On November 19, 2025, the Inland Revenue Authority of Singapore (IRAS) published the eighth edition of its Electronic Transfer Pricing Guide. This update is a significant milestone for any multinational group with operations in Singapore or linked to entities there, as it introduces key changes in documentation, intra-group financing, and new simplification mechanisms for certain routine functions. In this article, we analyze the scope of the new edition, its practical implications, and what companies and advisors should be aware of.
What is the IRAS e-guide?
The IRAS Transfer Pricing e-Tax Guide is the official instrument through which the Singapore tax authority details its criteria, methodologies, expectations, and practical guidance for related-party transactions to comply with the arm’s length principle. This is not just a statement of general principles: the guide contains specific guidelines on how to value transactions, how to document them, when transfer pricing reports should be prepared, what is expected of intra-group loans, cost reimbursements, services, financing, and how IRAS may audit adjustments.
Context of the eighth edition
IRAS publishes these guides periodically—whenever it considers it necessary to adapt its transfer pricing regulations to changes in international standards (e.g., reforms linked to the Organisation for Economic Co-operation and Development (OECD)/G20 framework) or to new market realities and business structures. The eighth edition of 2025 represents this regulatory evolution: it incorporates new areas of focus, clarifies audit processes, introduces simplification schemes (reflecting global standards), and updates critical aspects such as intragroup financing, documentation, pass-through costs (margin-free reimbursements), and dispute resolution.
Main changes and new provisions
Introduction of a pilot program with a simplified approach (SSA / “Amount B”) for distributors and marketing activities
A structural change: the new edition introduces a pilot program called the Simplified and Streamlined Approach (SSA), aligned with the “Amount B” model developed under OECD / G20 standards. This mechanism seeks to simplify the application of the arm’s length principle for certain intra-group distribution and marketing transactions that meet qualifying conditions.
The pilot will apply for tax years between January 1, 2026, and December 31, 2028. Those who meet the requirements will be eligible for predefined margins, reducing the burden of benchmarking and comparable documentation.
Strengthening the treatment of intra-group financial transactions
The 2025 edition strengthens the regulations surrounding loans between related parties, their characterization, rate determination, and documentation. For domestic loans arranged on or after January 1, 2025, taxpayers may choose to apply an IRAS “indicative margin” or set the rate according to arm’s length principles. If the indicative margin is chosen, IRAS has indicated that transfer pricing adjustments will not be applied under the relevant section, providing a more predictable alternative.
Guidance is also expanded on intragroup financing structures, refinancing, conversion of IBOR-based linked loans to new benchmarks, and documentation requirements when these changes constitute new agreements.
Clearer and more stringent documentation and evidence requirements
The updated guidance places particular emphasis on the quality of transfer pricing documentation. In particular:
- If simplified documentation based on past documentation is chosen, it is now mandatory to submit a formal statement; without this requirement, simplified documentation will not be considered valid.
- Pass-through costs or reimbursements of intragroup service costs must be adequately supported; invoices alone are no longer sufficient as evidence.
- In general, IRAS reinforces the expectation that intragroup transactions have economic substance, functional consistency, and a clear definition of roles, risks, and assets, in line with international standards.
New rules for dispute resolution, adjustments, and MAP procedures
The eighth edition updates the rules relating to the mutual agreement procedure (MAP), as well as the appeal mechanisms for transfer pricing adjustment disputes. In addition, it includes guidance on the implications of withholdings, the nature of capital, and adjustments arising from financing transactions.
What do these changes mean for multinational companies and groups?
For companies operating in Singapore or maintaining intra-group operations with entities in that country, the changes mean:
- Reduced administrative burden on certain routine transactions: thanks to the SSA pilot, qualified distribution/marketing activities could qualify for a safe harbor, reducing the need for complex comparative analysis.
- Greater financial flexibility and predictability in related domestic loans: the possibility of using an indicative margin provides certainty in interest deduction and intragroup financing structuring.
- Greater discipline in documentation and economic backing: with the strengthening of documentation, evidence, and substance requirements, companies must carefully review their policies on internal commissions, cost sharing, and intragroup services.
- Reduced risk of unexpected adjustments if formal requirements are met, but also greater risk of audit in complex transactions if not accompanied by robust documentation.
- Need to review the overall transfer pricing structure, not only in Singapore, but in all countries where the group operates, to ensure consistency with international standards and avoid double taxation or adverse adjustments.
Conclusion
The eighth edition of the IRAS electronic transfer pricing guide is a strategic update that balances simplification in routine transactions with greater technical, documentary, and economic substance rigor. For multinational groups, this reform is not simply administrative: it requires a technical and strategic rethinking of intragroup design, documentation, financing, and risks. If addressed properly, it can represent an opportunity to optimize structures—but also a wake-up call for those operating with traditional or unstructured approaches.
This context reaffirms the importance of staying up to date, reviewing transfer pricing policies, and adjusting practices in line with new international compliance guidelines.
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Source: IRAS