Transfer Pricing Guidelines

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Transfer Pricing Guidelines.

As a member of the Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework for Implementing Measures against Base Erosion and Profit Shifting (BEPS), Singapore supports the key principle underlying the BEPS Project, namely that profits should be taxed where the real economic activities generating the profits are performed and where value is created. Singapore also adheres to the internationally agreed arm’s length principle. The fundamental principles articulated in OECD’s and the Inland Revenue Authority of Singapore (IRAS)’, Transfer Pricing Guidelines (TPGs) are similar even though their approaches may vary.

While the latter focuses on comparability, the former places emphasis on the delineation and allocation of risks to parties that control the risks and have the financial capacity to bear the risk.

These differences provided the setting for an enlightening webinar organised by the Singapore Chartered Tax Professionals, where Adriana Calderon, Director, Transfer Pricing Solutions Asia, compared and contrasted the latest TPGs


  • IRAS’ Transfer Pricing Guideline (TPG) focuses more on comparability; OECD’s TPG focuses more on delineation and allocation of risks.
  • Fundamental principles in IRAS’ and OECD’s TPGs are largely aligned.
  • Both share the common objective that transfer pricing between related parties must follow the arm’s length principle.

Comparison of IRAS's and OECD's Transfer Pricing Guidelines 

This article is intended for general guidance only. It does not constitute professional advice and may not represent the views of Transfer Pricing Solutions Asia, the facilitator or the SCTP. While every effort has been made to ensure the information in this article is correct at time of publication, no responsibility for loss to any person acting or refraining from action as a result of reading this article or using any information in it can be accepted by Transfer Pricing Solutions Asia, the facilitator or the SCTP.

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Transfer Pricing Solutions Asia is a boutique transfer pricing firm that provides practical, proactive and cost-effective transfer pricing advisory.



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