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.

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.

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