Poland publishes guidance on transfer pricing, base interest rates, and margin rates
On 29 December 2023, Poland’s Ministry of Finance released the guide on submitting transfer pricing information, which includes: Detailed FAQs related to the obligation to submit transfer pricing information; entity identification
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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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Paraguay upgrades transfer pricing documentation process
On 20 July 2023, the tax authority of Paraguay (SET) issued General Resolution No. 134 of 18 July 2023, that introduces an exceptional mechanism for the submission of the technical transfer pricing study (Estudio Técnico de Precios de Transferencia
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Malaysia: IRBM publishes transfer pricing rules 2023
On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) officially published Order No P.U. (A) 165 (TP Rules 2023) introducing a new transfer pricing documentation process effective from assessment year 2023 onwards. The main changes
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Saudi Arabia: ZATCA approves amendment to the TP Bylaws
On 20 March 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) approved Decision No. 8-2-23 to amend the Transfer Pricing (TP) Bylaws. The approved amendments to the TP Bylaws in Saudi Arabia will expand the scope of the provisions to
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Cyprus: Tax department issues FAQs on new transfer pricing legislation
On 10 February 2023, the Cyprus Tax Department published a set of Frequently Asked Questions (FAQs) aiming to clarify certain provisions of the new transfer pricing rules approved in June 2022 with effect from 1 January 2022, including Local File
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Slovak Republic amends TP documentation requirements
The Slovak Ministry of Finance (MoF) has issued new guidelines to determine the content of transfer pricing (TP) documentation, effective for the tax period starting after 31 December 2022. The guidelines reflect an amendment to the income tax
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Argentina: AFIP introduces new mandatory disclosure regime for international transactions
On 27 December 2022, Argentina's federal tax authority (AFIP) released General Resolution No.5306/2022, establishing a new mandatory disclosure regime for certain international transactions. It has replaced the previous mandatory reporting regime
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North Macedonia proposes amendments to TP reporting
Proposed amendments to the corporate income tax law regarding transfer pricing reporting would become effective from 1 January 2023. The proposed amendments include following changes: the requirement to submit a transfer pricing (TP) report to
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Germany passed law for implementation of DAC7
On 16 December 2022, Germany passed the DAC7 to modernize tax procedural law. The new law amended Section 90 of the General Tax Code (GTC) and tightened the rules on transfer pricing documentation by allowing tax authorities to request transfer
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Hungary: MoF publishes draft transfer pricing decree on TP reporting obligation
On 9 December 2022, the Hungarian Ministry of Finance issued a draft transfer pricing decree detailing a new transfer pricing reporting obligation. Accordingly, taxpayers are required to prepare a transfer pricing report on a transaction basis or on
See MoreHungary: Parliament adopts a bill imposing additional requirement for TPD
On 19 July 2022, the Hungarian Parliament passed a bill introducing important changes to the transfer pricing rules. The law introduces a significant additional reporting requirement for intra-group transactions and requires transfer pricing
See MoreCyprus: Parliament adopts new transfer pricing legislation
On 30 June 2022, the Cyprus House of Representatives enacted detailed transfer pricing legislation amending the Cyprus Income Tax Law (ITL) and the issuance of Regulations. The amendment includes the new TP documentation requirements and a framework
See MoreParaguay issues resolution on TP reporting requirements
On 7 April 2022, the tax authority of Paraguay has issued General Resolution No. 115/2022, which provides detailed rules on the preparation and submission of the transfer pricing (TP) reporting requirements as per Law No. 6380/2019 and
See MoreAngola revises number of large taxpayers required to prepare TP documentation
On 15 March 2022, the Ministry of Finance of Angola has issued Order No. 1083/22 through which the list of the large taxpayers has been revised subject to the preparation of transfer pricing (TP) documentation. The listed large taxpayers must
See MoreKazakhstan: Government invites public comments regarding transfer pricing amendments
On 16 March 2022, the State Revenue Committee announced that they opened a public consultation on a draft bill to amend transfer pricing rules. The deadline for this public comments is 8 April 2022. The draft Bill contained the following measures
See MoreItaly clarifies TP documentation requirements
On 26 November 2021, the Italian Tax Authorities issued Circular No. 15 providing clarifications on the regulations introduced on 23 November 2020 regarding the content and validity of the elective transfer pricing (TP) documentation available to
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