Australia: ATO updates GILTI guidance following US tax regime changes
The Australian Taxation Office (ATO) has issued an Addendum to Taxation Determination TD 2022/9 by the Commissioner of Taxation on 23 September 2026 to account for amendments to the US global intangible low-taxed income (GILTI) regime introduced
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Netherlands updates interest deduction limitation rules
The Netherlands published Policy Decision No. 2026-17016 of 10 September 2026 from the State Secretary of Finance on 22 September 2026, updating and replacing the 2025 decision on the interest deduction limitation, or earnings stripping,
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Ukraine proposes broad transfer pricing reforms
The Ukrainian Parliament is reviewing the draft Law on amendments to the tax code of Ukraine regarding further improvement of Transfer Pricing (TP) rules, which was submitted on 4 September 2026. If adopted, the lew would enter into force on 1
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Iceland: MoF consults tax law changes on interest deductions, charities, rulings and nicotine products
Iceland’s Ministry of Finance and Economic Affairs (MoF) has initiated a public consultation on several proposed legislative amendments in its draft document on 4 September 2026, with a targeted entry into force on 1 January 2027. These planned
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Malaysia issues transfer pricing guidelines for intra-group loans
Malaysia's Inland Revenue Board (IRBM) has published the Malaysia Transfer Pricing Guidelines for Intra-Group Loans (MFTIL), providing a comprehensive framework for determining whether financing transactions between associated persons comply with
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Netherlands consults bill targeting compliance simplifications, adjustment of reorganisation facilities, hybrid entity changes
The Dutch government has put forward a comprehensive legislative package designed to refine the Income Tax Act 2001, the Corporate Income Tax Act 1969, the Successions Act 1956, and other tax frameworks. Following this, the government has opened a
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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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UK: HMRC consults draft International Controlled Transactions Schedule (ICTS)
The UK’s His Majesty's Revenue and Customs (HMRC) has launched a technical consultation regarding cross-border related party transactions on 16 June 2026, inviting views on the details of a draft International Controlled Transactions Schedule
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Taiwan: MOF clarifies reasonable interest on inter-company lending arrangements
Taiwan's Ministry of Finance (MoF) has released a notice on 1 June 2026, reminding taxpayers of the requirements governing reasonable interest on inter-company lending arrangements. To protect the rights and interests of company shareholders and
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Italy: Supreme Court exempts certain gratuitous intragroup guarantees from transfer pricing rules
Italy’s Supreme Court has clarified the circumstances in which domestic transfer pricing rules apply to intragroup transactions, confirming that transactions conducted without consideration may remain outside the scope of transfer pricing where
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Montenegro proposes draft corporate tax rules in accordance to EU ATAD
The Government of Montenegro has released a draft law on Amendments to the Law on Corporate Income Tax, proposing measures to address profit shifting in accordance with the EU Anti-Tax Avoidance Directive (ATAD) (Directive 2016/1164 as amended by
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Canada: 2025 Budget Implementation Act overhauls transfer pricing rules, scraps digital services tax
Canada’s Bill C-15, or the Budget 2025 Implementation Act, No. 1, which received Royal Assent on 26 March 2026, introduces a major overhaul of Canada's transfer pricing regime, repeals the Digital Services Tax, and enacts a wide array of business
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UN Tax Committee Discusses Transfer Pricing
On 24 March 2026 the UN Committee of Experts on International Cooperation in Tax Matters discussed the workstreams for transfer pricing during the current mandate of the Committee. The subcommittee on transfer pricing presented its planned
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Korea (Rep.) introduces transfer pricing reforms, Pillar Two rollout
Korea (Rep.) has published Presidential Decree No. 36128, partially amending the enforcement Decree of the International Tax Adjustment Act, in the Official Gazette on 27 February 2026. The Decree introduces sweeping updates to its international tax
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Ukraine: MoF consults transfer pricing reform bill
Ukraine’s Ministry of Finance (MoF) opened a public consultation on a draft law titled “On Amendments to the Tax Code of Ukraine Regarding Further Improvement of Transfer Pricing Rules” on 24 February 2026. The draft was prepared with the
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Singapore: IRAS revises e-tax guide on hybrid instrument taxation
The Inland Revenue Authority of Singapore (IRAS) has released the third edition of its e-Tax Guide on the Income Tax Treatment of Hybrid Instruments on 26 December 2025. The guide outlines how hybrid instruments are classified as debt or equity
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Poland: MoF updates 2024 transfer pricing guide on foreign currency conversion
Poland’s Ministry of Finance (MoF) published updated FAQs in the sixth edition of the TPR Guide – Questions and Answers on 31 October 2025, providing clarification on 2024 transfer pricing reporting obligations. The updates address revised
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Ireland: Irish Revenue updates guidance on anti-hybrid rules for partnerships
The Irish Revenue has issued eBrief No. 223/25, on 27 November 2025, on the country’s anti-hybrid rules, reflecting changes to the application of the associated enterprises test for partnerships. Tax and Duty Manual Part 35C-00-01 has been
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