Brazil: President signs OECD-aligned transfer pricing rules
On 14 June 2023, the president Luiz Inácio Lula da Silva signed the Law No. 14,596 adopting Provisional Measure No. 1,152, which enacts significant changes to the Brazilian transfer pricing system that is aligned with the guidelines provided by the
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Finland: Tax agency issues guidance on application of OECD guidelines for domestic TP rules
On 8 February 2023, the Finnish tax administration issued guidance No.VH/5942/00.01.00/2022 on the application of OECD transfer pricing guidelines to domestic transfer pricing rules. The purpose of the guidance is also to summarize the effects of
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Ireland: President signs the Finance Bill 2022 into Law
On 15 December 2022, Michael D. Higgins, the President of Ireland signed the Finance Bill 2022 into Law. The Finance Act contains new tax measures including changes in corporate income tax and transfer pricing related measures. The main tax measures
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United Kingdom adopts OECD TP Guidelines 2022
On 9 November 2022, the UK Official Gazette published Statutory Instrument No. 2022/1147, on transfer pricing (TP) guidelines. The statutory instrument outlines the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax
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Ireland: Government publishes Finance Bill 2022
On 20 Oct 2022, Ireland’s Minister for Finance Paschal Donohoe published the Finance Bill 2022 as part of the Irish budget. The Finance Bill contains new tax measures that were not included in the budget presented in September 2022. The main tax
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Netherlands publishes new transfer pricing decree
On 1 July 2022, the Netherlands Ministry of Finance issued Decree No. 2022-0000139020 related to the application of the arm's length principle and the OECD transfer pricing guidelines. The New Decree replaces the previous transfer pricing (TP)
See MoreMalta seeks comments on draft Transfer Pricing Rules
On 22 December 2021, Malta’s Commissioner for Revenue (CFR) has published draft Transfer Pricing Rules on its website for public consultation. The consultation period will end on 28 February 2022, and the draft Transfer Pricing Rules shall come
See MoreFinland issues guidance on application of OECD guidelines for domestic TP rules
On 17 December 2021, the Finnish Tax Administration issued Guidance No. VH/5755/00.01.00/2021, on the application of OECD transfer pricing guidelines to domestic transfer pricing rules, effective from 31 December 2021. On 11 February 2020, the
See MoreIreland adopts OECD authorized approach for TP of branches
On 21 October 2021, Minister for Finance, Paschal Donohoe TD, published the draft Finance Bill 2021, which underpins the Government’s ongoing support for the economy, particularly in response to the impact of Covid-19. It will introduce the
See MoreAustralia updates transfer pricing legislation in accordance with OECD guidelines
Australia's transfer pricing legislation has been updated to specify that it is to be interpreted to achieve consistency with the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines for Multinational
See MoreGeorgia adopts updated OECD transfer pricing guidelines
On 2 December 2019, the Ministry of Finance issued Decree No. 366 amending the country's transfer pricing legislation. The new decree updates the reference to the 2010 OECD transfer pricing guideline, providing that the 2017 version should
See MoreIreland: Public consultation on new transfer pricing regime
On 18 February 2019, Department of Finance of Ireland released the public consultation document to update transfer pricing regime, with an effective date of 1 January 2020. The consultation looks for feedback on a number of aspects of existing
See MoreBelgium issues draft TP guidelines for public comments
The tax authority of Belgium has published a draft Circular on the 2017 update to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing (TP) Guidelines. On 9 November 2018, the draft Circular was published by the Belgian
See MoreSweden: Tax Agency updates Transfer Pricing Guidance on Profit Splits method
On 29 August 2018, the Swedish Tax Agency (Skatteverket) has updated its transfer pricing guidance to incorporate the OECD guidance on the application of the transactional profit split method, which was revised as part of the work for BEPS Action
See MoreNetherlands publishes new transfer pricing decree
The Dutch Ministry of Finance published a new transfer pricing decree nr. 2018-6865 on 22 April 2018, which was published in the State Gazette on 11 May 2018. The Decree is in line with the outcomes of the Base Erosion and Profit Shifting (BEPS)
See MoreZambia: MoF approves amendments in transfer pricing regulation
The Minister of Finance (MoF) is set to approve changes in transfer pricing rules, including procedures for the valuation of the transfer pricing transactions between related entities and allow for taxable income adjustments and documentation
See MoreOECD: 2017 edition of the transfer pricing guidelines issued
On 10 July 2017 the OECD issued the 2017 edition of the OECD transfer pricing guidelines. The amendments made in the latest edition of the guidelines mainly arise from the transfer pricing aspects of the conclusions and recommendations of the
See MoreIndia: Latest update on country-by-country reporting
India has recently included a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act, 1961, with effect from the financial year 2016-2017. The first round of CbC reports, if applicable, must be submitted to the
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