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Transfer pricing changes to Sections 34D and 34F
Draft legislation on the identification of related parties for partnerships, trusts and registered business trusts
On 18 June 2025, the Ministry of Finance (MOF) released the proposed Finance (Income Taxes) Bill 2025 for public consultation. The proposed legislative amendments to the Singapore Income Tax Act 1947 (ITA) include specific transfer pricing (TP) related changes, in particular, to the existing sections 34D and 34F. The proposed amendments will have an impact on how related parties are determined for partnerships, trusts as well as registered business trusts.
This alert provides a summary of the proposed changes and our observations. As the Bill has not been enacted, this development and the potential implications for your business should be monitored.