Russia reminds taxpayers of controlled transaction notification obligations
Russia’s Federal Tax Service (FTS) has reminded taxpayers that notifications of controlled transactions for 2025 must be submitted no later than 20 May 2026. Under paragraph 8 of Article 105.15 of the Tax Code of the Russian Federation,
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Rwanda implements new transfer pricing rules, business tax regulations, loss carryforward extensions
Rwanda has published Ministerial Order No. 003/26/10/TC of 29 April 2026 in the Official Gazette, introducing updated transfer pricing rules under Law No. 027/2022 of 20 October 2022, the country’s new income tax law, accounting for small
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South Africa consults implementation of bilateral advance pricing agreements under DTAs
The South African Revenue Service (SARS) has initiated a public consultation, on 30 April 2026, on the implementation of bilateral advance pricing agreements (APAs) under double taxation agreements (DTAs), as part of an initial pilot phase of the
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France expands list of CbC reporting partner jurisdictions
France has published a Ministerial Order on 24 April 2026, published in Official Journal No. 0099 of 26 April 2026, updating the list of jurisdictions that meet the conditions for exemption from local filing under its country-by-country (CbC)
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Serbia sets 2026 arm’s length interest rates for related party loans
Serbia's Ministry of Finance has introduced new interest rates for related party loans in 2026, with the rulebook set to take effect on 2 May 2026 following its publication in the Official Gazette on 24 April 2026. The regulations establish arm's
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Australia: ATO clarifies general purpose financial statement filing obligations
The Australian Taxation Office (ATO) has issued a notice on 28 April 2026 outlining which entities are required to lodge a general purpose financial statement. Lodging a general purpose financial statement (GPFS) is a crucial step for various
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Romania consults new mutual agreement procedure (MAP) rules
Romania’s National Agency for Fiscal Administration (ANAF) initiated a public consultation, on 21 April 2026, on a draft order establishing the procedure for conducting the mutual agreement procedure (MAP), following amendments introduced to the
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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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US: IRS revives controversial transfer pricing rule after decades of dormancy
The US Internal Revenue Service (IRS) is dusting off a 40-year-old tax provision that could dramatically reshape how multinational companies price transactions involving intellectual property, raising concerns among international tax practitioners
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Bolivia updates corporate tax and transfer pricing reporting rules, extends 2025 filing deadlines
Bolivia’s National Tax Service (SIN) has issued Resolution No. 102600000014 on 16 April 2026, marking a significant shift toward the full digitalisation of financial and tax data. These updates specifically refine how businesses handle their
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Algeria extends CIT, PIT, transfer pricing filing deadlines for 2025 fiscal year
Algeria's tax authority, the General Directorate of Taxes (DGI) has granted taxpayers additional time to file their annual income tax returns for the 2025 fiscal year, according to an announcement on 16 April 2026. The filing deadline for annual
See MoreAustralia: ATO revises transfer pricing compliance for inbound distribution arrangements
The Australian Tax Office (ATO) has published updates to Practical Compliance Guideline PCG 2019/1 on transfer pricing issues related to inbound distribution arrangements to ensure profit markers remain relevant and aligned to more recent market
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Luxembourg implements Pillar One ‘Amount B’ simplified transfer pricing rules
The Luxembourg tax administration issued Circular L.I.R. n° 56/2 – 56bis/2 on 13 April 2026, introducing a simplified and rationalised approach for applying the arm’s length principle to baseline marketing and distribution activities, referred
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France clarifies MAP access rules, APA roll-back conditions in transfer pricing guidance
The French tax authority issued updated guidance on Mutual Agreement Procedures (MAP) and Advance Pricing Agreements (APA) on 15 April 2026, following a public consultation launched on 15 January 2025. The revisions provide clarification on MAP
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New Zealand tightens stance in updated TP guidance, introduces thin capitalisation infrastructure exemption
New Zealand’s Inland Revenue (IR) has issued updated guidance on Transfer Pricing Documentation and Thin Capitalisation Rules on 31 March 2026, replacing earlier versions from 2025 and 2021. The transfer pricing (TP) documentation guidance
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UAE: FTA issues revised rulings framework covering APAs, tax transaction directives
The UAE Federal Tax Authority (FTA) has issued an updated Policy on Issuing Clarifications and Directives, amended by Decision No. 2 of 23 February 2026 and effective from 1 March 2026. A key update is the introduction of Directives on Tax
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Brazil: New transfer pricing framework brings strategic shift for multinationals
Brazil has fundamentally restructured its transfer pricing system through Law No. 14,596/2023 and RFB Normative Instruction No. 2,161/2023, marking a decisive shift toward OECD standards. The arm's length principle takes centre stage The
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India: CBDT signs record 219 APAs in FY 2025-26
India’s Central Board of Direct Taxes (CBDT), under the Ministry of Finance’s Department of Revenue has announced the signing of a record 219 Advance Pricing Agreements (APAs) with Indian taxpayers in FY 2025-26. This total includes both
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