Singapore Transfer Pricing Guidelines
– 9th Edition Update
The Inland Revenue Authority of Singapore (IRAS) has released the
9th Edition of the Transfer Pricing Guidelines on 4 June 2026,
succeeding the 8th Edition issued in November 2025. While the
previous edition introduced significant changes such as the
Simplified and Streamlined Approach (Amount B pilot), domestic loan
exemptions, and enhanced transfer pricing documentation requirements,
the 9th Edition primarily serves to reaffirm and strengthen the
transfer pricing framework established therein. In addition, it
introduces a new FAQ section on Share Based Compensation (SBC),
offering the much needed clarity on its treatment and thereby
enhancing tax certainty and helping to mitigate potential tax disputes.
Share Based Compensation (SBC)
The new FAQ section under Para 5.120 addresses the transfer
pricing treatment of SBC costs. The FAQ provides valuable
guidance for multinational groups operating under cost-plus
arrangements in Singapore, particularly where employee stock
options or other equity-settled compensation form part of
employee remuneration. The update underscores IRAS’ expectations
regarding the treatment of SBC costs and highlights an area that
may attract increased scrutiny in the coming years.
VSTN newsletter analyses the key update introduced in the 9th Edition.
Focusing on the newly added guidance on SBC costs, providing businesses
with a concise yet practical overview of the implications of these
changes, helping them better navigate the evolving transfer pricing
landscape.
Singapore Transfer Pricing Guidelines – 9th Edition
Singapore Transfer Pricing Guidelines
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