Singapore's IRAS released its 8th Edition Transfer Pricing Guidelines (TPG8) in November 2025 just 18 months after the previous edition. The speed of the update signals IRAS's intent to stay closely aligned with international developments. Simultaneously, Singapore's Pillar Two registration portal opens in May 2026, with a hard deadline of June 30, 2026 for most MNE groups under the Multinational Enterprise (Minimum Tax) Act 2024 (MMT Act).
Key Changes in TPG8
Among the most welcome changes in TPG8 is IRAS's decision to exempt domestic intra-group loans from TP scrutiny. Where two Singapore entities neither being a bank transact via intra-group lending, IRAS will no longer challenge the interest rate or require TP documentation for loans entered into from January 1, 2025 onwards. This removes a real compliance burden for Singapore-domiciled groups.
Singapore's 2026 indicative margin for intra-group loans is set at +180 basis points above the applicable risk-free rate a benchmark that provides clear pricing guidance for treasury functions managing intercompany financing.
Amount B Adoption: A Cautious Pilot
Singapore launched its Amount B pilot on January 1, 2026, running through December 31, 2028 a year later than the OECD's recommended start date of January 1, 2025, reflecting Singapore's characteristically careful implementation approach. The Simplified and Streamlined Approach (SSA) is entirely optional, and crucially, TP documentation must still be maintained even when using it. Given that jurisdictions including Australia, New Zealand, Norway, and Turkey have opted out, Singapore taxpayers should verify whether their counterparty's jurisdiction has adopted Amount B before relying on the SSA.
Pillar Two Implementation
Singapore enacted the MMT Act in October 2024, and the GloBE Rules are now effective for financial years beginning on or after January 1, 2025. The two key mechanisms are the Domestic Top-up Tax (DTT) which tops up Singapore-sourced profits to 15% if the group's local ETR falls short and the Multinational Enterprise Top-up Tax (MTT), which operates as the Income Inclusion Rule (IIR) for Singapore-based parent entities with undertaxed overseas subsidiaries.
