Cyprus: Tax Department revises transfer pricing simplification return rates from 2026
The Cyprus Tax Department has revised the minimum and maximum return rates used in its transfer pricing simplification measures, through Circular 5/2026 issued on 12 October 2026. The circular updates the rates set out in Circular 6/2023, with
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Ukraine proposes ATAD-aligned anti-avoidance rules to combat aggressive tax planning
Ukraine’s government has approved Draft Law No. 16150 prepared by the Ministry of Finance to implement provisions of the Anti-Tax Avoidance Directive (2016/1164) (ATAD) aimed at combating aggressive tax planning. Draft Law No. 16150 was
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South Africa proposes SEZ transfer pricing reforms, corporate tax changes in Medium-Term Budget Policy
South Africa’s National Treasury has delivered the Medium-Term Budget Policy Statement (MTBPS) to Parliament on 21 October 2026. This package comprises three key amendment bills designed to implement the government's tax policy, monetary
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Bulgaria amends tax procedure code to implement DAC8 and DAC9, revise transfer pricing rules
Bulgaria's government has promulgated the Law amending the Tax and Social Security Procedure Code (TSSPC), published in State Gazette No. 85 on 15 September 2026 under Decree No. 302. The Law transposes Council Directive (EU) 2023/2226 (DAC8) and
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OECD publishes 2026 Peer Review Reports for Country-by-Country Reporting
The OECD published the Compilation of 2026 Peer Review Reports for Country-by-Country Reporting on 19 October 2026, presenting findings on the implementation of Country-by-Country (CbC) reporting across 142 jurisdictions that submitted relevant
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Kuwait gazettes agreement on the exchange of Country-by-Country reports
Kuwait has approved the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) through Decree-Law No. 116 of 2026, published in the Official Gazette Kuwait Al-Youm on 18 October 2026. The agreement
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Kenya replaces 2006 transfer pricing rules with new framework
Kenya’s Income Tax (Transfer Pricing) Rules, 2026 (the 2026 TP Rules) took effect on 12 August 2026, replacing the Income Tax (Transfer Pricing) Rules, 2006 (the 2006 TP Rules). The rules were made by Cabinet Secretary for the National Treasury
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France tables Pillar Two safe harbours, CbC reporting relief
The French government tabled Amendment I-3734 to the 2027 Finance Bill (Projet de loi de finances pour 2027, No. 3210) on 10 October 2026, introducing significant updates to France’s Pillar Two global minimum tax framework. The proposal
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Australia: ATO extends 2025 public CbC reporting deadline
The Australian Taxation Office (ATO) announced, on 15 October 2026, that large corporations reporting tax information for 2025 now have until 29 January 2027 to publish their public country-by-country reports. The ATO initially set the deadline
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Finland proposes interest deduction relief for critical infrastructure projects
Finland’s Parliament is reviewing Government Proposal HE 227/2026 vp, part of the Government’s 2027 Budget package, which proposes a new exception to the country’s interest deduction restriction rules. This legislative change allows
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Belgium launches BEPS13 Local File XML Creator Tool
Belgium’s Federal Public Service Finance has announced on 30 September 2026 that the new BEPS13 LF XML creator tool is now operational. The tool enables users to generate XML files that comply with the new XSD schema 275.LF. Earlier, on 2
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Argentina: ARCA overhauls international tax, transfer pricing rules
Argentina's tax authority (ARCA) has published General Resolution 5903/2026 in the Official Gazette on 30 September 2026. This regulation completely overhauls and unifies Argentina's international tax and transfer pricing rules into a single,
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Turkey introduces specialised audits for tax evasion, transfer pricing
Turkey’s Tax Audit Board announced that three new specialised departments would become fully operational from 1 October 2026 as part of efforts to strengthen tax audits through specialisation, data analytics, digital auditing and risk-based
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Slovak Republic issues guidance on advance pricing agreement procedures
The Slovak Republic’s tax authorities have issued guidance under No. 4/MZ/2026/MU on 23 September 2026 (the Slovak version was issued on 5 August 2026) that outlines the application process and regulatory framework for Advance Pricing
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Singapore updates guidance on transfer pricing treatment of share-based compensation from YA 2026
The Inland Revenue Authority of Singapore (IRAS) updated its Transfer Pricing guidance page on 25 September 2026 with additional guidance on transfer pricing adjustments relating to share-based compensation. The update sets out a revised
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OECD to consult revisions to intra-group services transfer pricing guidance
The OECD will hold a public consultation meeting on 9 November 2026 to discuss proposed revisions to Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The meeting will focus on feedback
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Australia: ATO issues new guidance on Country-by-Country reporting requirements
The Australian Taxation Office (ATO) has released new guidance on 25 September 2026 on administrative matters related to Country-by-Country (CbC) reporting. The updates clarify lodgment deadlines, extension procedures, and international obligations
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Bulgaria introduces new transfer pricing rules aligned with OECD guidelines
Bulgaria's new Ordinance on Transfer Pricing Methods Application (the New Ordinance) entered into effect on 1 January 2026, replacing the previous 2006 regulatory framework. Introduced to align national tax regulations with updated OECD Transfer
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