South Africa: SARS issues rules for DTA advance pricing agreement system
South Africa has introduced a detailed framework for its Double Taxation Agreement (DTA) advance pricing agreement (APA) system through six income tax notices covering applicant eligibility, fees, rejection grounds, processing requirements,
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India publishes 25-26 APA report highlighting record agreements
India's Income Tax Department has released the Advance Pricing Agreement (APA) Programme Annual APA Report FY 2025-26, detailing record activity under the country's APA programme, legislative reforms that took effect on 1 April 2026, and progress in
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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
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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
See MoreIndia: 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
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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China releases 16th annual APA report (2024), highlighting strong growth, efficiency
China’s State Taxation Administration (STA) published its 16th Annual Advance Pricing Agreement (APA) Report on 25 November 2025, providing a comprehensive overview of the country’s APA programme and its development between 2005 and 2024. The
See MoreUAE: FTA updates corporate advance pricing agreements guidance
The UAE Federal Tax Authority (FTA) has released a new Corporate Tax Guide on Advance Pricing Agreements (CTGAPA1) in December 2025. The guide outlines the procedural framework for APAs and covers an overview of the APA programme, applicable
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Kenya: KRA consults on draft income tax regulations for advance pricing agreement, minimum top-up tax for 2025
The Kenya Revenue Authority (KRA) released two draft regulations for public consultation, covering its global minimum tax regime and advance pricing agreement procedures for 2025, on 3 November 2025. In compliance with the Statutory Instruments
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Australia: ATO updates APA guidance
The Australian Taxation Office (ATO) updated Law Administration Practice Statement PS LA 2015/4 to reflect enhancements to its advance pricing arrangement (APA) programme. The changes incorporate recommendations from the ATO’s 2023 APA Programme
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