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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Romania issues draft order to replace 2016 transfer pricing rules with OECD-aligned framework
Romania’s National Agency for Fiscal Administration has issued a draft order of the President regarding the thresholds of transactions, deadlines for preparation, content and conditions for requesting the transfer pricing file, and the procedure
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Colombia revises tax decree, reinforces transfer pricing compliance rules
The Colombian Ministry of Finance and Public Credit published a revised edition of Decree No. 1625 of 2016 on 8 May 2026. The decree consolidates rules covering income tax, occasional gains tax, transfer pricing, withholding tax, VAT, national
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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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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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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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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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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 transfer pricing documentation rules
Belgium published the Royal Decree of 7 December 2025 in the Official Gazette on 19 December 2025, which repeals the previous Royal Decree of 16 June 2024 concerning transfer pricing documentation. Under the new decree, taxpayers are no longer
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France strengthens transfer pricing rules under 2024 Finance Act
France has introduced new measures to reinforce the administration’s ability to detect and penalise abusive transfer pricing practices, following the publication of updates linked to Article 116 of Finance Act No. 2023-1322 of 29 December 2023 for
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Hungary consults overhaul of transfer pricing documentation rules
Hungary’s Ministry of National Economy announced, on 2 December 2025, that it is inviting feedback on a proposed overhaul of its transfer pricing documentation rules. The revision aims to clarify reporting requirements, expand the information
See MoreKorea (Rep.): Ministry of Economy and Finance proposes corporate tax hikes, AI investment incentives, QDMTT Pillar Two rules
The proposals will require approval from the National Assembly before they can enter into force. The South Korean Ministry of Economy and Finance released the 2025 tax law amendment proposal, on 31 July 2025, which includes corporate tax hikes,
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Sweden clarifies group contributions in CbC reporting
Group contributions should be excluded from profit or loss calculations in Country-by-Country (CbC) reporting. Sweden’s tax agency (Skatteverket) has issued Position Statement No. 8-174683-2025 on 17 June 2025, clarifying its stance on group
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Australia: ATO issues additional guidance on public CbC reporting
The guidance outlines several benefits of voluntary registration. The Australian Taxation Office (ATO) released additional guidance on its public country-by-country (CbC) regime on 12 June 2025. The guidance outlines several benefits of voluntary
See MoreAustralia: BoT consults on revised tax transparency code to align with public CbC reporting
Australia’s Board of Taxation has launched a consultation on 5 June 2025, proposing updates to simplify the Voluntary Tax Transparency Code (VTTC). Australia’s Board of Taxation (BoT), which oversees Australia's Voluntary Tax Transparency
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Denmark: Parliament simplifies transfer pricing rules, lowers documentation requirements
The revised rules, which will apply from the 2025 income year, are expected to exempt at least 1,500 companies that submitted documentation for the 2022 fiscal year. Denmark’s Parliament has passed amendments to Sections 39 and 40 of the
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Taiwan clarifies transfer pricing report rules for Tax Year 2024
Taiwan’s Ministry of Finance has outlined documentation requirements for 2024 controlled transactions, allowing certain enterprises to submit alternative evidence instead of a full transfer pricing report. Taiwan’s Ministry of Finance has
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