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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.
The Berry Ratio may sound light‑hearted, but in transfer pricing it is one of the most debated Profit Level Indicators (PLIs) used under the Transactional Net Margin Method (TNMM). Simple in formula yet demanding in application, the Berry Ratio continues to attract scrutiny from tax authorities worldwide.
Geopolitical volatility has moved from the margins of risk management to the centre of transfer pricing strategy. For multinational groups operating across Australia, Asia and Europe, geopolitical turmoil is no longer a short-term disruption to be explained away in annual documentation.
Singapore’s Budget 2026 sets out a clear strategy to strengthen competitiveness in a changing global environment. The Budget introduces important tax measures while confirming Singapore’s implementation of OECD Pillar Two global minimum tax rules.
