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
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Rwanda establishes formal APA framework under new transfer pricing rules
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
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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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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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