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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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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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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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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UK: HMRC consults transfer pricing framework, permanent establishment rules, diverted profits tax
The UK’s tax authority, His Majesty’s Revenue and Customs (HMRC) has launched consultations seeking public input on potential updates to the UK’s transfer pricing framework, permanent establishment rules and the diverted profits tax on 28
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Peru: Congress approves bill for MLI ratification
The Peruvian Congress approved the bill for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 13 March 2025. Following the internal ratification process,
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India extends transfer pricing safe harbor rules to FY 2024-25, updates filing deadline for international transactions
India's Central Board of Direct Taxes (CBDT) has released Notification No. 124/2024 outlining the Income Tax (Tenth Amendment) Rules, 2024 on 29 November 2024. According to the amendment, the transfer pricing safe harbor rules under Rule 10TD of
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Cyprus publishes FAQs on new transfer pricing rules
The tax authority has published additional frequently asked questions (FAQs) numbered 25 – 43 to provide clarity on specific provisions of the new transfer pricing rules in Cyprus. Notably, FAQ 25 clarifies that taxpayers do not need to
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Singapore updates tax guide for variable capital companies with new GST and deduction rules
The Inland Revenue Authority of Singapore (IRAS) published an e-tax guide (Second Edition) detailing the tax framework for variable capital companies (VCCs), a corporate structure designed for investment funds, on 31 May, 2024. The Second Edition
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Ireland updates guidance on relief from stamp duty and property transfers for associated companies
The Irish Revenue has released eBrief No. 142/24 on 21 May, 2024, which provides an updated guidance on the associated companies relief for stamp duty on conveyances and transfers of property between associated corporate bodies. Revenue eBrief
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Germany: Parliament approves law for growth, investment, and tax simplification
The Bundesrat, upper chamber of the German Parliament, gave its approval to the compromise proposal for the "Act aimed at Enhancing Growth Opportunities, Investment, and Innovation, while Simultaneously Simplifying Taxation and Ensuring Fairness" on
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Bolivia defers deadline for submitting and paying financial transaction tax
On 4 March 2024, Bolivia’s tax authority, the National Tax Service (Servicio de Impuestos Nacionales), released the RND N°102400000007. In this guidance, the tax authorities have extended the deadline for submitting affidavits and paying taxes
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Botswana: Finance Minister presents tax reforms and digitalization measures in budget speech 2024
On 5 February 2024, Mr. Peggy O. Serame, Botswana's Minister of Finance and Economic Development presented the 2024 Budget Speech to the National Assembly. The budget contains a number of important tax measures. The key proposed tax measures are as
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Russia: MoF issues guidance on expanded tax regimes for transfer pricing
The Russian Ministry of Finance (MoF) issued Guidance Letter No. 03-12-11/1/126454 on 27 December 2023, providing clarification on the application of Order No. 86n from 5 June 2023. This order expanded the list of states with preferential tax
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India: CBDT issues notification for non-resident investors in financial products by IFSC capital market intermediaries
On 4 January 2024, India's Central Board of Direct Taxes (CBDT) issued Notification No. 4/2024 as per the provisions of Section 10, Clause 4G, of the Income Tax Act, 1961. This notification specifically addresses entities who are not residents and
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Spain releases 2024 FTT list for companies
On 13 December 2023, the Spanish Tax Agency released the list of companies whose market capitalization value surpassed EUR 1 billion as of 1 December 2023. The list pertains to financial transaction tax (FTT). The financial transactions tax (FTT)
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Cyprus: Tax Department issues circular on back-to-back financing transactions
On 7 July 2023, the Cyprus Tax Authority released Circular 7/2023, focusing on transfer pricing for intra-group back-to-back financing transactions. The Circular specifies that starting from the tax year 2023, the Comparable Uncontrolled Price (CUP)
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