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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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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Peru: SUNAT extends deadline for local file submissions 2025
Peru's National Superintendency of Customs and Tax Administration (SUNAT) has extended the deadline for submitting the Informative Sworn Statement "Reporte Local" or Local File (Report) (Virtual Form No. 3560) for the 2025 tax year. The extension
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Bahrain publishes transfer pricing guidance for MNEs
Bahrain's National Bureau for Revenue (NBR) has published the DMTT Transfer Pricing Guide, providing guidance on the application of transfer pricing requirements under Decree-Law No. 11 of 2024, which introduced a global minimum tax through a
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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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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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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 MoreHungary updates transfer pricing documentation framework
Hungary has adopted revised transfer pricing documentation rules under Decree No. 45/2025, published in the Official Gazette on 23 December 2025. The revised rules will require taxpayers to reassess their compliance approach ahead of the 2026
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Colombia: DIAN raises tax value unit for 2026
The Colombian Tax and Customs National Authority (DIAN) issued Resolution No. 000238 on 15 December 2025, setting the Tax Value Unit (Unidad de Valor Tributario – UVT) for 2026 at COP 52,374. This is an increase from COP 49,799 in 2025. The UVT
See MorePeru: Government raises tax unit value for 2026
Peru’s government, through Supreme Decree No. 301-2025-EF issued on 17 December 2025, has set the Tax Unit (Unidad Impositiva Tributaria – UIT) for 2026 at PEN 5,500, up from PEN 5,350. The UIT is a key reference in the country’s tax
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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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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
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Morocco: Government approves draft decree updating transfer pricing documentation, filing rules
Morocco's Council of Government approved draft Decree No. 2.22.1020 on 13 November 2025, introducing updated transfer pricing documentation and filing rules. The decree specifies the content required for both the master and local files and sets
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Argentina tightens reporting rules on cross-border transaction
RF Report Argentina published Decree 767/2025 in the Official Gazette on 28 October 2025, introducing significant updates to its cross-border transaction reporting rules, effective for fiscal years ending on or after 29 October 2025. The
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Denmark: Transfer Pricing documentation submission deadline set for FY 2025
Danish companies must submit comprehensive transfer pricing documentation, including master and local files and intercompany agreements, within 60 days of their corporate tax return to comply with section 39 of the Danish Tax Control
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Australia: ATO updates country-by-country reporting rules from 2025
The Australian Taxation Office (ATO) introduced changes to Country-by-Country reporting (CbCR) from 1 January 2025, which requires Version 4 of the local file/master file schema for reporting periods starting on or after 1 January
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Australia: ATO issues guidance for local file and master file, private property and construction sector company transfer pricing for 2025
The Australian Taxation Office (ATO) has published updated guidance on the local and master file requirements – which applies to reporting periods beginning on or after 1 January 2024 –, and transfer pricing guidance for the private property and
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