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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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
See MoreHungary 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
See MoreHungary: 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 MoreParaguay introduces new guidance on TP law
On 30 December 2020, the tax authority of Paraguay issued Decree 4644/2020, providing further guidance on the technical aspects of Paraguay’s transfer pricing (TP) provisions included in Law 6380. Law No. 6,380/2019 modernized the Paraguayan
See MoreVietnam: MoF issues new transfer pricing Decree
On 5 November 2020, the Vietnamese Ministry of Finance (MoF) has issued new transfer pricing Decree No. 132/2020/ND-CP. The new Decree replaces the existing Transfer Pricing (TP) regulations (Decree No. 20/2017/ND-CP) and provides the following new
See MoreIndia issues notification on transfer pricing tolerance range for 2019–20
On 19 October 2020, India’s Central Board of Direct Taxes has released the Notification No. 83/2020 setting the arm’s length pricing variation limit for assessment year 2020-21. Accordingly, the variation between the arm’s length price
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