France expands list of CbC reporting partner jurisdictions
France has published a Ministerial Order on 24 April 2026, published in Official Journal No. 0099 of 26 April 2026, updating the list of jurisdictions that meet the conditions for exemption from local filing under its country-by-country (CbC)
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Australia: ATO clarifies general purpose financial statement filing obligations
The Australian Taxation Office (ATO) has issued a notice on 28 April 2026 outlining which entities are required to lodge a general purpose financial statement. Lodging a general purpose financial statement (GPFS) is a crucial step for various
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New Zealand tightens stance in updated TP guidance, introduces thin capitalisation infrastructure exemption
New Zealand’s Inland Revenue (IR) has issued updated guidance on Transfer Pricing Documentation and Thin Capitalisation Rules on 31 March 2026, replacing earlier versions from 2025 and 2021. The transfer pricing (TP) documentation guidance
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Canada: 2025 Budget Implementation Act overhauls transfer pricing rules, scraps digital services tax
Canada’s Bill C-15, or the Budget 2025 Implementation Act, No. 1, which received Royal Assent on 26 March 2026, introduces a major overhaul of Canada's transfer pricing regime, repeals the Digital Services Tax, and enacts a wide array of business
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India: CBDT rolls out 2026 income tax rules with expanded transfer pricing framework
India’s Central Board of Direct Taxes (CBDT) issued Notification No. 22/2026 on 20 March 2026 under the Income Tax Act, 2025, introducing the Income Tax Rules, 2026. The rules provide a comprehensive framework for income tax administration,
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UK: HMRC updates CbC reporting guidance
UK’s His Majesty's Revenue and Customs (HMRC) updated its country-by-country reporting (CbCR) guidance on 17 March 2026, clarifying which entities must report, how to register and submit reports, and the process for agents seeking
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Vietnam: MoF drafting new transfer pricing, taxpayer obligations, CbC reporting rules
The Vietnamese Ministry of Finance (MoF) is preparing a draft Decree on tax administration for related-party transactions of enterprises with affiliated relationships, in line with the Law on Tax Administration No. 108/2025/QH15. The new
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OECD updates signatories list for MCAA-CbC
The Organisation for Economic Cooperation and Development (OECD) released an updated list of signatories, along with their signing dates, for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports
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Korea (Rep.) introduces transfer pricing reforms, Pillar Two rollout
Korea (Rep.) has published Presidential Decree No. 36128, partially amending the enforcement Decree of the International Tax Adjustment Act, in the Official Gazette on 27 February 2026. The Decree introduces sweeping updates to its international tax
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Namibia: 2026-27 budget includes accelerated depreciation for businesses
Namibia's Parliament has released the Budget Statement for the Fiscal Year 2026-27 on 26 February 2026, introducing significant changes to the tax code to support both individuals and businesses. The key tax measures are: Corporate and
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Australia: ATO releases public country-by-country reporting compliance guidance
The Australian Taxation Office (ATO) has released instructions to complete the public country-by-country report on 3 March 2026. The instructions include: Public CBC report overview Overview of Public CBC report instructions and publishing
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Ukraine: MoF consults transfer pricing reform bill
Ukraine’s Ministry of Finance (MoF) opened a public consultation on a draft law titled “On Amendments to the Tax Code of Ukraine Regarding Further Improvement of Transfer Pricing Rules” on 24 February 2026. The draft was prepared with the
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Poland: Court rules deferred tax regime doesn’t exempt companies from transfer pricing rules
Poland's Supreme Administrative Court has ruled that companies using the deferred corporate income tax regime must comply with transfer pricing rules, including Local File documentation requirements. This ruling details a judgment from the
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Colombia: DIAN highlights 2025 transfer pricing adjustment requirements
Colombia’s tax authority (DIAN) has issued a notification, on 6 February 2026, for large taxpayers subject to the transfer pricing regime to make any required transfer pricing adjustments when filing their 2025 fiscal year income tax return. As
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France simplifies EU public CbC reporting rules
France adopted new rules on 28 December 2025 to streamline compliance with the EU public CbC reporting directive (Directive (EU) 2021/2101), fully aligning national law with EU requirements and implementing the multiple reporting exemption. The
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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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Belgium updates Local File form, clarifies use of ‘Termination of CBC notification obligation’
Belgium’s Federal Public Service (SPF) Finance has released a BEPS13 News update detailing the new Local File form issued in December 2025 and providing guidance on using the “Termination of notification obligation” for CbC filings
See MoreOECD publishes transfer pricing profiles for eight countries
The OECD has published the revised transfer pricing country profiles, including profiles for Bosnia and Herzegovina, Brazil, Costa Rica, Croatia, Greece, Iceland, Korea (Rep.), and Norway on 22 January 2026. These profiles focus on countries'
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