Singapore: Updated transfer pricing guidelines include pilot implementation of Pillar Two Amount B

Eighth edition of e-Tax Guide on Transfer Pricing Guidelines (TPG8)

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November 26, 2025

The Inland Revenue Authority of Singapore (IRAS) on November 19, 2025, published the eighth edition of the e-Tax Guide on Transfer Pricing Guidelines (TPG8).

The updated guide includes a number of key changes related to:

  • Treatment of certain domestic related-party loans
  • Annual review of related-party loans
  • IRAS’ ability to recharacterize or disregard funding arrangements
  • Simplified transfer pricing documentation
  • Pilot implementation of Amount B of Pillar Two

Read a November 2025 report prepared by the KPMG member firm in Singapore

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