Ukraine clarifies transfer pricing penalty changes effective from March 2025
These amendments, which took effect on 25 March 2025, adjust the penalties applicable to late or missing submissions of TP-related reports and notifications. The Ukrainian State Fiscal Service issued a clarification on upcoming changes to the Tax
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Ecuador extends transfer pricing filing deadlines for 2024
Ecuador has extended the 2024 transfer pricing filing deadlines to September 2025 for qualifying taxpayers. Ecuador’s Internal Revenue Service (SRI) published Resolution No. NAC-DGERCGC25-00000012 in the Official Gazette on 7 June 2025,
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Algeria extends 2024 transfer pricing filing deadline
The deadline has been further extended to 5 June 2025. Algeria's Directorate General of Taxes announced on 28 May 2025 an extension of the 2024 transfer pricing declaration deadline for the 2024 financial year. Algeria’s tax authorities have
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Kazakhstan updates CbC notification form, mandates e-filing
Kazakhstan has revised the MNE group participation notification or country-by-country (CbC) notification form through Order No. 84 of 24 February 2025. The Order No. 84 amends Order No. 178 of 14 February 2018, which includes adjustments to the
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Algeria extends 2024 transfer pricing and individual income tax filing deadlines
Algeria's Directorate General of Taxes announced on 14 April 2025 that it had extended the deadline for the annual transfer pricing declaration, which must be submitted electronically, for the 2024 fiscal year. Taxpayers now have until 31 May
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UN Tax Committee: Transfer Pricing Subcommittee Discusses Future Guidance
On 26 March 2025 the UN Tax Committee discussed their transfer pricing work. Since the previous session of the Committee, the Subcommittee on Transfer Pricing has gathered feedback from members on possible future workstreams that could be pursued by
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Brazil extends commodity transaction registration deadline
Brazil has extended the deadline for commodity transaction registration deadline, issued in Normative Instruction No. 2.249 of 6 February 2025 which outlines amendments to Normative Instruction RFB No. 2.161 of 28 September 2023 regarding transfer
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Costa Rica issues draft resolution on annual transfer pricing reporting obligation
Costa Rica's Directorate-General of Taxation has published a notice in the Official Gazette announcing a public consultation on a draft resolution on 13 February 2025. The resolution pertains to submitting the informative statement on transfer
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Azerbaijan plans to raise penalties for CBC reporting tax non-compliance
Azerbaijan has proposed changes to the Tax Code on penalties for tax non-compliance and country-by-country (CbC) reporting. The penalty for failing to submit requested documents and information to the tax authorities within 60 days will be
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India extends transfer pricing safe harbor rules to FY 2024-25, updates filing deadline for international transactions
India's Central Board of Direct Taxes (CBDT) has released Notification No. 124/2024 outlining the Income Tax (Tenth Amendment) Rules, 2024 on 29 November 2024. According to the amendment, the transfer pricing safe harbor rules under Rule 10TD of
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El Salvador launches ‘Inspectores Fiscales Sin Fronteras’ programme to combat tax evasion
El Salvador’s Ministry of Finance has launched the "Inspectores Fiscales Sin Fronteras" programme to improve tax auditing and criminal investigations, focusing on Transfer Pricing and Tax Crime Investigation. The initiative aims to strengthen
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Argentina issues transfer pricing rules for SPV transactions under large investment incentive regime
Under the new rules, SPVs must annually file transfer pricing analyses with the ARCA for both local and international transactions, including those in low- or no-tax jurisdictions, and may engage in Contribution and Cost Sharing
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Cyprus revises transfer pricing FAQs
The Cyprus Tax Department announced that it updated its Frequently Asked Questions (FAQs) (English version) on transfer pricing on 24 September 2024. New questions are added from 25 through 43. The main question is 25, which highlights that
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Germany seeks to extend deadline for transfer pricing documentation reporting, reduce bureaucratic burden on taxpayers
Germany’s government has proposed to extend the deadline for taxpayers to submit detailed transfer pricing documentation, and to revise the guidelines for how companies compile information for audits. Germany's first chamber approved a bill
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Costa Rica updates beneficial ownership registry rules, extends 2024 filing deadline
Costa Rica’s General Directorate of Taxation (DGT) and the Costa Rican Institute on Drugs (ICD) updated the regulations governing the beneficial ownership registry; they jointly issued Resolution No. MH-DGT-RES-0020-2024 / DG-336-2024 in the
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Poland updates transfer pricing reporting FAQs
Poland’s Ministry of Finance released the fifth edition of the transfer pricing reporting Q&A (TPR Guide 2023) on 4 September 2024, offering an updated collection of answers to frequently asked questions about transfer pricing reporting
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UK releases new transfer pricing compliance guidelines
The UK’s tax authority, HM Revenue & Customs (HMRC), published new transfer pricing compliance guidelines, Guidelines for Compliance—Help with common risks in transfer pricing approaches—GfC7’ (Guidelines for Compliance), on 10 September
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Turkey extends Q2 2024 provisional tax return deadline
Turkey's Revenue Administration has announced an extension for the submission of the provisional tax return for the second quarter of the 2024 accounting period. The deadline has been moved from 19 August 2024 to 27 August 2024. Normally,
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