Singapore: IRAS updates transfer pricing guidance, raises indicative margin for related party loans
The Inland Revenue Authority of Singapore (IRAS) has updated its Transfer Pricing guidance for 2026 on 2 January 2026, including the indicative margin for related party loans. For the year 2026, the indicative margin applicable to Risk-Free Rates
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Kenya repeals digital assets tax, expands economic presence tax under Finance Act 2025
The Finance Act 2025 introduces a 10% excise duty on virtual asset transaction fees, expanded SEP tax, a 5-year loss carry forward limit, AMT, and new APA guidelines. Kenya’s President William Ruto signed the Finance Act 2025 into law on 26
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Hungary updates tax rates on retail, financial entities, and insurance sectors
Act LIV of 2025 introduces updated tax rates, increased VAT thresholds, and new regulations across retail, financial, insurance, and energy sectors, along with enhanced R&D deductions. Hungary has published Act LIV of 2025 in the Official
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UK: HMRC updates guidance on unilateral APA programme for development CCAs
HMRC has updated its international manual with new guidance and a sample agreement for a unilateral APA programme covering UK entities’ participation in development cost contribution arrangements. The UK HM Revenue & Customs (HMRC) has
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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
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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
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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
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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
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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
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Saudi Arabia releases third edition of transfer pricing guidelines
The Zakat, Tax and Customs Authority (ZATCA) in Saudi Arabia published the third edition of its Transfer Pricing (TP) Guidelines on 29 July 2024, introducing several changes. Key updates include: Exemptions for group companies: Group
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UAE: FTA introduces new guidelines for corporate tax clarifications, APA submissions
In a move aimed at enhancing clarity and support for taxpayers in the UAE, the Federal Tax Authority (FTA) has introduced new guidelines under Decisions No. 4 and No. 5 of 2024. These decisions, which took effect on 1 July and 1 August respectively,
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UAE: FTA announces implementation of advance pricing agreements in Q4 2024
The UAE Federal Tax Authority (FTA) updated Decision No. 4 of 2024 on 12 June 2024, clarifying the future implementation of an advance pricing agreements (APAs) framework in the UAE. Based on the Corporate Tax Law, a person may make an
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Switzerland publishes transfer pricing guidelines
On 23 January 2024, the Swiss Federal Tax Administration published the updated Transfer Pricing Guide. The main provisions of the guide include: An overview of the arm's length principle and the consequences of non-compliance under Swiss law.
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Poland announces guide on filing transfer pricing reporting forms
On 23 January 2024, Poland’s Ministry of Finance released a notice outlining the process for submitting transfer pricing reporting (TPR) forms for acquired entities. This requirement applies to tax years commencing after 31 December 2021. The
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Israel releases Guidance on MAP and APA procedures
On 17 August 2023, the Israel Tax Authority (ITA) released Tax Circular No. 1/2023, which provides guidance for mutual agreement procedure (MAP), and bilateral advance pricing agreement (APA) requests. The new circular replaces the guidance of
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Luxembourg: Government submits draft bill on transfer pricing and general tax procedures
On 28 March 2023, the Luxembourg government submitted Bill No. 8186 to the Parliament. The bill includes changes in advance pricing arrangement (APA), mutual agreement procedure (MAP), compliance with transfer pricing documentation requirements, and
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US: Sixth Circuit affirms taxpayer not liable for penalty upon cancellation of APAs
On 25 August 2022, the U.S. Court of Appeals for the Sixth Circuit affirmed in part and reversed in part a decision of the U.S. tax court regarding the transfer pricing case of Eaton Corp. v. Commissioner. Facts of the case Eaton Corporation
See MoreMexico: Congress approves Economic Package for the fiscal year 2022
On 26 October 2021, Mexican Congress has approved the tax reform for 2020 which was presented for the fiscal year 2022 which was presented on 8 September 2021. The Economic Package clarifies income tax law, value-added tax (VAT) law, excise tax
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