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Singapore issues Transfer Pricing Guidelines (Eighth Edition)
Summary of updates on the e-tax guide Transfer Pricing Guidelines (Eighth Edition)
On 19 November 2025, the Inland Revenue Authority of Singapore (IRAS) released the e-tax-guide Transfer Pricing Guidelines (Eighth Edition) (TPG (eighth edition)). The TPG (eighth edition) provides updates and additional transfer pricing (TP) guidance in several areas.
Notable changes in the TPG (eighth edition) include:
Additional guidance on TP aspects of financial transactions
Guidance on implementing the simplified and streamlined approach (SSA) on a pilot basis
Additional guidance on mutual agreement procedure (MAP)
Additional guidance on capital transactions
Guidance on the recourse if taxpayer disagrees with TP adjustment
Additional guidance on the revision of surcharge
Additional guidance on attribution of profits to a permanent establishment (PE)
Additional guidance on simplified TP documentation (TPD)
Additional guidance on strict pass-through costs