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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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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Ukraine updates fines for certain transfer pricing reporting violations
The State Tax Service of Ukraine issued a notice on fines for specific transfer pricing reporting violations on 5 February 2025. A penalty of 100 subsistence minimums is imposed for not submitting the notification of participation in an
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Azerbaijan amends tax code: Cuts branch profit tax, introduces new corporate tax and VAT exemptions
Azerbaijan has approved several amendments to the Azerbaijan Tax Code on 27 December 2024. Key amendments include a reduction of branch profit tax rate, new corporate income tax exemptions, and revised transfer pricing penalties. Reduction of
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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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Australia: ATO extends CbC reporting deadlines
The Australian Taxation Office (ATO) announced, on 13 November 2024, an extension for the filing deadline of country-by-country (CbC) reporting entities for the year ending 31 December 2023. The deadline has been extended until 31 January
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Albania implements country-by-country reporting legislation
Albania enacted regulations on 11 August 2024, concerning country-by-country (CbC) reporting, outlining specific rules and procedures that ultimate parent entities and constituent entities of a multinational enterprise (MNE) group must follow
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Italy approves draft public CbCR legislative decree
Italy’s Council of Ministers passed the draft decree introducing Public Country-by-Country Reporting (PCbCR) on 10 June, 2024. It amends Directive 2013/34/EU of 26 June 2013 (Accounting Directive), which pertains to the reporting of income
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Ecuador updates transfer pricing report guideline, introduces new penalties
The Internal revenue service (SRI) has issued “Resolution No. NAC-DGERCGC24-00000020” in the Ecuadorian Official Gazette on 28 May, 2024, which outlines details of the transfer pricing annex concerning related party transactions and the
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Ghana mandates transfer pricing compliance in CbC reporting
Ghana has made it mandatory for Multinational Enterprises (MNEs) operating in the country, that meet specific revenue thresholds, to provide detailed information on their worldwide operations through Country-by-Country Reporting (CbCR). MNEs are
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Nigeria: FIRS shifts e-platform for transfer pricing and CbC reporting notifications
Nigeria’s Federal Inland Revenue Service (FIRS), in a notice to taxpayers and the general public, announced the transitioning of the electronic platform for filing transfer pricing returns and country-by-country (CbC) reporting notifications from
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Qatar extends deadline for CbC reports submission
Qatar’s tax authority announced that it is extending the deadline for Qatar-based companies to submit their country-by-country (CbC) reports for the fiscal year 2022 and CbC notifications for the fiscal year 2023. The new deadline is 31 January
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Ireland publishes new guidance on requesting TP documentation
On 18 December 2023, the Irish Revenue issued eBrief No. 261/23 providing a new Tax and Duty Manual Part 35a-01-05 - Requests for Transfer Pricing (TP) Documentation. This Tax and Duty Manual documents the operational policy of the Transfer
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Egypt releases explanatory instructions on transfer pricing reporting obligations
On 19 September 2023, the Egyptian Tax Authority issued Explanatory Instruction No. 78 introducing mandatory transfer pricing reporting obligations for related party transactions. Accordingly, the Tax Authority has set deadlines for submitting
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Brazil releases normative instruction for its new transfer pricing rules
On 28 September 2023, Brazil published Normative Instruction Nº 2,161 (IN 2,161/23) that governs Brazil’s recently established new transfer pricing law. The new legislation explicitly adopts the arm's length principle into the Brazilian legal
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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
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Israel publishes guidance on CbC reporting
The Israel Tax Authority (ITA) has released guidelines and Technical instructions for the filing of Country-by-Country (CbC) reports. Multi-National Enterprise (MNE) groups with a combined revenue of ILS 3.4 billion and above, starting from the 2022
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Brazil issues new transfer pricing legislation to align with OECD transfer pricing guidelines
On 29 December 2022, the outgoing Brazilian President issued draft legislation MP 1.152 to align Brazil’s unique transfer pricing system with the OECD Transfer Pricing Guidelines. The news rule will be compulsory for 2024, for fiscal year 2023,
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