Japan: National Tax Agency updates CbC exchange jurisdictions list
Japan’s National Tax Agency has published an updated list of jurisdictions for the exchange of Country-by-Country (CbC) reports. Country-by-Country (CbC) reports are a standardised tax reporting framework requiring large multinational
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Bolivia: SIN further extends 2025 filing deadline for financial statements, transfer pricing documentation
Bolivia’s National Tax Service (SIN) has issued Resolution No. 102600000017 of 27 May 2026 to further extend the deadline for the digital submission of financial statements, the annual report, the transfer pricing study, and the related-party
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Canada: CRA releases updated 2025 corporate income tax guide
The Canadian Revenue Agency (CRA) has issued an updated corporate income tax guide for tax year 2025 on 28 May 2026. The guide covers the following: Accelerated capital cost allowance (CCA) for liquefied natural gas (LNG) facilities The
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Malawi enacts 2026–27 budget, introduces VAT on digital services by foreign companies
Malawi has enacted the legislation implementing the 2026–2027 Budget, which was published in the Official Gazette on 14 April 2026 and entered into force on 15 April 2026. This follows after Malawi’s Minister of Finance, Economic Planning and
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Sweden: Court rules in favour of Kubal, overturns transfer pricing-based adjustment
Sweden’s Supreme Administrative Court has ruled in favour of Kubikenborg Aluminium AB (Kubal), overturning a transfer pricing-based adjustment made by the Swedish Tax Agency in a dispute concerning the deductibility of damages arising from an
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Kenya refines country-by-country reporting rules in Finance Bill 2026
Kenya’s Finance Bill, 2026, introduces significant updates to Country-by-Country (CbC) reporting through amendments to the Income Tax Act. These changes focus on refining definitions and aligning statutory references to ensure clarity and
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Rwanda establishes formal APA framework under new transfer pricing rulesÂ
Rwanda has introduced new transfer pricing rules establishing a clearer tax framework for controlled transactions, replacing the 2020 rules, which ceased to apply in October 2023 under the amended Income Tax Law No. 027/2022. The updated transfer
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Moldova: STS introduces electronic transfer pricing information form ahead of June deadlineÂ
Moldova’s State Tax Service (STS) has announced the rollout of an electronic transfer pricing information form within the Electronic Declaration system, accessible through taxpayers' Personal Cabinets on 12 May 2026. This new platform will handle
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Colombia revises tax decree, reinforces transfer pricing compliance rules
The Colombian Ministry of Finance and Public Credit published a revised edition of Decree No. 1625 of 2016 on 8 May 2026. The decree consolidates rules covering income tax, occasional gains tax, transfer pricing, withholding tax, VAT, national
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Italy: Supreme Court exempts certain gratuitous intragroup guarantees from transfer pricing rules
Italy’s Supreme Court has clarified the circumstances in which domestic transfer pricing rules apply to intragroup transactions, confirming that transactions conducted without consideration may remain outside the scope of transfer pricing where
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Australia: ATO announces first public CbC report deadlineÂ
The Australian Taxation Office (ATO) has issued a notice on 15 May 2026, reminding entities with a reporting period ending on 30 June 2025 that the deadline for lodging the public CbC report is 30 June 2026. The ATO is continually updating its
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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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