Montenegro issues rulebook on cross-border tax reporting, transfer pricing
Montenegro’s government has published Rulebook No. 10/1-1-01-040/26-2637/4 in the Official Gazette on 7 August 2026, clarifying the automatic exchange of information (AEOI) with EU member states and the European Commission (EC) on previous
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South Africa: SARS issues rules for DTA advance pricing agreement system
South Africa has introduced a detailed framework for its Double Taxation Agreement (DTA) advance pricing agreement (APA) system through six income tax notices covering applicant eligibility, fees, rejection grounds, processing requirements,
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Luxembourg: Administrative Court rules on transfer pricing treatment of debt restructuring
The Luxembourg Administrative Court (Cour administrative) issued its decision in case 53194C on 22 July 2026, concerning the application of the arm’s length principle to an intra-group debt restructuring and the deductibility of interest
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India publishes 25-26 APA report highlighting record agreements
India's Income Tax Department has released the Advance Pricing Agreement (APA) Programme Annual APA Report FY 2025-26, detailing record activity under the country's APA programme, legislative reforms that took effect on 1 April 2026, and progress in
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OECD updates signatories list for MCAA-CbC
The Organisation for Economic Cooperation and Development (OECD) released an updated list of signatories, along with their signing dates, for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports
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Malaysia issues transfer pricing guidelines for intra-group loans
Malaysia's Inland Revenue Board (IRBM) has published the Malaysia Transfer Pricing Guidelines for Intra-Group Loans (MFTIL), providing a comprehensive framework for determining whether financing transactions between associated persons comply with
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Vietnam issues comprehensive guidance on the implementation of DTA, MAP, APA
The Vietnamese Ministry of Finance has issued Circular No. 95/2026/TT-BTC, effective from 1 July 2026, setting out comprehensive guidance on the implementation of Double Taxation Agreements (DTAs), Mutual Agreement Procedures (MAP), and Advance
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EU: European Commission updates public CbC reporting taxonomy, technical guidance
The European Commission has updated its Public Country-by-Country (CbC) Reporting Taxonomy project, originally launched in 2025 to support the preparation of public CbC reports. Following a review initiated in January 2026, the Commission has
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Canada consults transfer pricing documentation amendments, various other tax measures
Canada's Department of Finance has released draft legislative proposals for public consultation on 23 July 2026 to implement a range of previously announced tax measures, along with other technical amendments to the country's tax
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Korea (Rep of.) introduces APA fast-track, expands tax support for foreign investors
South Korea's National Tax Service (NTS) has introduced a Fast-track procedure for Advance Pricing Agreement (APA) renewals and rolled out a broader package of tax support measures for foreign-invested enterprises (FIEs) aimed at strengthening the
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Chile: SII clarifies arm’s length pricing for intangibles
The Chilean tax authority (SII) has released Letter Ruling No. 1801, dated 20 July 2026, in response to a taxpayer inquiry on whether the DEMPE analysis set out in Chapter VI of the OECD Transfer Pricing Guidelines is an appropriate method for
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Poland eases transfer pricing compliance, payment penalties
The Polish Council of Ministers approved amendments to the Personal Income Tax Act and Corporate Income Tax Act on 21 July 2026, designed to cut red tape around transfer pricing disclosures and reduce penalties for misfiled payments. The changes
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Singapore adds related party transaction reporting to corporate tax compliance focus
The Inland Revenue Authority of Singapore (IRAS) has updated its Getting Companies to Comply guidance, adding the timely and accurate filing of the Form for Reporting Related Party Transactions (RPT Form) as a new ongoing area of corporate tax
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Hungary publishes new transfer pricing documentation guidance
Hungary has introduced a revised transfer pricing (TP) documentation framework through Decree No. 45/2025 (XII. 23.) NGM on 9 July 2026, accompanied by guidance from the Ministry of Finance, setting out new documentation and data reporting
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Netherlands consults bill targeting compliance simplifications, adjustment of reorganisation facilities, hybrid entity changes
The Dutch government has put forward a comprehensive legislative package designed to refine the Income Tax Act 2001, the Corporate Income Tax Act 1969, the Successions Act 1956, and other tax frameworks. Following this, the government has opened a
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South Africa: SARS publishes Advance Pricing Agreement implementation webpage
The South African Revenue Service (SARS) has published a dedicated webpage on the implementation of its Advance Pricing Agreement (APA) programme, outlining the objectives, benefits and planned pilot phase as the authority prepares to launch the
See MoreChile: SII, mining authority push advance pricing agreements to lock in transfer prices
Chile's tax authority (SII) announced on 20 July 2026 that SII and Chile’s Copper Commission (Cochilco) hosted a conference on 13 July 2026, aimed at encouraging major mining companies to enter into advance pricing agreements—formal contracts
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Argentina: ARCA simplifies goods export registration for transfer pricing
Argentina’s tax authority (ARCA) has published General Resolution 5872/2026 in the Official Gazette of 3 July 2026, which consolidates and updates the mandatory registration process for export contracts involving goods with transparent market
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