Transfer Pricing guide: Singapore
Read below for more detailed information on transfer pricing regulations, document requirements, and other considerations for Singapore, as well as recent industry hot topics and key developments in the country's business landscape.
Page updated 1st July 2026
Transfer Pricing regulations
Is the jurisdiction part of OECD/G20 Inclusive Framework on BEPS?
Yes, Singapore is part of the OECD / G20 Inclusive Framework on BEPS.
Relevant Transfer Pricing regulation
Section 34F of the Income Tax Act and the accompanying Regulations.
Is this regulation aligned with the OECD Guidelines
The transfer pricing rules are broadly aligned with the OECD Transfer Pricing Guidelines.
Transfer Pricing documentation requirements
Documentation Threshold for Preparation of Local File/ TP Documentation
Where an entity has annual gross revenue that exceeds SGD10 million, and there are related party transactions which exceed specified thresholds based on the individual categories of transactions, such as sale / purchase of goods, services, royalty, loans, etc.
Documentation Threshold for Preparation of Master File
Parent entity prepares Master file and its subsidiary keeps the Master File as a back-up for its Local File.
Documentation Threshold for Preparation of Country by Country Report
The ultimate parent company ("UPE") of a Singapore MNE group that is tax resident in Singapore is required to notify / file CbC Report with the IRAS if the consolidated group revenue in the preceding financial year is at least SGD1,125 million and the group has subsidiaries or operations in at least one foreign jurisdiction.
Submission of Local File, Master File, and CbC Report Required? If so, when?
Where required, the submission timeline is:
- Local File: 30 November of the year of assessment.
- Master File: Same as the local file, as necessary.
- CbC Report: Within 12 months from the end of the UPE's financial year. Note also that the UPE is required to notify the IRAS of its requirement to file CbC Report within 3 months from the end of the relevant financial year.
If No Submission Required, any Other Deadline?
No other reporting or filing deadline.
Other Documentation Requirements
A taxpayer must keep the supporting documentation needed to demonstrate the arm’s length nature of its related party transactions, even though it does not have to submit them to the IRAS until they are required by the IRAS.
Does TP documentation / Local file Need to be Prepared Contemporaneously with Tax Return Filing (i.e., before filing the return)?
Local File need to be prepared contemporaneously and be completed by the filing deadline of the tax return.
Transfer Pricing Specific Returns
Preparation of TP Return Required?
TP return does not apply, but a taxpayer has to complete and file a form where its related party transactions in a financial year in total exceed SGD15 million.
Deadline for TP Return Filing
N/A
Key information to be included in the TP Return
N/A
Benchmarking - Local Tax Authority Preferences
Local vs Regional Comparables Set
Not specified, but should use comparables set aligned with the geography of the related party transactions where possible.
Single-Year vs Multi-Year Analysis
Can use single-year or multi-year analysis, depending on the suitability of each case and the taxpayer has to justify its adoption.
Public vs Private Comparables
Public data is required.
Interquartile Range or Full Range
Interquartile range is preferred.
Transaction-Based or Aggregate Approach, or Both
Transaction-based approach is standard; but aggregate is allowed where there are justifications.
How Often are Benchmarking Sets Renewed (financial update versus full scope BMS preparation)
No fixed frequency; but the benchmarking sets need to maintain its currency.
TP Penalties
In Case of Delayed Submission of Documentation
Yes, there are fines for not submitting the Local File, Master File and CbC Report. In addition, for non-compliance with the preparation of Local File, there is a fine not exceeding SGD10,000 and a surcharge of 5% on transfer pricing adjustments made by the IRAS, regardless of whether there is tax payable on the adjustments.
In case of Income Adjustments in Course of a Tax audit
Refer to comments stated above.
Other Considerations
APA & MAP Availability
Both are available in Singapore.
Applicability of Safe Harbour Rules
N/A
Critical Transfer Pricing Issues Prevailing in the Jurisdiction, if any
No public data compiled concerning critical transfer pricing issues in Singapore.
Criteria/ Guidelines for Transfer Pricing Audit/ Assessments by Tax Authority
No public data compiled concerning IRAS transfer pricing audits and assessments. Anecdotally, MNEs with high volume of related party transactions or in perceived high risk businesses are in focus.
Relevant Regulations and Rulings with Respect to Thin Capitalisation or Debt Capacity in the Jurisdiction
There are no thin capitalisation or specific debt capacity regulations.
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There were several developments in the guidance from the Inland Revenue Authority of Singapore (“IRAS”) on several matters, and the main ones are:
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New transfer pricing documentation (“TPD”) for domestic loans between related parties;
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Amending the thresholds for exemption from TPD on certain transactions;
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New guidance on transfer pricing pertaining to capital transactions; and
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The treatment of government assistance in transfer pricing.
MNEs are required to keep and retain sufficient records to demonstrate that their intra-group transactions are accurate and in accordance with the arm’s length principle.
In the recent years, the IRAS have stepped up their scrutiny of related party transactions in line with the global trend towards closer scrutiny of intra-group transactions. With the adoption of BEPS Pillar 2 in 2024, the IRAS are likely to focus more on the requirements for taxpayers to apply arm’s length principle on their related party transactions.
There is no systemic audit as the IRAS take a risk-based approach in their review of tax returns, including the transfer pricing of related party transactions. The review of the IRAS can be in the form of requiring taxpayers to address a series of questions or through on-site visits to discuss with taxpayers their transfer pricing policies and requiring them to furnish the necessary documents to support their representations.
In Singapore, the Advanced Pricing Agreement (APA) and Mutual Agreement Procedure (MAP) are the channels for managing tax certainty, resolving transfer pricing disputes and minimising double taxation risk with DTA (or Avoidance of Double Taxation Agreement) partners.
There are 3 types of APA:
1) Unilateral APA – Agreement between IRAS and the taxpayer.
2) Bilateral APA – Agreement between IRAS and a DTA partner on the transfer pricing between entities in their respective jurisdictions.
3) Multilateral APA – Agreement between IRAS and 2 or more DTA partners on the transfer pricing between entities in their respective jurisdictions.
The level of certainty through a unilateral APA is lower than a bilateral or multilateral APA. This is because the APA terms are non-binding on the foreign tax authority which is not a party to the unilateral APA.
If Singapore does not have a DTA with the other tax jurisdiction, an unilateral APA can be obtained through the Advance Ruling System.
As for MAP, it is designed to resolve disputes arising from the interpretation or application of tax treaties, including transfer pricing adjustment. MAP is a dispute resolution mechanism provided under the MAP article in the DTAs of Singapore. Usually, a MAP is entered into between two competent authorities (“CAs”), but it is also possible for IRAS to enter a multilateral MAP involving three or more CAs.
MAP should be initiated by the taxpayers within the time limit specified in the MAP article of the relevant DTA. Failure to do so may result in the CAs rejecting the MAP request. Taxpayers may seek resolution on issues that recur over multiple tax years, subject to the time limits provided in the relevant DTA.
Singapore has undergone the Stage 1 and Stage 2 MAP Peer Review under the Inclusive Framework on the OECD / G20 Base Erosion and Profit Shifting Project (“BEPS”) - Action 14 (Making Dispute Resolution Mechanisms More Effective). The peer review reports provide an assessment of best practices which Singapore adopts in the implementation of the Action 14 Minimum Standard.
