Singapore: Updated transfer pricing guidelines include pilot implementation of Pillar Two Amount B
Eighth edition of e-Tax Guide on Transfer Pricing Guidelines (TPG8)
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