US: IRS issues guidance on APA submission review
The US Internal Revenue Service (IRS) Large Business and International (LB&I) division released memorandum LB&I-04-0425-0005 on 22 April 2025, which reissues interim guidance LB&I-04-0423-0006 on 25 April 2023. This
See More
India: CBDT signs record number of advance pricing agreements in FY 2024-25
The Indian Central Board of Direct Taxes (CBDT) announced that India has entered into a record 174 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2024-25. These include Unilateral APAs (UAPAs), Bilateral APAs (BAPAs) and Multilateral
See More
Ukraine: State Tax Service highlights possibility of concluding АРА agreement
Ukraine’s State Tax Service, in a release, highlighted the possibility of concluding Advance Pricing Arrangement (АРА) on 28 March 2025. Transfer pricing rules in Ukraine, introduced since 2013, are a tool to combat tax evasion and ensure
See More
US: IRS report shows decline in APA executions and completion times in 2024
The US Internal Revenue Service (IRS) released Announcement 2025-13 - Announcement and Report Concerning Advance Pricing Agreements on 27 March 2025. The report outlines the experience, structure, and activities of the Advance Pricing and Mutual
See More
Moldova updates transfer pricing rules, adds new APA regulations
Moldova published Order No. 21 of 11 March 2025 in the Official Gazette on 14 March 2025, establishing rules for the country's new transfer pricing regime. The Order No. 21 of 11 March 2025 amends Order No. 9 of 26 January 2024. A key change
See More
Chile introduces new advance pricing agreement process
Chile’s Internal Revenue Service (SII) has issued Resolution No. 28 of 6 March 2025 on 6 March 2025, introducing a new approach for taxpayers to request advance pricing agreements (APAs). This new resolution replaces previous resolutions from
See MoreOECD: Report on Simplified Peer Review of Peru under BEPS Action 14
On 4 March 2025 the OECD issued a stage one simplified peer review report on Peru under BEPS action 14. The report sets out the results of Stage 1 of the simplified peer review of the implementation of the minimum standard on making dispute
See More
Saudi Arabia issues advance pricing agreement guidelines
Saudi Arabia’s Zakat, Tax and Customs Authority has released guidelines for its new advance pricing agreement (APA) regime. According to the guidance from the Zakat, Tax and Customs Authority, the program "will not process Bilateral and
See More
Sri Lanka publishes new Advance Pricing Agreements guide
The Inland Revenue Department of Sri Lanka has announced the release of a new guide on Advanced Pricing Agreements (APAs) on 6 January 2025. This guide provides an overview of the APA process in Sri Lanka, including detailed steps, documentation
See More
India: CBDT releases 6th annual report on APA programme
India’s Central Board of Direct Taxes (CBDT) has published its 6th Annual Report on the country’s Advance Pricing Agreement (APA) programme for the fiscal year 2023-24. A record 125 APAs were signed, marking the highest number in a single
See More
China publishes 15th APA programme report
China’s State Taxation Administration (STA) has published its 15th annual report on the advance pricing agreement (APA) programme on 26 December 2024. The report provides comprehensive statistical insights into the implementation of the APA
See More
US, Norway Competent Authority Arrangement (CAA) enters into force
The US Internal Revenue Service (IRS) has issued Announcement 2024-42 on 9 December 2024 in which it notified taxpayers the US and Norway has entered a competent authority arrangement (CAA) in accordance to the paragraph 2 of Article 27 (mutual
See More
Nigeria: FIRS publishes guidance on advance pricing agreements
Nigeria’s Federal Inland Revenue Service (FIRS) has released detailed guidelines on Advance Pricing Agreements (APAs), providing a framework for companies to establish transfer pricing agreements with tax authorities in advance. Businesses
See More
Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
See More
UK considers changes to transfer pricing, advance pricing rules in Autumn Budget 2024
UK’s Chancellor of the Exchequer Rachel Reeves, in her Autumn Budget 2025 announcement on 30 October 2024, said her government is considering modernising the country’s transfer pricing rules and the advance pricing agreement system. Reeves
See More
UN Tax Committee: Issues in Extractive Industries Taxation
On 15 October 2024 the UN Tax Committee discussed developments in their work on extractive industries taxation. The work of the relevant subcommittee has focused on the energy transition; the valuation of mining products for tax purposes; and tax
See More
UN Tax Committee: Transfer Pricing Issues
On 16 October 2024 the UN Tax Committee discussed transfer pricing issues. The transfer pricing subcommittee presented for approval a paper on dispute resolution addressing the implementation of advance pricing agreement (APA) programs. The
See More
Peru approves retroactive application of APAs
The Peruvian Executive Branch has announced the approval of Legislative Decree No. 1662, dated 24 September 2024, which modifies the Advance Pricing Agreement (APA) provision in the income tax law to permit the retroactive application (roll-back) of
See More