Chapter Twenty-Seven

Singapore Transfer Pricing Guidelines for Related Party Loans and Services

The Inland Revenue Authority Of Singapore (IRAS) issued Transfer Pricing Guidelines for Related Party Loans and Related Party Services on February 23, 2009. As background, the IRAS had issued draft supplementary guidelines for related party loans and services on October 21, 2008. The draft supplementary guidelines were subject to public comment. The IRAS took these comments into account in finalizing the Transfer Pricing Guidelines for Related Party Loans and Related Party Services.

The loan guidelines and the services guidelines supplement the February 23, 2006, transfer pricing guidelines. The supplementary guideline circular addresses these issues:

• Interest-free loans
• The 5% markup on costs applied in the services context
• No-markup services provided by one service provider to another service provider

All citations, except as noted, pertain to the Transfer Pricing Guidelines for Related Party Loans and Related Party Services that the IRAS issued on February 23, 2009.

The IRAS believes that the arm’s length principle is the “most appropriate standard” to determine the transfer prices for related party transactions.1 As such, the IRAS abides by this arm’s length principle. The IRAS recognizes that the arm’s length principle should apply to all related party transactions. Nevertheless, despite this affirmation of the arm’s length principle, the IRAS recognizes that “a mechanical application” of the arm’s length principle could give rise to difficulties and concerns for businesses. The IRAS recognizes that, in some cases, the conduct of a comprehensive analysis for the purpose of demonstrating compliance with the arm’s length principle might not be practical. As such, the IRAS will allow practical alternatives to the arm’s length principle to assist taxpayers with complying with the principle.

The IRAS is increasingly concerned about the increased level of cross-border related party transfers. The IRAS points out that most tax authorities, implicitly including itself, focus on these cross-border related party transactions, doing so to ensure that the transactions do not erode their tax bases. The IRAS warns that a tax authority that makes a transfer pricing adjustment concerning cross-border related party transactions may cause double taxation to the taxpayer. The IRAS then suggests that the taxpayer having related party transactions establish arm’s length transfer pricing policies and maintain adequate documentation to minimize the incidence of double taxation.2

TRANSFER PRICING GUIDELINES FOR RELATED PARTY LOANS

As a general matter, the Singapore loan guidelines provide that an entity that undertakes a loan made to a related entity should charge the related entity for the use of funds at a rate that reflects an arm’s length rate of interest. The arm’s length rate is the rate of interest that an independent party would charge to the recipient under similar circumstances. In other words, the arm’s length rate of interest is the interest rate that the lender of the funds would charge to provide funds to borrowers that are independent of the lender.3

Such a related party loan includes a loan in which a related party lends money, in one form or another, irrespective of whether the party makes the loan through a written agreement or afterward.4 Such a related party loan includes credit facilities or intercompany balances that arise from the normal course of sales or services. The credit balance provision applies to services that are “left uncollected over a substantial period of time,” the time period beyond which a third party creditor would typically allow.

TWO LOAN CATEGORIES

The Singapore loan guidelines delineate two types of related party loans:5

A “domestic entity” means any business entity that is incorporated in Singapore or registered in Singapore and is carrying on a business in Singapore.

Domestic Loan Provisions

The Singapore loan provisions postulate that, in adhering to the arm’s length principle, an entity that makes a loan to another related entity or otherwise becomes a creditor of another related entity should charge the related entity for the use of funds at a rate that reflects an arm’s length rate of interest.6 The Singapore loan provisions define the arm’s length rate of interest in the case of loans as the rate of interest that should have been charged between independent parties under similar circumstances at the time the evidence arose.7 The IRAS defines the arm’s length rate of interest as “the interest rate that a lender of the funds would charge to provide funds to borrowers that are independent of the lender.”

As to the treatment of related domestic loans, the IRAS recognizes that it currently had been common practice for entities to extend interest-free loans, or to receive interest-free loans, or for entities to extend or receive interest-bearing loans at rates that are not supported by transfer pricing analysis to or from other related entities. In the past, the IRAS had not strictly required entities making these loans to adopt an arm’s length procedure to determine the rate of interest. The IRAS has now agreed to accept this prior non–arm’s length practice as to domestic loans. Nevertheless, the IRAS will accept this non–arm’s length practice only to related party domestic loans and then only where the lender is not in the business of borrowing and lending funds. The final loan guidelines would restrict the amount to any interest expense claimed by the lender on such loans, where applicable.8

During the review process following the issuance of the proposed loan regulations, taxpayers expressed their concern that the IRAS requirement regarding applying arm’s length methodology to all related party loans would result in complications for these taxpayers and would result in increased compliance cost. These taxpayers requested that the IRAS continue with the current practice of restricting the interest expense claimed as a proxy to the arm’s length principle.9

The IRAS reviewed the taxpayers’ suggestion. At the outset, it was the view of the IRAS that the arm’s length principle is the correct and most appropriate standard for determining the rate of interest in related party loans. Interest adjustments applied at the lending entry level may serve as a proxy to the arm’s length principle under certain circumstances. Nevertheless, the interest adjustment is not a perfect proxy and may address concerns of revenue leakage partially under certain other circumstances for domestic purposes vis-à-vis a case where arm’s length methodology is applied.10 The IRAS provides as an example the fact that the limit on the tax deduction is of minimal impact if the lending entity does not incur interest expense.

The IRAS sought to take into account the taxpayers’ feedback and other considerations. The IRAS agreed to facilitate the efforts of domestic taxpayers in complying with the arm’s length standard by continuing the current practice of making adjustments on lenders that make loans to related entities that are interest-free or otherwise at interest rates that are not supported by transfer pricing analysis.11 The IRAS will apply this practice only to domestic loans, and where the lender concerned is also not in the business of borrowing and lending funds, such as through banks or other financial institutions or finance and treasury centers.

International Loan Provisions

The Singapore loan guidelines take a stronger stance in enforcing arm’s length pricing in the case of related cross-border loans than they do for related domestic loans. The IRAS recognizes that some domestic lenders may have extended loans to foreign-related entities and that these loans may be tax-free or at interest rates not supported by transfer pricing analysis. These domestic lenders may need time to restructure the loans to reflect commercial conditions and obtain an arm’s length rate of interest.12

Here the IRAS would enforce the arm’s length rule, but only after a two-year transition period beginning January 1, 2009. The IRAS has recognized that some domestic lenders might have extended loans to foreign-related entities on an interest-free basis or otherwise at interest rates that the transfer pricing analysis does not support. Beginning January 1, 2011, the IRAS would require all cross-border loan arrangements to reflect arm’s length conditions.

The Singapore loan guidelines recognize that the observance of the arm’s length standard is part of Singapore’s tax treaty obligations and that the arm’s length standard is the internationally adopted standard. As such, the loan guidelines warn the taxpayer that chooses to extend interest-free cross-border loans to related parties or extend interest-bearing cross-border loans not supported by transfer pricing analysis to related parties. These taxpayers should then recognize these loans might be subject to higher risk of unresolved disagreements when these loans are subject to transfer pricing audits and adjustments.13 Thus, double taxation is more likely to result.

FACTS AND CIRCUMSTANCES TO DETERMINE COMPARABILITY ANALYSIS

The Singapore loan guidelines provide nine nonexclusive comparability factors to determine the arm’s length rate:14

The Singapore loan guidelines, in determining the interest rate, specifically prefer the comparable uncontrolled price (CUP) method for loans. The IRAS favors the CUP method because of its conceptual superiority compared with other methods and because it is often found to be the most suitable method of loan transactions.15 Nevertheless, a taxpayer can select a different transfer pricing method for its loans if the taxpayer believes this other method to be more appropriate. In addition, the taxpayer needs to maintain documentation to justify why that method is more suitable.

The IRAS suggests that the taxpayer rely on a suitable reference rate for comparability purposes. The IRAS suggests two reference rates and permits the taxpayer to apply other rates:

• Singapore Interbank Offered Rate (SIBOR)
• London Interbank Offered Rate (LIBOR)
• Prime rates offered by banks
• Special rates quoted by banks for similar loans

The taxpayer can make adjustments to the reference rate, based on the outcome of the comparability analysis the taxpayer undertakes, to arrive at the appropriate arm’s length rate or a range of rates.16

TRANSFER PRICING GUIDELINES FOR RELATED PARTY SERVICES

The Singapore services guidelines address the application of the arm’s length principles to related party services, here termed “intragroup services within a group of companies or businesses.” The Singapore services guidelines recognize that related parties within a group would arrange for a wide array for services to one or more members of the group.17 Such services may include, for example, these activities:

• Administrative services
• Technical services
• Financial services
• Commercial services
• Management services
• Coordination services
• Control functions

The Singapore services guidelines do not address other services activities that the taxpayer might view as profit-center activities. Such noneligible activities include:

• Sales activities
• Leasing activities
• Engineering activities
• Manufacturing activities

The Singapore services guidelines apply certain of the arm’s length principles only on a prospective basis.18

The first order of business, from the standpoint of the Singapore services guidelines, is to ascertain whether one party provided services to another party. However, the services guidelines fail to provide such an established set of strict criteria to determine whether one party provided services to another. The IRAS recognizes that it is not possible to establish a set of strict criteria to determine if an activity amounts to a service provided.19 Instead, the taxpayer is to look to the surrounding facts and circumstances. Generally accepted considerations apply to determine whether one company in fact provided services to another company.

As a general matter, one party provides services to another when the provider of services receives benefits from these activities or, alternatively, when the provider of the services expects to receive benefits from such activities. Services are considered to have taken place when there is a reasonable expectation or intention of providing services conferred or received, even if the expected service does not eventually materialize.20

The benefit that a party receives or provides must have economic or commercial benefit such that an independent party would expect to receive or pay for that service. The benefit must be identifiable and capable of being valued. Hence, the benefit must be sufficiently direct and substantial. No service is considered to have been provided if the benefit to be derived from an activity is not what an independent party in comparable circumstances would be willing to pay for or to carry out for itself.21

The Singapore services guidelines recognize that it is common for a parent company, or for a designated entity within a group of companies, to undertake activities that benefit the group as a whole. Such centrally performed entities can include, for example, administrative functions, financial functions, and personnel functions. The central thrust of Singapore’s service provisions are activities that an independent party would be willing to pay for, or to perform for itself.22

As a general matter, a taxpayer views a service as having been provided when the taxpayer meets an identified need of the related party or a group of related parties by performance of these services by another related party. An independent party would have either engaged the services of a third party or performed the activities itself to fulfill the need. Consequently, although the performance of an activity confers a benefit to a related party that has no need for such activity, then no services are deemed provided. When the benefit is too remote, no service is deemed provided.23

DIRECT CHARGING VERSUS INDIRECT CHARGING OF SERVICES

The Singapore services guidelines delineate both the direct charge method and the indirect charge method. The service provider can adopt the direct charge method or the indirect charge method, as the service provider determines:24

• Direct charge method. Under the direct charge method, the service provider would identify clearly the actual work the service provider performs, the costs that the service provider expended, and the basis of making that charge. The Singapore services guidelines prefer the direct charge method in charging for related party services because the direct charge method facilitates the tax authorities’ review and examination. Nevertheless, the services guidelines favor the direct charge method only in the context of providing specific services, such as, in an example in the services guidelines, in conducting a market survey for a particular product developed by a related party. The prerequisite for applying the direct charge method is where the beneficiary of the services and the costs incurred for the performance of the services are usually identifiable.25
• Indirect charge method. The indirect charge method entails the use of an appropriate apportionment basis or allocation key to charge or to bill for services provided.26 Such apportionment basis or allocation key includes, for example, gross sales, income, or receipts, loans and deposits, staff numbers, floor area, and asset size. The IRAS recognizes that it might not be practical for taxpayers to adopt the direct charge method for all related party services to the members belonging to the same group or to services performed specifically for individual recipients. The IRAS suggests that accounting services, for example, would be better accounted for under the indirect charge method to approximate the charges.

The central ingredient in applying the indirect charge method is the selection of the apportionment basis or the allocation key. The services guidelines imply that the service provider must select an apportionment basis or allocation key that is appropriate. This selection of the allocation key depends on the nature and use of the services.27

As a general matter, the most appropriate allocation key is the method that most accurately reflects the share of the benefits the beneficiary receives or expects to receive. The services guidelines acknowledge that the taxpayer selects the allocation key and that that choice is largely a question of judgment. The services guidelines expect the taxpayer to use judgment to demonstrate that it has undertaken in choosing the allocation key.

The IRAS is prepared to accept the allocation key that the taxpayer adopts so long as the allocation key meets these criteria:

• The allocation key must be reasonable.
• The allocation key must be founded on sound accounting principles.
• The taxpayer applies the allocation key consistently year to year throughout the group unless there are very good reasons for failing to do so.

ASCERTAINING THE ARM’S LENGTH FEE

After the service provider determines which charging method is appropriate, the next step is to determine the arm’s length fee for services the service provider provides. This remuneration should be in accordance with the arm’s length principle, based on a comparability analysis with an independent party.28 The services guidelines suggest that the taxpayer undertake this analysis from the perspective of both the service provider and the recipient of the services. This charge is the amount that a service provider would charge an independent party, taking into account the service provider’s costs and the amount than the recipient is willing to pay for that service. The parties are to consider what the service provider would have otherwise paid to independent parties for similar services under similar circumstances.29

The taxpayer is to be guided by what services guidelines term “important considerations,” such as these, when determining the appropriate transfer pricing method:

• Nature of the transaction
• Availability of the data
• Quality of the data

This services analysis is directly applicable to related party services.

Notwithstanding this services analysis, however, the services guidelines indicate that CUP and the cost plus methods are most often the most appropriate choices for determining the arm’s length fee for related party services.30

ROUTINE SERVICES AND THE 5% MARKUP

The services guidelines refer to “a common practice [in Singapore] among parent companies or group service companies to charge a 5% markup on costs incurred for providing certain routine support services.” The services guidelines postulate that the service provider provides these services for the purposes of business convenience and efficiency, centralizing these routine support services within the parent company or a group service company. The services guidelines provide three such nonexclusive examples: the performance of accounting services, of payroll services, and of certain other management or administrative functions. The services guidelines then acknowledge that related companies might, in practice, based on their own business considerations, provide intragroup services to one another even when these services activities are beyond routine services.31

The issue as to whether a 5% cost markup conforms to the arm’s length principle depends on three facets:

The IRAS is prepared to accept the current 5% markup for certain routine support services as a reasonable arm’s length charge for these services on the proviso that the service provider, in providing these routine support services, does not also offer these routine support services to an unrelated party. The objective of the IRAS is to facilitate taxpayers’ compliance with the arm’s length standard while maintaining a high level of adherence to the arm’s length principle, based on industry norms. The services guidelines accept the practicality that performing a proper transfer pricing comparability analysis for every type of service would greatly increase the administration and compliance for the taxpayer and would increase the administration costs of evaluating them.

The IRAS is prepared to accept the current 5% markup adopted for certain routine support services as a reasonable arm’s length charge for such services. The IRAS is willing to make this determination to facilitate taxpayers’ compliance with the arm’s length standard while maintaining a high level of adherence to the arm’s length principle. The IRAS requires, for the 5% cost markup to apply, that these routine support activities that the service provider offers to its related party are not also provided to an unrelated party.32

A taxpayer, in charging routine support services at a 5% markup, needs to take into account all costs for this purpose that are directly related or indirectly related to the services performed. The direct costs include, for example, materials consumed and labor expended to render these services. The indirect costs include, for example, overheads, depreciation, and telecommunication expenses that the department provides to the department providing these services.33

The Singapore services guidelines provide Annex A, which lists routine support services that companies commonly provide on an intragroup basis across many industries. The IRAS can modify or expand the list of routine services in the future. These routine support services do not generate a significant arm’s length markup. This list is nonexhaustive, but the taxpayer must follow the existing list of routine services.34 The list includes:

• Accounting and auditing services, including maintenance of accounting records, preparation of financial statements based on such records, ensuring authenticity and reliability of accounting records, and so forth, including the performance of operational and financial audits.
• Accounts receivable and accounts payable services, including the collation and verification of data pertaining to accounts receivable and accounts payable, undertaken for the purposes of financial reporting, aging, billing, soliciting payments from customers, payment to vendors, procurement, and so forth.
• Budgeting services, including the compilation of data for preparing budget estimates, reports, and so forth.
• Computer support services, including providing technical services and troubleshooting support services in relation to the usage of computer hardware, computer software, maintenance of intellectual property software, and so forth.
• Database administration services, including the general maintenance of computer databases, including data storage, but excluding analytic services performed on stored data.
• Employee benefits services, including the administration of employee compensation and benefit plans, such as health care, life insurance, dental, employee incentive compensation, profit sharing plans, and so forth; and including the coordination with external parties, such as hospitals, insurers, and so forth to implement such benefit plans.
• General administrative services, including the performance of clerical and administrative functions, such as data entry, photocopying, scanning of materials, scheduling of appointments, word processing, file maintenance, and so forth.
• Legal services, including the providing of legal services by in-house legal counsel.
• Payroll services, including the compilation and verification of employees’ time worked and employee claims for reimbursable expenses to compute salaries, commissions, and reimbursements. Payroll services include the payment of paychecks and arranging credit of such payments into employees’ bank accounts.
• Public relations services and corporate communications, including the handling of internal and external communications relating to corporate policies.
• Purchasing services, including the procurement of goods and services based on organization requirements or based on standards.
• Staffing and recruiting services, including the management of staffing requirements, performance issues, and staff welfare in the organization or group and the implementation of recruitment plans, such as publicizing open positions and candidate screening, and so forth.
• Tax services, including the preparation of various tax returns, computations, refund claims, and responses to inquiries for submission to the tax authorities, the processing of tax payments, and so forth.
• Training and employee development services, including the management and implementation of employee training and development programs.

The draft of services guidelines included purchasing services, including the procurement of goods and services based on organization requirements or based on standards. The final services guidelines exclude the purchasing services category.

The IRAS is prepared to consider adding additional services on further review where taxpayers view that certain of these intragroup services are routine support services but are not included in this routine support list. The IRAS’s acceptance of a 5% markup for routine services provides taxpayers with an alternative to having service providers undertake a detailed transfer pricing analysis. These service providers might have undertaken a detailed transfer pricing analysis that supports the charging for services at different markups other than 5%. In the event that this difference occurs, the service provider should adopt that alternative markup. Once the taxpayer adopts the arm’s length markup, the taxpayer should apply this markup consistently year after year throughout the group until there are material changes to the circumstances or to the services that the service provider provides. These service providers should regularly review the markup they have adopted to make sure that the markup continues to reflect arm’s length conditions in their situations.35

COST POOLING CONTRACTS

The IRAS has developed a virtually new and quite useful transfer pricing technique termed “cost pooling.”36 Taxpayers can apply this cost pooling technique to certain routine services expenditures that occur among related parties with the corporate group. Cost pooling arrangements differ in numerous respects from cost contribution arrangements (or cost sharing arrangements) that taxpayers enter into primarily to develop intangible assets. Regrettably, the Singapore services guidelines fail to distinguish between cost pooling arrangements and cost sharing arrangements.

Taxpayers that have exceptional circumstances might find it mutually beneficial to enter into a cost pooling contract among members of the corporate group.37 The cost pooling contract enables members of the corporate group to share in the costs of routine support services for the common use of the group to meet a common need of the members. The cost pooling arrangement allows the members of the corporate group to pool resources together in order to acquire services that meet these parameters:

• A party to the cost pooling contract must have a reasonable expectation of benefiting from or must actually benefit from the services for which costs are being shared.
• Contributions by related parties to the costs of providing the services must be made in proportion to the nature and extent of the expected benefits that each party receives.
• Each party’s share of the costs in the cost pooling arrangement must be borne in the form of cash or by other monetary contributions.

The proposed services guidelines had provided that the arrangement must be necessary for the corporate group to function effectively. The final services guidelines eliminate this requirement.

Additional pooling requirements are:38

• The arrangement is to acquire services that are not the principal activities of the corporate group.
• The arrangement is not intended to be a profitable exploit of the corporate group.
• The arrangement must address mutual benefit among members of the group.
• The party to the arrangement must reasonably expect to benefit from the shared services or actually benefit from the shared services.
• The party to the arrangement must determine the contribution as to the costs of providing the service in proportion to the expected benefits that each party receives.
• Each party must bear the share of its costs in the form of cash or other contributions, and nothing else.
• To satisfy the arm’s length principle, each participant’s share of the costs must be consistent with the costs to which an independent party would have agreed under comparable circumstances, given the benefit the participant would have expected to derive from the services being provided.

The services guidelines provide specific parameters for the allowance of the cost pooling arrangement:39

• The arrangement must be termed a proportionate share of the cost of the services.
• The arrangement can be determined on a prospective basis.
• The arrangement is to be determined with no element of markup.
• The service provider that offers its services to its related parties does not offer these same services to unrelated parties.
• The service provider, in providing these services to related parties is not the principal activity for which the service provider is to undertake. The term “principal activity” is based on facts and circumstances, based on a 15% threshold.
• These provisions apply to Annex A services.
• The taxpayer provides sufficient documentation to show that the parties intended to pool their resources to share costs, doing so before the service provider performs the services.

The services guidelines require the taxpayer to maintain adequate documentation to support the cost allocation as being arm’s length. The services guidelines require the taxpayer to maintain adequate documentation to demonstrate the sharing of expected benefits arising from providing these services. The proposed services guidelines were concerned about the taxpayer’s risk of double taxation and suggested that the taxpayer retain the following documentation:40

• Description of the type of services provided
• Rationale for selecting a specific cost method
• Nature of the related parties’ contributions
• Anticipated benefits
• Calculation details

STRICT COST PASS-THROUGH

Singapore’s services guidelines address two separate procedures to aggregate and distribute services costs:

A group service provider might occasionally arrange and pay for services from third-party providers. A third-party provider can undertake this service on behalf of the related parties in the group, but the third party can be independent from the related party or can be related to that party. A third-party service provider or a related party service provider might have already charged the members an arm’s length markup for their services. In the event that the provider has already charged the members for these costs, it may be appropriate for the group service provider to pass on these costs without incurring further markup. The parties are to pass on the costs without markup if the group service provider is merely the paying agent, and the group service provider itself does not act to enhance the value of these services.

The IRAS is prepared to accept that these costs may be charged without a markup to the related party for whose benefit the services are provided. These costs must meet the next preconditions:41

• The costs are the legal liabilities or the contractual liabilities of the related party.
• The group service provider is merely the paying agent, and the service provider does not itself act to enhance the value of such services.

Singapore’s services guidelines provide an example of the strict cost pass-through method.42 Assume that a group service provider incurs expenses on behalf of a related party to pay for the costs of engaging a third-party firm to provide various corporate secretarial services for its related party. The parties can identify the costs as legal or contractual liabilities of the party itself. The group service provider is the paying agent. The group service provider can pass on these costs to the related party, doing so without markup.

Singapore’s services guidelines provide that the group service provider is to ensure an arm’s length markup for its own aggregate costs of providing the services.43 This markup is to be reflective of the nature of the services rendered by the service provider and the extent of the value-added amount that benefits the participants who receive these services. The aggregate costs that related parties incur should include its own costs incurred, if any, in facilitating the purchase of services from third-party service providers or from related party service providers. Returning to the prior example, assume that the group service provider used its own resources to arrange, select, and liaise in having the third-party firm provide corporate secretarial services. In that event, the group service provider should charge this cost to its related parties at an arm’s length markup.44

DOCUMENTATION

The main transfer pricing circular highlights the importance of documentation. Documentation is important for loan and services transactions, and the taxpayer should refer to the main transfer pricing circular for guidance on appropriate documentation.45

NOTES

1. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 1.2.

2. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 1.3.

3. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.

4. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.1.

5. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.2.

6. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.3.

7. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.4.

8. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.5.

9. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.6.

10. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.7.

11. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.8.

12. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.9.

13. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.1.10.

14. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.2.2.

15. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.2.3.

16. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 2.2.4.

17. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.1.1.

18. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.1.2.

19. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.2.1.

20. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.2.2.

21. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.2.3.

22. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.2.4.

23. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.2.5.

24. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.2.

25. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.3.

26. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.4.

27. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.5.

28. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.6.

29. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.7.

30. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.8.

31. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.9.

32. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.10.

33. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.11.

34. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.12.

35. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.13.

36. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.14.

37. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.15.

38. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.16.

39. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.16.

40. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.16.

41. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.18.

42. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.18.

43. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.19.

44. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 3.3.19.

45. Transfer Pricing Guidelines for Related Party Loans and Related Party Services, 4.1.