Key updates in the Singapore Transfer Pricing Guidelines (Eighth Edition)

On 19 November 2025, the Inland Revenue Authority of Singapore (IRAS) released the Eighth Edition of its Transfer Pricing Guidelines, introducing important enhancements and clarifications to Singapore’s transfer pricing framework.

The updates align Singapore’s rules more closely with international developments, including BEPS 2.0, and provide clearer guidance on areas such as related-party financial transactions, application of the arm’s length principle, annual review and documentation of financing arrangements, simplified and streamlined approaches for baseline distribution activities, mutual agreement procedures, capital transactions, recourse options for disputed TP adjustments, profit attribution to permanent establishments, simplified TP documentation, and strict pass-through costs.

These changes collectively aim to reduce uncertainty, ease compliance in appropriate cases, and reinforce IRAS’ expectation that taxpayers maintain robust, defensible TP positions.

Key updates in the TPG Eighth Edition - AAA.pdf

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