Peru: SUNAT issues MAP guidance 2.0 (2026), updates tax treaty dispute framework
The Peru tax authority (SUNAT) has introduced Mutual Agreement Procedure Guidance Version 2.0 (2026) to replace the previous Mutual Agreement Procedure Guidance Version 1.0 (2023). The 2026 version of the Mutual Agreement Procedure (MAP) Guide
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EU: Court rules transfer pricing profit adjustments fall outside VAT scope
The Court of Justice of the European Union (CJEU) delivered its judgment on 13 May 2026 in Stellantis Portugal, S.A. v Autoridade Tributária e Aduaneira (Case C-603/24) concerning whether intra-group transfer pricing adjustments are subject to
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US: IRS permits retroactive cost allocation refinement, setoff relief in transfer pricing case
In a Chief Counsel Advice memorandum dated 27 January 2026 and released publicly on 1 May 2026, the US Internal Revenue Service (IRS) ruled that a multinational corporation could retroactively adopt a more detailed cost allocation approach for
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Malta updates corporate income tax return for 2026 with transfer pricing, new reporting changes
Malta's Commissioner for Revenue has announced that the electronic corporate income tax return for the year of assessment 2026 is now available through its online services. The supplemental document for Fiscal Units is also available for
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Bulgaria advances DAC8 and DAC9 transposition: Expands crypto reporting, Pillar Two exchange rules, transfer pricing framework
Bulgaria’s Council of Ministers has approved and submitted a draft bill to the National Assembly on 7 May 2026 to transpose two European Union directives into national law: Council Directive (EU) 2023/2226 (DAC8) and Council Directive (EU)
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Montenegro sets 2026 arm’s length interest rate for related party loans
Montenegro has set the deemed arm’s length interest rate for 2026 at 4.97% after the Ministry of Finance adopted a Rulebook regulating interest rates on financial instruments between related parties. The Rulebook was published in the Official
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Russia reminds taxpayers of controlled transaction notification obligations
Russia’s Federal Tax Service (FTS) has reminded taxpayers that notifications of controlled transactions for 2025 must be submitted no later than 20 May 2026. Under paragraph 8 of Article 105.15 of the Tax Code of the Russian Federation,
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Rwanda implements new transfer pricing rules, business tax regulations, loss carryforward extensions
Rwanda has published Ministerial Order No. 003/26/10/TC of 29 April 2026 in the Official Gazette, introducing updated transfer pricing rules under Law No. 027/2022 of 20 October 2022, the country’s new income tax law, accounting for small
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South Africa consults implementation of bilateral advance pricing agreements under DTAs
The South African Revenue Service (SARS) has initiated a public consultation, on 30 April 2026, on the implementation of bilateral advance pricing agreements (APAs) under double taxation agreements (DTAs), as part of an initial pilot phase of the
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France expands list of CbC reporting partner jurisdictions
France has published a Ministerial Order on 24 April 2026, published in Official Journal No. 0099 of 26 April 2026, updating the list of jurisdictions that meet the conditions for exemption from local filing under its country-by-country (CbC)
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Serbia sets 2026 arm’s length interest rates for related party loans
Serbia's Ministry of Finance has introduced new interest rates for related party loans in 2026, with the rulebook set to take effect on 2 May 2026 following its publication in the Official Gazette on 24 April 2026. The regulations establish arm's
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Australia: ATO clarifies general purpose financial statement filing obligations
The Australian Taxation Office (ATO) has issued a notice on 28 April 2026 outlining which entities are required to lodge a general purpose financial statement. Lodging a general purpose financial statement (GPFS) is a crucial step for various
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Romania consults new mutual agreement procedure (MAP) rules
Romania’s National Agency for Fiscal Administration (ANAF) initiated a public consultation, on 21 April 2026, on a draft order establishing the procedure for conducting the mutual agreement procedure (MAP), following amendments introduced to the
See MoreMontenegro proposes draft corporate tax rules in accordance to EU ATAD
The Government of Montenegro has released a draft law on Amendments to the Law on Corporate Income Tax, proposing measures to address profit shifting in accordance with the EU Anti-Tax Avoidance Directive (ATAD) (Directive 2016/1164 as amended by
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US: IRS revives controversial transfer pricing rule after decades of dormancy
The US Internal Revenue Service (IRS) is dusting off a 40-year-old tax provision that could dramatically reshape how multinational companies price transactions involving intellectual property, raising concerns among international tax practitioners
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Bolivia updates corporate tax and transfer pricing reporting rules, extends 2025 filing deadlines
Bolivia’s National Tax Service (SIN) has issued Resolution No. 102600000014 on 16 April 2026, marking a significant shift toward the full digitalisation of financial and tax data. These updates specifically refine how businesses handle their
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Algeria extends CIT, PIT, transfer pricing filing deadlines for 2025 fiscal year
Algeria's tax authority, the General Directorate of Taxes (DGI) has granted taxpayers additional time to file their annual income tax returns for the 2025 fiscal year, according to an announcement on 16 April 2026. The filing deadline for annual
See MoreAustralia: ATO revises transfer pricing compliance for inbound distribution arrangements
The Australian Tax Office (ATO) has published updates to Practical Compliance Guideline PCG 2019/1 on transfer pricing issues related to inbound distribution arrangements to ensure profit markers remain relevant and aligned to more recent market
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