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.
About us
VSTN Consultancy is a Global Transfer Pricing firm with extensive expertise in the field of international taxation and transfer pricing. VSTN Consultancy has been awarded by International Tax Review (ITR) as Best Newcomer in Asia Pacific – 2024 and is ranked as one of the recommended transfer pricing firms. VSTN has also been nominated in 9 Categories under APAC, EMEA and Middle East Region ITR awards 2025. VSTN has its offices in India and Dubai.
Nithya Srinivasan, Founder of VSTN Consultancy, was named Middle East Transfer Pricing Practice Leader of the Year, recognizing her outstanding leadership and contribution to the profession. VSTN also received the Best Newcomer in the Middle East award from International Tax Review, showcasing its rapid growth and excellence in global transfer pricing advisory.
VSTN Consultancy has been honored with the Best Global Transfer Pricing Consultancy 2025 – India award at the prestigious Wealth & Finance Management Consulting Awards 2025.
Our offering spans the end-to-end Transfer Pricing value chain, including design of intercompany policy and drafting of Interco agreement, ensuring effective implementation of the Transfer Pricing policy, year-end documentation and certification, BEPS related compliances (including advisory, Masterfile, Country by Country report), safe harbour filing, audit defense before all forums and dispute prevention mechanisms such as Advance Pricing agreement. VSTNs senior partners have been ranked in ITR in the list of recognized Practitioners.
Locations Served
| Australia | Philippines |
| Belgium | Singapore |
| Denmark | Switzerland |
| India | Turkey |
| Italy | UAE |
| KSA | UK |
| Mexico | USA |
| Netherlands | Zambia |
Our Licensed Databases
| SNo | Database | Provider |
|---|---|---|
| 1 | TP Catalyst | Moody’s |
| 2 | ORBIS | Moody’s |
| 3 | Loan Module | Moody’s |
| 4 | IP & Royalty Data | Moody’s |
| 5 | Royalty Rates and Benchmark Module | ktMINE |
| 6 | Services CUT | ktMINE |
| 7 | EDF-X Bond Database | Moody’s |
| 8 | EDF-X Credit Risk Analytics | Moody’s |
| 9 | Loan Module | Royalty Range |
| 10 | Transfer Pricing Documenter (formerly Thomson Reuters Onesource) | Ryan |
| 11 | Prowess | CMIE |
As businesses expand across borders, navigating complex transfer pricing regulations becomes critical. At VSTN Consultancy, a global transfer pricing firm, we specialize in helping companies stay compliant and competitive across key markets including:
India | UAE | Singapore | USA | KSA | Dubai | Asia Pacific | Europe | Africa | North America
Whether you’re preparing for benchmarking intercompany transactions, or developing robust TP documentation, our team is here to support your international strategy and Compliance.
Contact us today to explore how we can partner with you to optimize your global transfer pricing approach.
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