Argentina: ARCA simplifies goods export registration for transfer pricing
Argentina’s tax authority (ARCA) has published General Resolution 5872/2026 in the Official Gazette of 3 July 2026, which consolidates and updates the mandatory registration process for export contracts involving goods with transparent market
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Lithuania consults transfer pricing documentation, arm’s length range draft guides
The Lithuanian State Tax Inspectorate (STI) has opened a public consultation on draft guides for transfer pricing documentation and establishing the arm's length range on 13 July 2026. The Q&A-style guides reflect the most common compliance
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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.
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Panama: DGI updates transfer pricing reporting form ahead of 2026 filing season
Panama's tax authority (DGI) has announced the approval of a new version of the transfer pricing information return (Form 930 – Version 3) under Resolution No. 201-4247 of 16 June 2026, published in the Official Gazette on 1 July 2026. The
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Bolivia: SIN further extends 2025 filing deadline for financial statements, transfer pricing documentation
Bolivia’s National Tax Service (SIN) has issued Resolution No. 102600000017 of 27 May 2026 to further extend the deadline for the digital submission of financial statements, the annual report, the transfer pricing study, and the related-party
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Moldova: STS introduces electronic transfer pricing information form ahead of June deadline
Moldova’s State Tax Service (STS) has announced the rollout of an electronic transfer pricing information form within the Electronic Declaration system, accessible through taxpayers' Personal Cabinets on 12 May 2026. This new platform will handle
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Brazil: New transfer pricing framework brings strategic shift for multinationals
Brazil has fundamentally restructured its transfer pricing system through Law No. 14,596/2023 and RFB Normative Instruction No. 2,161/2023, marking a decisive shift toward OECD standards. The arm's length principle takes centre stage The
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Georgia introduces reporting obligations for international controlled transactions exceeding GEL 500,000
Georgia has issued Order No. 52 of 24 February 2026, in the Official Gazette, establishing a new annual obligation to report information on international controlled transactions. The order introduces a mandatory reporting requirement for entities
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Latvia introduces controlled transactions report to streamline transfer pricing compliance
Latvia has significantly reshaped its transfer pricing compliance framework from 1 January 2026, following amendments to the Law “On Taxes and Fees” adopted at the end of 2025. The changes are designed to modernise reporting requirements, reduce
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Denmark issues consolidated rules on tax-free business conversions
The Danish Official Gazette published Executive Order No. 24/2026 on 13 January, proclaiming the consolidated text of the Act on Tax-Free Business Conversion. The consolidation incorporates amendments introduced by Act No. 1576 of 27 December 2019,
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Tunisia mandates electronic submission of tax returns, transfer pricing declaration
Tunisia’s tax administration, the Directorate General of Taxes, issued a notice on 11 November 2025, informing taxpayers, who are required to file tax returns, and legal entities, who are required to submit the annual transfer pricing declaration,
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Costa Rica: DGT updates transfer pricing return dates for 2024, 2025
Costa Rica’s tax administration (DGT) has published Resolution MH-DGT-RES-TEMPORAL-0001-2025 in the Official Gazette on 31 October 2025 clarifying deadlines for submitting the transfer pricing information returns for fiscal years 2024 and
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Brazil mandates disclosure of ultimate beneficial owners of investment funds, companies
Brazil’s Federal Revenue Service published an update to the rule on 31 October 2025, which deals with the identification of the ultimate beneficiaries of investment funds, companies, and legal arrangements operating in the country. This measure
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Slovak Republic updates transfer pricing documentation guidelines
Regfollower Desk The Slovak Republic’s Ministry of Finance has released updated guidelines on transfer pricing documentation (MF/012879/2025-724) and introduced a new 2025 corporate income tax return form, which includes a redesigned “Table I
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Bulgaria consults proposed transfer pricing reforms, positions to match OECD standards
The consultation is set to conclude on 23 October 2025. Bulgaria has initiated a public consultation on its proposed draft regulations to update its transfer pricing regulations as part of its efforts to join the Organisation for Economic
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Poland: MoF announces measures to combat aggressive transfer pricing strategies
The new measures assist the National Tax Administration in detecting and countering large corporations that evade or underreport their income tax. Poland’s Ministry of Finance has announced two new measures on 19 August 2025, to tackle
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Costa Rica gazettes new resolution on transfer pricing information return
The new resolution will take effect on 4 August 2025, replacing the 2016 and 2017 resolutions. Costa Rica's Tax Administration (DGT) has published Resolution MH-DGT-RES-0026-2025 in the Official Gazette on 24 July 2025, which pertains to the
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France approves Amount B simplified transfer pricing method for transactions with developing countries
France will restrict the use of the OECD's Amount B transfer pricing method to transactions with developing nations that have adopted the method and have a bilateral tax treaty with France, excluding non-qualifying jurisdictions. France
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