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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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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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
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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
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Peru: 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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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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Egypt simplifies tax environment for businesses
The Egyptian Ministry of Finance announced a series of initiatives aimed at improving the tax environment for businesses; introducing a simplified tax regime for businesses with a turnover of up to EGP 15 million, covering small businesses, sole
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Australia: ATO issues local and master file guidance for 2024
The Australian Taxation Office (ATO) issued guidance for the local and master file requirements for 2024 on 15 July, 2024. This guidance applies to reporting periods commencing from 1 January 2023. This guidance includes the Local file
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Australia ATO introduces change to CbC local file reporting from 2025
The Australian Taxation Office (ATO) released a notice announcing changes to the Country-by-Country (CbC) Local file reporting on Wednesday, 1 May 2024. These changes will take effect starting 1 January 2025. The key points of the notice
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Slovak Republic releases 2023 transfer pricing documentation guidelines
Slovak Republic's Ministry of Finance has issued guidelines (MF/020061/2022-724) outlining the requirements for transfer pricing documentation for 2023. These guidelines categorise transfer pricing documentation into three types: Full-scope
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Cyprus announces updates to its transfer pricing FAQs
On 28 March 2024, the Cyprus Tax Department released the updated version of its English-language Frequently Asked Questions (FAQs) on transfer pricing. The FAQs present the questions and the corresponding answers as published on the Tax
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Kazakhstan’s Transfer Pricing Legislative Amendments 2023
Kazakhstan is undergoing a pivotal transformation in its transfer pricing framework, marked by the Majilis' approval of substantial amendments to the existing legislation. The aim is to curb revenue losses, prevent capital outflow, and align with
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Ecuador releases updated technical sheet for standardizing the analysis of transfer pricing
On 22 November 2023, the Ecuadorian Tax Authority released a new edition of the technical sheet for the standardization of transfer pricing analysis, effective for fiscal year 2023. This updated document introduces significant changes to filing
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