Latvia introduces controlled transactions report to streamline transfer pricing compliance
Latvia has significantly reshaped its transfer pricing compliance framework from 1 January 2026, following amendments to the Law “On Taxes and Fees” adopted at the end of 2025. The changes are designed to modernise reporting requirements, reduce
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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
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Argentina: ARCA raises transfer pricing reporting thresholds
Argentina’s Federal Tax Administration (ARCA) has increased the revenue thresholds that trigger mandatory transfer pricing documentation, aiming to streamline reporting requirements for multinational and local taxpayers. The changes are set out
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Egypt: MoF increases transfer pricing documentation threshold
Egypt’s Ministry of Finance (MoF) has issued Minister of Finance Decision No. 534 of 2025 of 17 December 2025, revising the rules for transfer pricing (TP) documentation. Under the decision, the annual related-party transaction threshold for TP
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France strengthens transfer pricing rules under 2024 Finance Act
France has introduced new measures to reinforce the administration’s ability to detect and penalise abusive transfer pricing practices, following the publication of updates linked to Article 116 of Finance Act No. 2023-1322 of 29 December 2023 for
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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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Albania implements country-by-country reporting legislation
Albania enacted regulations on 11 August 2024, concerning country-by-country (CbC) reporting, outlining specific rules and procedures that ultimate parent entities and constituent entities of a multinational enterprise (MNE) group must follow
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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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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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France introduces strict measures to combat international tax fraud
On 5 May 2023, French Minister for public accounts unveils anti-fraud measures targeting international tax and customs activities. Key elements of these measures include lowering the annual turnover threshold that triggers the requirement for
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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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Hungary: MoF publishes decree amending TP rules on transfer pricing documentation
On 28 December 2022, the Hungarian Ministry of Finance published Decree 27/2022 (XII.28) which amends the Decree 32/2017 (X.18) on the documentation requirement related to the determination of arm’s length prices. Increase threshold
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South Korea approves budget for 2023
On 23 December 2022, South Korea’s National Assembly approved the budget for 2023 including the tax reform proposal for 2023. Accordingly, South Korea changes the existing tax-related measures including transfer pricing measures. The key tax
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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
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 MorePortugal publishes new transfer pricing Legislation
On 26 November 2021, the Portuguese Tax Administration (PTA) published Order No. 268/2021, which replaces Regulation No. 1446-C / 2001 of December 21, 2001. The new regulation revises the rules for implementing the arm's length principle under
See MoreRomania revises number of large taxpayers required to prepare TP documentation
On 29 October 2021, the Romanian National Tax Agency (NTA) published Order No. 1721 that revises the list of large taxpayers those are subject to prepare transfer pricing (TP) documentation. There are currently 2,940 large taxpayers until 31
See MoreColombia issues Draft Resolution to set UVT for 2022
On 8 November 2021, the Colombian National Tax Authority (Dirección de Impuestos y Aduanas Nacionales-DIAN) has issued a Draft Resolution to set out the tax unit value (Unidad de Valor Tributario – UVT) applicable for the year 2022. The UVT is
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