Executive summaryThe Inland Revenue Authority of Singapore (IRAS) released the 6th Edition Transfer Pricing Guidelines1 (TPG) on 10 August 2021, which provides updates and additional transfer pricing (TP) guidance in a number of areas as compared to the previous (5th) edition of the TPG, published on 23 February 2018.The 6th Edition TPG does not deviate significantly from the 5th Edition TPG in terms of guidance on the considerations for the application of the arm’s-length principle and TP documentation requirements. However, the various updates and guidance in additional areas (including conditions for mitigating a TP surcharge) are reflective of the IRAS’ continuing...