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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Ecuador rejects OECD Pillar One Amount B safe harbour in new SRI circular
Ecuador’s Internal Revenue Service (SRI) has clarified that the OECD’s Pillar One – Amount B framework has not been adopted in the country, reaffirming that taxpayers must continue to apply existing domestic transfer pricing rules to routine
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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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Belgium issues guidance on Pillar One Amount B
The Belgian Ministry of Finance has released Circular 2026/C/45 on 19 March 2026, introducing an addendum to the transfer pricing guidance set out in Circular 2020/C/35. The Circular clarifies how multinational enterprises should apply
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Germany updates jurisdiction list for the exchange of CbC reports
Germany has issued the Eighth Regulation Amending the Country-by-Country (CbC) Report Extension Regulation, which was published in the Official Gazette on 30 March 2026. The regulation updates the list of jurisdictions with which Germany will
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US: IRS reports decline in advance pricing agreement executions amid staffing challenges
The US Internal Revenue Service (IRS) released Announcement 2026-08 on 30 March 2026, revealing a decline in advance pricing agreements executed during 2025. The annual report from the Advance Pricing and Mutual Agreement (APMA) Program shows
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Russia: MoF updates guidance on mutual agreement procedure requests
The Russian Ministry of Finance (MoF) published updated guidance on requesting assistance under the Mutual Agreement Procedure (MAP), setting out detailed rules for taxpayers seeking relief from double taxation under applicable double taxation
See MoreIndia: CBDT rolls out 2026 income tax rules with expanded transfer pricing framework
India’s Central Board of Direct Taxes (CBDT) issued Notification No. 22/2026 on 20 March 2026 under the Income Tax Act, 2025, introducing the Income Tax Rules, 2026. The rules provide a comprehensive framework for income tax administration,
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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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UN Tax Committee Discusses the Digitalised and Globalised Economy
On 23 March 2026 the UN Committee of Experts on International Cooperation in Tax Matters discussed the workstreams on the taxation of the digitalised and globalised economy. The relevant subcommittee presented its planned workstreams for comment and
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UK: HMRC updates CbC reporting guidance
UK’s His Majesty's Revenue and Customs (HMRC) updated its country-by-country reporting (CbCR) guidance on 17 March 2026, clarifying which entities must report, how to register and submit reports, and the process for agents seeking
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Vietnam: MoF drafting new transfer pricing, taxpayer obligations, CbC reporting rules
The Vietnamese Ministry of Finance (MoF) is preparing a draft Decree on tax administration for related-party transactions of enterprises with affiliated relationships, in line with the Law on Tax Administration No. 108/2025/QH15. The new
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UN Tax Committee Discusses Extractive Industries Taxation
The 32nd session of the UN Committee of Experts on International Cooperation in Tax Matters commenced on 23 March 2026. The Committee discussed the continuing work on aspects of taxation in the extractive industries. The relevant subcommittee
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