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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Poland: Senate passes transfer pricing, business tax reporting reforms
Poland's Senate (Upper house of Parliament) passed a legislation that reshapes how small businesses handle tax reporting and cash transactions. The Act of 18 September 2026, transmitted as Senate Print No. 834 (Druk nr 834), amends both the
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Australia: ATO updates GILTI guidance following US tax regime changes
The Australian Taxation Office (ATO) has issued an Addendum to Taxation Determination TD 2022/9 by the Commissioner of Taxation on 23 September 2026 to account for amendments to the US global intangible low-taxed income (GILTI) regime introduced
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Latvia: SRS issues transfer pricing controlled transaction report guidance
Latvia’s tax authority, the State Revenue Service, on 18 September 2026, issued the methodological guidance covering transfer pricing controlled transaction report requirements. These documents provide official guidelines from the Latvian State
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Netherlands updates interest deduction limitation rules
The Netherlands published Policy Decision No. 2026-17016 of 10 September 2026 from the State Secretary of Finance on 22 September 2026, updating and replacing the 2025 decision on the interest deduction limitation, or earnings stripping,
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Ukraine proposes broad transfer pricing reforms
The Ukrainian Parliament is reviewing the draft Law on amendments to the tax code of Ukraine regarding further improvement of Transfer Pricing (TP) rules, which was submitted on 4 September 2026. If adopted, the lew would enter into force on 1
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Australia: Federal Court upholds AUD 173.3m tax benefit adjustment against Hilton
The Federal Court of Australia rejected Hilton International Australia Pty Ltd's challenge to the Commissioner of Taxation on 9 September 2026 (Case: Hilton International Australia Pty Ltd v Commissioner of Taxation (No 2) FCA 1325). Justice Younan
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Panama: DGI extends transfer pricing report filing deadline for specified taxpayers
Panama’s tax authority (DGI) has published Resolution No. 201-6989 (issued on 2 September 2026) in the Official Gazette on 8 September 2026 extending the deadline for filing the Transfer Pricing Report (Form 930) for taxpayers operating under a
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Belgium hosts webinar clarifying updated BEPS 13 transfer pricing forms filing requirements, CbC reporting
Belgium's tax authorities hosted a webinar attended by over 200 participants to address technical implementation requirements for updated BEPS 13 reporting forms on 7 September 2026. The session covered the country-by-country (CbC) notification
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Iceland: MoF consults tax law changes on interest deductions, charities, rulings and nicotine products
Iceland’s Ministry of Finance and Economic Affairs (MoF) has initiated a public consultation on several proposed legislative amendments in its draft document on 4 September 2026, with a targeted entry into force on 1 January 2027. These planned
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Malaysia gazettes Income Tax (Transfer Pricing) (Amendment) Rules 2026
Malaysia’s government has published Order No. P.U. (A) 300/2026, the Income Tax (Transfer Pricing) (Amendment) Rules 2026, in the Official Gazette on 27 August 2026, officially updating Malaysia's regulatory framework regarding transactions
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Ireland: Revenue clarifies Section 110 transfer pricing, profit participating note rules
Ireland Revenue has clarified the application of Section 110 of the Taxes Consolidation Act (TCA) 1997, including Transfer Pricing, arm's length requirements and restrictions on profit participating notes (PPNs), in eBrief 120/2026 published on 21
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Morocco announces ratification of MCAA-CbC
Morocco published Royal Decree No. 1.26.72 in the Official Gazette on 12 August 2026, promulgating Law No. 76.19, which ratifies the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA). The law
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Australia: ATO tightens CbC reporting exemptions, extends administrative relief indefinitely
The Australian Taxation Office (ATO) has implemented significant updates to its Country-by-Country (CbC) reporting exemptions and administrative relief guidelines for requests received from 1 January 2025. It details the specific criteria and
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