is transforming transfer pricing, offering efficiency and predictive compliance but posing risks of opacity and bias. It is a net opportunity only with robust human oversight, explainability, and regular audits. Without safeguards, AI threatens the arm's length principle and procedural fairness. Success requires transparency and accountable human judgment.

Three Singapore obstetricians lost a High Court challenge over tax avoidance. They paid themselves low salaries (S$5,000–S$6,000 monthly) while taking millions in dividends and interest-free loans from personal companies. IRAS deemed the arrangement artificial, as salaries weren't market-rate and didn't reflect growing profits. The court upheld revised tax assessments, with penalties now including a 50% surcharge.

The Indian Supreme Court in Tiger Global (2026) incorrectly used anti-abuse (GAAR) standards to determine treaty residence, reversing the legal sequence. This merges distinct inquiries—residence status and benefit denial—undermining bilateral treaty certainty. The ruling transforms a fixed status into a variable one, creating instability for cross-border investment planning.