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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Egypt raises materiality threshold for master file and local file for 2024
On 15 February 2024, Egypt published the Ministerial Decree No. 52 of 2024 in the Official Gazette, providing updated transfer pricing documentation requirements for Egyptian taxpayers. This decree came into effect on 22 February 2024. In this
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Egypt preparing draft for new income tax law
Egypt’s Minister of Finance for Tax Policy and Reforms has announced plans to draft a new iteration of the Income Tax Law. The details of the new law has been fully published, but the main proposals of the new law include: A focus on
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Cyprus revises thresholds for transfer pricing documentation
On 1 February 2024, the Cyprus Tax Department released updated thresholds regarding the requirement for taxpayers to prepare a Cyprus Local File for intercompany transactions covered by Section 33 of the Income Tax Law (ITL). These revised
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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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UAE: MoF issues decision on TP documentation requirements
On 11 May 2023, the United Arab Emirates (UAE) Ministry of Finance (MoF) issued Ministerial Decision No. 97 of 2023 on the requirements for maintaining transfer pricing (TP) documentation. Federal Decree Law No (47) of 2023 on the Taxation of
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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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Poland: President signs the Polish Deal 3.0 including transfer pricing changes
On 21 October 2022, the President of Poland signed the Law of 7 October 2022 amending the Corporate Income Tax Act (referred to as Polish Deal 3.0), including certain transfer pricing changes. One of the most significant changes to transfer pricing
See MoreSaudi Arabia issues draft Transfer Pricing Bylaws for public consultation
On 4 July 2022, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued a draft of Transfer Pricing (TP) Bylaws and invited public consultation. The public consultation period is open until 30 July 2022. The final Transfer Pricing Bylaws
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Cyprus: 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 MoreDominican Republic: DGII publishes thresholds for TP documentation and some tax issues
The Directorate General of Internal Revenue (DGII) has published Resolution No. DDG- AR1-2021-00001, which provides the general multiplier for inflation adjustments for the fiscal year ending 31 December 2021, including new transfer pricing
See MoreThailand: New documentation requirement introduces Local file
On 30 September 2021, the Director-General of the Thai Revenue Department issued guidance Notification No. 407 regarding transfer pricing (TP) documentation requirements for the information and documentation for the Local file and exemption from
See MoreQatar introduces new TP documentation requirements
On 16 July 2020, the General Tax Authority (GTA) of Qatar has issued Decision No. 4 of 2020 and made public on 1 March 2021, which confirms the obligation to submit the transfer pricing (TP) disclosure form, master file, and local file applies to
See MoreBelgium plans to launch further TP audit cycle
On 11 January 2021, a number of selected Belgian taxpayers received a transfer pricing (TP) questionnaires from the tax authority’s special TP audit department. Based on noncompliant TP forms again audit cycles will be launched by the special TP
See MoreSri Lanka: TP documentation requirement for domestic controlled transactions
According to the notice of 25 November 2020, under the Regulation 1 of the TP Gazette, transfer pricing regulations inter alia, are applicable to the local transactions made between associated enterprises (AE) as referred to in section 77 of the
See MoreEgypt: President approves unified tax procedures law
On 19 October 2020, Egyptian President Abdel Fattah El Sisi has approved a unified tax procedures law (Law no. 206 of 2020). The Law was published in the Official Gazette. The law will be applied to tax on income, added value tax, stamp duty, fees
See MoreChile: SII publishes new transfer pricing reporting obligations
On 31 August 2020, the Internal Revenue Service (SII) published a Resolution No. 101, which establishes the obligations for companies to submit master file (Form 1950) and local file (Form 1951) respectively. The Resolution includes both Forms. The
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