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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
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