At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-09-30. Tax authority: Inland Revenue Authority of Singapore (IRAS). Summaries are simplified; check the linked official source before relying on them.
The law
#Income Tax Act 1947 s. 34D (arm's length adjustments), s. 34E (5% surcharge), s. 34F (TP documentation) and s. 105M (CbC), with the Income Tax (Transfer Pricing Documentation) Rules 2018 and the CbC Reporting Regulations. IRAS Transfer Pricing Guidelines (9th edition, 4 June 2026) explain practice and broadly follow the OECD Transfer Pricing Guidelines.
Documentation
#TP documentation is required for a basis period if gross revenue exceeds S$10 million, or if documentation was required for the previous basis period. It must contain group-level and entity-level information (no separate Master File or Local File filing). Exempt categories when the total per category is at or below S$15 million (goods purchases, goods sales, loans given, loans received) or, from YA 2026, S$2 million (services, royalties, rent, guarantees and any other transaction; S$1 million up to YA 2025); also domestic transactions, related-party loans on the indicative margin and routine services at cost plus 5%. Prepare by the return filing due date, in English (or translated on request), submit within 30 days of a request, keep 5 years. Simplified refresh allowed every 3 years. Form for Reporting RPT with Form C if related-party transactions exceed S$15 million.
Methods
#CUP, resale price, cost plus, profit split and TNMM, with no strict hierarchy; choose the most appropriate method. Where the range is wide, use the interquartile range to improve reliability. Administrative safe harbours: 5% cost mark-up for routine support services and the IRAS indicative margin for related-party loans (up to S$15 million, or domestic loans of any amount from 2025).
Penalties
#Failure to prepare, keep or submit TP documentation (or giving false documents): fine up to S$10,000 per offence on conviction, can be compounded (s. 34F). 5% surcharge on the amount of any TP adjustment made by IRAS, whether or not extra tax results (s. 34E). Without documentation IRAS may decline MAP support or APA applications. CbC failures are offences under s. 105M. Late Form C filing can lead to composition or summons (up to S$5,000).
Pillar Two
#Singapore applies a Multinational Enterprise Top-up Tax (IIR) and a Domestic Top-up Tax (QDMTT) from fiscal years starting on or after 1 January 2025, with no UTPR. Groups register once within 6 months of the first in-scope year end, file the GIR and MTT and DTT returns 15 months after year end (18 for a transition year), and pay one month later.
Other rules
#Unilateral, bilateral and multilateral APAs and MAP are available. No secondary adjustment rule and no general interest limitation rule. CbC: Singapore-parented groups with prior-year consolidated revenue of at least S$1,125 million must notify IRAS within 3 months of the year end (from FY 2022) and file within 12 months. Singapore uses fixed calendar filing dates: income for a financial year ending in year X is assessed in YA X+1, and Form C is due 30 November of the YA, so dates below use yearOffset 1.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | CbC notification of filing obligation Within three months from the end of the financial year (from FY 2022). | 3 months after year end (e.g. Mar 31, 2026) | Singapore ultimate parent of a group with foreign operations and prior-year consolidated revenue of at least S$1,125 million. Singapore subsidiaries of foreign groups do not notify. | IRAS e-Tax Guide: Country-by-Country Reporting (5th edition, 30 January 2026) |
| 2 | Register for MTT and DTT (one-time) The group registers with IRAS within 6 months of the end of its first fiscal year in scope (30 June 2026 for calendar 2025), naming the GIR filer and DTT filer. Failing to register can bring a 10% surcharge on MTT and DTT. | 6 months after year end (first year) (e.g. Jun 30, 2026) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | IRAS: MTT and DTT Module 9, compliance obligations |
| 3 | Corporate income tax return (Form C / Form C-S / Form C-S Lite) 30 November of the Year of Assessment (YA = year after the financial year end year). For YA 2023 to YA 2027, Form C-S returns filed through accounting software get an automatic 15-day extension to 15 December. Estimated Chargeable Income (ECI) is due within 3 months of year end. | Fixed calendar date (e.g. Nov 30, 2026) | All companies. Form C-S for revenue of S$5 million or less; Form C otherwise. | IRAS: Corporate Income Tax filing season 2026 |
| 4 | Form for Reporting Related Party Transactions (part of Form C) Answer 'Yes' at Item 31 of Form C and complete the Related Party Transactions tab. Includes domestic related parties. | With Corporate income tax return (Form C / Form C-S / Form C-S Lite) (e.g. Nov 30, 2026) | Value of related-party transactions in the financial statements exceeds S$15 million (income and expense amounts with related parties, excluding key management pay, directors' fees and dividends, plus year-end loan and non-trade balances). | IRAS Transfer Pricing page, Reporting Related Party Transactions |
| 5 | Contemporaneous TP documentation (s. 34F) Must be prepared no later than the filing due date of the return (30 November of the YA). Not submitted with the return. Group-level and entity-level content required. Keep at least 5 years. | Fixed calendar date (e.g. Nov 30, 2026) | Gross revenue above S$10 million for the basis period, or documentation required for the prior basis period. Category exemptions: S$15 million for goods and loans; S$2 million (YA 2026 onward) for services, royalties, rent, guarantees and other transactions. | IRAS e-Tax Guide: Transfer Pricing Guidelines (9th edition, 4 June 2026), section 6 |
| 6 | CbC report Within 12 months from the end of the financial year (for example FYE 31 December 2026, due 31 December 2027). Filed electronically. | 12 months after year end (e.g. Dec 31, 2026) | Same as the notification: Singapore ultimate parent, S$1,125 million group revenue in the preceding year, at least one foreign jurisdiction. | IRAS e-Tax Guide: Country-by-Country Reporting (5th edition) |
| 7 | GloBE Information Return or GIR notification Due 15 months after year end, 18 months for a transition year. A transition year is the group's first year in scope of any qualified IIR or UTPR, or of Singapore registration, whichever is earlier, so groups already in scope elsewhere in 2024 get 15 months for 2025. The site uses 15 months for 2025 year ends because the 18-month first-year period only applies in the group's first year in scope of Pillar Two anywhere; a group first in scope here gets 18 months. | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | IRAS: MTT and DTT Module 9, compliance obligations |
| 8 | MTT return and DTT return MTT (IIR) return by each responsible parent and one DTT return per group, nil returns included, due 15 months after year end, 18 for a transition year. Both apply to fiscal years starting on or after 1 January 2025. Singapore has no UTPR. The site uses 15 months for 2025 year ends because the 18-month first-year period only applies in the group's first year in scope of Pillar Two anywhere; a group first in scope here gets 18 months. | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | IRAS: MTT and DTT Module 9, compliance obligations |
| 9 | MTT and DTT payment Top-up tax is payable one month after the return due date: 16 months after year end, 19 months for a transition year (31 July 2027 for a calendar 2025 transition year). Late payment penalties apply. The site uses 16 months for 2025 year ends because the 19-month first-year period only applies in the group's first year in scope of Pillar Two anywhere; a group first in scope here gets 19 months. | 16 months after year end (e.g. Apr 30, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | IRAS: MTT and DTT Module 9, compliance obligations |
| 10 | Submit TP documentation on request Within 30 days from the date of IRAS's written notice. Failure is an offence (fine up to S$10,000). | Within 30 days of a tax authority request | Taxpayers required to prepare s. 34F documentation. | IRAS Transfer Pricing Guidelines (9th edition), paras. 6.5 and 9.13 |