Kenya replaces 2006 transfer pricing rules with new framework
Kenya’s Income Tax (Transfer Pricing) Rules, 2026 (the 2026 TP Rules) took effect on 12 August 2026, replacing the Income Tax (Transfer Pricing) Rules, 2006 (the 2006 TP Rules). The rules were made by Cabinet Secretary for the National Treasury
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France tables Pillar Two safe harbours, CbC reporting relief
The French government tabled Amendment I-3734 to the 2027 Finance Bill (Projet de loi de finances pour 2027, No. 3210) on 10 October 2026, introducing significant updates to France’s Pillar Two global minimum tax framework. The proposal
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Australia: ATO extends 2025 public CbC reporting deadline
The Australian Taxation Office (ATO) announced, on 15 October 2026, that large corporations reporting tax information for 2025 now have until 29 January 2027 to publish their public country-by-country reports. The ATO initially set the deadline
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Belgium launches BEPS13 Local File XML Creator Tool
Belgium’s Federal Public Service Finance has announced on 30 September 2026 that the new BEPS13 LF XML creator tool is now operational. The tool enables users to generate XML files that comply with the new XSD schema 275.LF. Earlier, on 2
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Argentina: ARCA overhauls international tax, transfer pricing rules
Argentina's tax authority (ARCA) has published General Resolution 5903/2026 in the Official Gazette on 30 September 2026. This regulation completely overhauls and unifies Argentina's international tax and transfer pricing rules into a single,
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Turkey introduces specialised audits for tax evasion, transfer pricing
Turkey’s Tax Audit Board announced that three new specialised departments would become fully operational from 1 October 2026 as part of efforts to strengthen tax audits through specialisation, data analytics, digital auditing and risk-based
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Singapore updates guidance on transfer pricing treatment of share-based compensation from YA 2026
The Inland Revenue Authority of Singapore (IRAS) updated its Transfer Pricing guidance page on 25 September 2026 with additional guidance on transfer pricing adjustments relating to share-based compensation. The update sets out a revised
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Australia: ATO issues new guidance on Country-by-Country reporting requirements
The Australian Taxation Office (ATO) has released new guidance on 25 September 2026 on administrative matters related to Country-by-Country (CbC) reporting. The updates clarify lodgment deadlines, extension procedures, and international obligations
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Ukraine proposes broad transfer pricing reforms
The Ukrainian Parliament is reviewing the draft Law on amendments to the tax code of Ukraine regarding further improvement of Transfer Pricing (TP) rules, which was submitted on 4 September 2026. If adopted, the lew would enter into force on 1
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Belgium hosts webinar clarifying updated BEPS 13 transfer pricing forms filing requirements, CbC reporting
Belgium's tax authorities hosted a webinar attended by over 200 participants to address technical implementation requirements for updated BEPS 13 reporting forms on 7 September 2026. The session covered the country-by-country (CbC) notification
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Australia: ATO tightens CbC reporting exemptions, extends administrative relief indefinitely
The Australian Taxation Office (ATO) has implemented significant updates to its Country-by-Country (CbC) reporting exemptions and administrative relief guidelines for requests received from 1 January 2025. It details the specific criteria and
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EU: European Commission updates public CbC reporting taxonomy, technical guidance
The European Commission has updated its Public Country-by-Country (CbC) Reporting Taxonomy project, originally launched in 2025 to support the preparation of public CbC reports. Following a review initiated in January 2026, the Commission has
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Canada consults transfer pricing documentation amendments, various other tax measures
Canada's Department of Finance has released draft legislative proposals for public consultation on 23 July 2026 to implement a range of previously announced tax measures, along with other technical amendments to the country's tax
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Hungary publishes new transfer pricing documentation guidance
Hungary has introduced a revised transfer pricing (TP) documentation framework through Decree No. 45/2025 (XII. 23.) NGM on 9 July 2026, accompanied by guidance from the Ministry of Finance, setting out new documentation and data reporting
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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 13 July 2026 on draft guides for transfer pricing documentation and establishing the arm's length range. The Q&A-style guides reflect the most common compliance
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France issues rules for preparing, filing CbC reporting
France has published the Order of 3 July 2026 in the Official Gazette on 9 July 2026, establishing the rules for preparing and filing the profit tax information declaration (Public Country-by-Country Report) required under the French Commercial
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Vietnam gazettes decree updating transfer pricing rules
Vietnam has published Decree No. 255/2026/ND-CP, issued on 30 June 2026, introducing a new framework for tax administration of enterprises engaged in related-party transactions. The Decree sets out the principles, methods and compliance requirements
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US: IRS reviews CbC report exchange status, makes no changes
The US Internal Revenue Service (IRS) published a reviewed version of its Country-by-Country (CbC) Reporting Jurisdiction Status Table on 1 July 2026. The previous update, released on 1 July 2025, reflected the addition of the competent authority
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