India: MoF clarifies transfer pricing tolerance range for FY 2025-26
India’s Ministry of Finance (MoF) has issued a notification on 6 November 2025, setting tolerance limits for arm’s length pricing in international and specified domestic transactions for the assessment year 2025-26. Under the new rules, the
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UK: HMRC updates transfer pricing guidance
The UK’s HM Revenue and Customs (HMRC) revised its Transfer Pricing Operational Guidance (INTM480000) on 10 November 2025. The update revises the section Searching for comparables: range of results (INTM485120), which sets out HMRC’s approach to
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Australia: Administrative Review Tribunal rules in favour of Alcoa against ATO in key transfer pricing ruling
This case focused on a major transfer pricing issue, where ATO claimed Alcoa underpriced its alumina sales to Aluminium Bahrain B.S.C. (Alba) from 1993 to 2009, causing a tax shortfall of over AUD 213 million. Australia’s Administrative Review
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Colombia: CUP method valid for commodity transactions without quoted prices
The Colombian Tax Authority (DIAN) released Ruling 1118 (Int. 81) of 13 February 2024, which provides clarification of the application of the Comparable Uncontrolled Price (CUP) method for commodity transactions between related parties that do not
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Kazakhstan’s Transfer Pricing Legislative Amendments 2023
Kazakhstan is undergoing a pivotal transformation in its transfer pricing framework, marked by the Majilis' approval of substantial amendments to the existing legislation. The aim is to curb revenue losses, prevent capital outflow, and align with
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Poland releases notice providing clarification on TPD documentation
On 4 September 2023, the Polish Official Gazetted a notice aimed at providing comprehensive clarification regarding the regulations governing transfer pricing documentation for corporate income tax purposes. This notice encompasses several key
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Spain: National Court issues rule on TP adjustment using median of arm’s length range
On 29 July 2023, the Spanish National Court issued a decision that provided clarification on the range of arm's length pricing adjustments applicable. In this case, Ferroli Spain, a Spanish manufacturer specializing in non-electric stoves,
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India: CBDT issues notification to set arm’s-length variation for 2023-2024
On 26 June 2023, the Indian Central Board of Direct Taxes (CBDT) has issued Notification No. 46/2023, setting arm's-length pricing variation limits for the 2023-24 assessment year. The limits are 1 percent for wholesale trading and 3 percent for
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Malaysia: IRBM publishes transfer pricing rules 2023
On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) officially published Order No P.U. (A) 165 (TP Rules 2023) introducing a new transfer pricing documentation process effective from assessment year 2023 onwards. The main changes
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Albania releases a law amending transfer pricing provisions
On 23 May 2023, Vietnam has deposited its instrument of approval for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). This move makes Vietnam the 81st jurisdiction to
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Hungary: MoF publishes decree amending TP rules on transfer pricing documentation
On 28 December 2022, the Hungarian Ministry of Finance published Decree 27/2022 (XII.28) which amends the Decree 32/2017 (X.18) on the documentation requirement related to the determination of arm’s length prices. Increase threshold
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Hungary gazettes the 2023 Budget bill including transfer pricing changes
On 27 July 2022, the Hungarian Official Gazette published the Budget Bill (Law XXIV of 2022) providing for amendments to the Hungarian transfer pricing regulations. The law was passed by the parliament on 19 July 2022. The law includes the following
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Hungary: Parliament adopts a bill imposing additional requirement for TPD
On 19 July 2022, the Hungarian Parliament passed a bill introducing important changes to the transfer pricing rules. The law introduces a significant additional reporting requirement for intra-group transactions and requires transfer pricing
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India: CBDT notifies the arm’s-length pricing variation limit for 2022-23
On 28 June 2022, the Indian Central Board of Direct Taxes (CBDT) issued Notification No. 70/2022, clarifying the calculation procedure of the arm’s length price under the income tax act. The notification provides a tolerance range of 1 % for
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Hungary: Finance minister presents 2023 budget bill to parliament
On 22 June 2022, the Hungarian finance minister submitted the 2023 Budget Bill in parliament providing following tax measures related to transfer pricing changes. The bill proposes to revise the regulation of the application of the interquartile
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Italy: New circular clarifies application of ALP
On 24 May 2022, the tax authority of Italy has issued Circular No. 16/E, that clarifies the application of the arm's length principle (ALP) in transfer pricing as per Decree of 14 May 2018 and Decree No. 50 of 24 April 2017 as converted by Law No.
See MoreRussia: FTS clarifies the application of transfer pricing control under sanctions
On 14 March 2022, the Federal Tax Service (FTS) published guidance (Letter No. ШЮ-4-13/2724) stipulating that the application of sanctions against Russian individuals and legal entities may adversely affect the economic conditions of the
See MoreDenmark approves the bill to relax rules on TP documentation
On 25 November 2021, the Danish Parliament passed Draft Law No. L7, which largely abolishes the obligation to include domestically, controlled transactions in the Transfer Pricing Documentation (TP). The draft law also specifies the requirement to
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