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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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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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
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Chile: 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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Romania gazettes modernised advance pricing agreement, transfer pricing documentation rules
Romania has published Order No. 827/2026 and Order No. 828/2026 in the Official Gazette on 30 June 2026. Order No. 827 revises the procedures and application requirements for issuing and modifying advance pricing agreements (APAs), while Order No.
See MoreRomania: ANAF approves updated transfer pricing rules to prevent tax disputes, align with OECD standards
Romania's Ministry of Finance and the National Agency for Fiscal Administration (ANAF) announced, on 30 June 2026, that they have introduced revised transfer pricing regulations designed to bring greater clarity and consistency to how multinational
See MoreRomania: ANAF modernises advance pricing agreement rules
Romania's National Agency of Fiscal Administration (ANAF) has unveiled a draft Order to replace the longstanding procedure governing advance pricing agreements (APAs), which has operated under Order No. 3735/2015 for over a decade. The proposed
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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
See MoreRwanda 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
See MoreSouth 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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Montenegro 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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France clarifies MAP access rules, APA roll-back conditions in transfer pricing guidance
The French tax authority issued updated guidance on Mutual Agreement Procedures (MAP) and Advance Pricing Agreements (APA) on 15 April 2026, following a public consultation launched on 15 January 2025. The revisions provide clarification on MAP
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UAE: FTA issues revised rulings framework covering APAs, tax transaction directives
The UAE Federal Tax Authority (FTA) has issued an updated Policy on Issuing Clarifications and Directives, amended by Decision No. 2 of 23 February 2026 and effective from 1 March 2026. A key update is the introduction of Directives on Tax
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Brazil: New transfer pricing framework brings strategic shift for multinationals
Brazil has fundamentally restructured its transfer pricing system through Law No. 14,596/2023 and RFB Normative Instruction No. 2,161/2023, marking a decisive shift toward OECD standards. The arm's length principle takes centre stage The
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India: CBDT signs record 219 APAs in FY 2025-26
India’s Central Board of Direct Taxes (CBDT), under the Ministry of Finance’s Department of Revenue has announced the signing of a record 219 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2025-26. This total includes both
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US: IRS reports decline in advance pricing agreement executions amid staffing challenges
The US Internal Revenue Service (IRS)Â released Announcement 2026-08 on 30 March 2026, revealing a decline in advance pricing agreements executed during 2025. The annual report from the Advance Pricing and Mutual Agreement (APMA) Program shows
See MoreIndia: CBDT rolls out 2026 income tax rules with expanded transfer pricing framework
India’s Central Board of Direct Taxes (CBDT) issued Notification No. 22/2026 on 20 March 2026 under the Income Tax Act, 2025, introducing the Income Tax Rules, 2026. The rules provide a comprehensive framework for income tax administration,
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UN Tax Committee Discusses Transfer Pricing
On 24 March 2026 the UN Committee of Experts on International Cooperation in Tax Matters discussed the workstreams for transfer pricing during the current mandate of the Committee. The subcommittee on transfer pricing presented its planned
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