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Singapore’s transfer pricing landscape continues to evolve, with increasing expectations from IRAS on contemporaneous documentation, robust intercompany policies, and clear support for pricing outcomes. Finance and tax teams continue to face tighter scrutiny, shorter response times, and a stronger focus on substance, benchmarking, and implementation.
This practical webinar will break down the latest Singapore transfer pricing compliance developments into clear, actionable steps.
Attendees will gain a concise view of what has changed, what IRAS is focusing on, and what you should prioritise before year end to stay
compliant, minimise risks, and avoid unnecessary disputes and penalties.
Ms Adriana Calderon
Director, Asia and Malaysia - Transfer Pricing Solutions Asia
Accredited Tax Advisor (Income Tax)
Adriana is the co-founder of Transfer Pricing Solutions Asia. She has extensive international experience with Big Four and mid-tier firms
advising multinational companies in the areas of corporate and international taxation across South America, the US, Australia and the Asia
Pacific Region. As a Transfer Pricing practitioner, Adriana has advised companies in the Asia Pacific Region across various industries and
in a wide range of projects associated with planning, compliance and dispute resolutions with tax authorities. She has also participated in
specialised projects involving pricing of financial transactions, business restructures and negotiation of APAs. Most recently, she has
participated in transfer pricing planning projects to implement BEPS’s Action Plan and country-by-country reporting.
Adriana also enjoys teaching and is a regular speaker and facilitator of Transfer Pricing seminars and workshops. She is a transfer pricing trainer for the Institute of Singapore Chartered Accountants and Singapore Institute of Accredited Tax Professionals. Adriana has also facilitated training sessions for CFOs, tax teams of large companies and consultancies, and tax executives at the Australian Taxation Office. In addition, Adriana is also SCTP’s representative for the TP Roundtables organised by the tax authority.
Practical guidance to simplify Singapore transfer pricing compliance in 2026 and stay ahead of IRAS expectations.
On 1 June 2026, the OECD released a public consultation draft revising Chapter VII of the OECD Transfer Pricing Guidelines – the chapter dealing with intra-group services. The draft is extensive but does not change the underlying arm’s length principles.
The Inland Revenue Authority of Singapore (IRAS) released the 9th Edition of the Singapore Transfer Pricing Guidelines (TPG) on 4 June 2026. The update introduces targeted clarification on the treatment of share‑based compensation (SBC) in the context of intercompany services arrangements remunerated on a cost‑plus basis.
Adriana Calderon, Managing Partner - Asia & Malaysia at Transfer Pricing Solutions, shares insights from the IFA APAC Conference in Tokyo, highlighting key trends in transfer pricing across Asia. She explores regional differences in approach, increasing regulatory complexity, and rising audit activity, while reflecting on the importance of global networks in fostering collaboration and shaping the future of international tax.
