This alert summarises the key changes in the seventh edition TPG and TPD rules.
On 14 June 2024, the Inland Revenue Authority of Singapore (IRAS) released the Transfer Pricing Guidelines (TPG) (Seventh Edition). Compared to the sixth edition TPG, published on 10 August 2021, the seventh edition TPG provides updates and additional transfer pricing (TP) guidance in several areas. Singapore’s transfer pricing documentation (TPD) rules have also been amended to reflect the changes in the seventh edition TPG.
The key changes in the seventh edition TPG and TPD rules include:
- Additional guidance on TP aspects for financial transactions
- Increased thresholds for exemption from TPD requirements for certain transactions from Year of Assessment (YA) 2026
- Dating of simplified TPD
- Guidance on working capital adjustments
- Additional guidance on the conditions around remission of the 5% surcharge
- Guidance on TP adjustments for capital transactions
- Additional guidance on strict pass-through costs
- Guidance on the TP aspects of government assistance
- Additional guidance on TP audits
- Removal of the pre-filing phase under the Mutual Agreement Procedure
- Additional guidance on how the IRAS will disregard an actual related party transaction
