[World Tax News] OECD Transfer Pricing Revisions Singapore TP Update and Turkey GloBE Agreement

Editorial Team – [2026] 187 taxmann.com 510 (Article)

World Tax News provides a weekly snippet of tax news from around the globe. Here is a glimpse of the tax happening in the world this week:

1. OECD releases consultation draft on revisions to TP guidelines

The OECD Committee on Fiscal Affairs is undertaking a review and modernisation of Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG), which deals with intra-group services. The objective is to align the guidance on intra-group services more closely with the fundamental principles set out in Chapters I, II and III of the OECD TPG.

The proposed revisions are intended to improve clarity, enhance practical application through additional examples, and address interpretational issues that have emerged over time. However, the revisions are not designed to alter the established principles governing the transfer pricing analysis of intra-group services.

To gather diverse perspectives from stakeholders across industries, jurisdictions and business sectors, the OECD has released a public consultation document titled “Revisions to Chapter VII of the OECD Transfer Pricing Guidelines – Special Considerations for Intra-Group Services.” Stakeholders are invited to comment on all aspects of the discussion draft, including whether the stated objectives have been achieved. The draft also contains specific questions on areas where stakeholder input would be particularly valuable.
Source: Oecd.org

2. Singapore modifies TP guidelines with share-based compensation FAQ

The Inland Revenue Authority of Singapore (IRAS) has released the Ninth Edition of its Transfer Pricing Guidelines through an updated e-Tax Guide. The key amendment in this edition is the insertion of new paragraph 5.120, which introduces a frequently asked question (FAQ) clarifying the transfer pricing treatment of share-based compensation. This update forms the principal change in the Ninth Edition, published on 4 June 2026.

The new FAQ clarifies the transfer pricing treatment of share-based compensation costs incurred in connection with intra-group services. IRAS confirms that share-based compensation represents remuneration for services performed by employees and, therefore, forms part of the service provider’s cost base when applying a cost-based transfer pricing method. The guidance covers three scenarios which are incurred, uncharged, and notional share-based compensation costs and states that such costs should generally be included in the cost base for determining the arm’s length charge for related-party services.

To balance technical accuracy with practical compliance considerations, IRAS has introduced an administrative concession effective from YA 2026. Under this approach, while uncharged and notional share-based compensation costs continue to be included in the cost base for calculating the mark-up, they may be excluded from the resulting service income. However, incurred share-based compensation costs remain fully includible in both the cost base and service income. The revised guidance provides greater certainty to taxpayers on the transfer pricing treatment of employee share-based compensation arrangements within multinational groups.

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