Hungary 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
See More
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
See More
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
See More
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
See More
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
See More
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
See More
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
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
See More
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 MoreSri Lanka amends transfer pricing regulations
Sri Lanka has published amended Transfer Pricing (TP) Regulations that update the existing regulations of 2018. The amended regulations were published in the Official Gazette on 2 March 2021 and apply retroactively from 1 April 2020. The
See MoreArgentina: AFIP extends the deadline of TP filing reports
On 18 June 2021, the Federal Administration of Public Revenues (AFIP) Officially published General Resolution 5010/2021, which extends the deadline for filing transfer pricing reports and related forms F. 2668 and F. 2672 for tax years ended
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 MoreGermany: Ministry of Finance publishes new transfer pricing guidance
On 3 December 2020, the Federal Ministry of Finance (BMF) has published the Administrative Principles 2020, which contain updated guidelines on audits / reviews of transfer prices between related parties and the responsibility of taxpayers to
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 MoreTurkey publishes transfer pricing General Communiqué No. 4
On 1 September 2020, the Turkish Revenue Administration has published transfer pricing General Communiqué No. 4 on disguised profit distribution in the Official Gazette No. 31231. The Communiqué explains information regarding new transfer pricing
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
See More