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 More
Germany suspends new advance pricing agreements with China
Until further notice, the BZSt, as the competent authority for APAs, will not initiate any new procedures aimed at concluding APAs with China. Germany has temporarily suspended the initiation of new advance pricing agreements (APAs) with China,
See More
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
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
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
Ireland: Irish Revenue makes changes to bilateral advance pricing agreement guidelines
On 26 April 2024, the Irish Revenue published eBrief No. 127/24 outlining the updated Tax and Duty Manual Part 35-02-07 Bilateral Advance Pricing Agreement Guidelines. The updated Guidelines take into account international best practices in relation
See MoreMalta seeks comments on draft Transfer Pricing Rules
On 22 December 2021, Malta’s Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come
See MoreUkraine: Cabinet of Ministers adopts new APA procedures
On 28 October 2021, the Cabinet of Ministers of Ukraine has adopted new procedures of preliminary coordination of advance pricing agreements (APAs) in controlled transactions, as a result of which agreements on preliminary coordination of pricing,
See MoreTaiwan: MOF issues Decree on cross-border bilateral, multilateral APAs under MAP
On 24 June 2021, the Ministry of Finance issued a Decree which stipulates that when tax collection authorities negotiate cross-border bilateral or multilateral advance pricing arrangements (APAs) (hereinafter referred to as "BAPAs") with the
See MoreSwitzerland: Review on international financial and tax matters of 2020
Switzerland’s Secretariat for International Finance (SIF) has published its annual review on international financial and tax matters for 2020. With respect to tax-related matters in particular, the review includes the following: Taxing
See MoreGreece: Government publishes a Law amending APA rollback rules
On 31 July 2020, the Government Officially published Law 4714/2020, which amends the existing advance pricing agreement (APA) provisions. The new Law helps to comply with the minimum standard under Action 14 of the OECD’s base erosion and profit
See MoreIndonesia publishes new regulations concerning advance pricing agreements
On 18 March 2020, the Indonesian Ministry of Finance released 22/PMK.03/2020 which updates the Advance Pricing Agreements (“APA”) regulations. The new regulations, effective 18 March 2020, include the following amendments: Previously
See MoreQatar introduces directives on MAP
On 11 February 2020, Qatar's General Tax Authority (GTA) has published following six directives on the application of the mutual agreement procedure (MAP) under double taxation avoidance agreements in relation to the implementation of base erosion
See MoreIndia: CBDT signs 18 new APAs
On 3 April 2019, the Central Board of Direct Taxes (CBDT) has announced the signing of 18 advance pricing agreements (APAs) during March 2019, including three bilateral APAs. With the signing of these APAs, the total number of APAs entered into
See MoreIndia: CBDT publishes second APA annual report
The Central Board of Direct Tax (CBDT) released the second annual report (2017-18) of its advance pricing agreement (APA) programme on 31 August 2018. The report introduced a report card of the performance of the programme along with qualitative and
See MoreIndia: CBDT signs first ever substantive revision to India-UK Bilateral APA
Recently, the Central Board of Direct Taxes (CBDT) signed the first ever substantive revision to an India-U.K. Bilateral advance pricing agreement (APA) due to certain changes in the way a particular transaction was being conducted. The changes were
See More