Romania issues draft order to replace 2016 transfer pricing rules with OECD-aligned framework
Romania’s National Agency for Fiscal Administration has issued a draft order of the President regarding the thresholds of transactions, deadlines for preparation, content and conditions for requesting the transfer pricing file, and the procedure
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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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Singapore: IRAS issues new guidance on tax treatment of related party payments
The Inland Revenue Authority of Singapore (IRAS) has updated its guidance on Business Expenses, introducing new clarification on the tax treatment of payments for related party services. The update confirms that such payments may be deducted for tax
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Romania's National Agency of Fiscal Administration (ANAF) has unveiled a draft Order to replace the longstanding procedure governing advance pricing agreements (APAs), which has operated under Order No. 3735/2015 for over a decade. The proposed
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Australia: ATO updates public CbC reporting guidance
The Australian Taxation Office (ATO) issued new guidance on public country-by-country (CbC) reporting on 9 June 2026. Australia's public CbC reporting rules apply to reporting periods commencing on or after 1 July 2024, with reports required to be
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Kuwait approves accession to BEPS multilateral convention
Kuwait has published Decree-Law No. 62 of 2026 in the Official Gazette on 7 June 2026, approving the country's accession to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
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Bahrain publishes transfer pricing guidance for MNEs
Bahrain's National Bureau for Revenue (NBR) has published the DMTT Transfer Pricing Guide, providing guidance on the application of transfer pricing requirements under Decree-Law No. 11 of 2024, which introduced a global minimum tax through a
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Singapore updates transfer pricing guidance on share-based compensation under TNMM
The Inland Revenue Authority of Singapore (IRAS) has updated its Transfer Pricing Guidelines (Ninth Edition), released on 4 June 2026, to clarify the treatment of share-based compensation costs under the Transactional Net Margin Method
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Bolivia updates list of low-tax jurisdictions for transfer pricing, tax control purposes
Bolivia’s National Tax Service has published Resolución Normativa de Directorio (RND) Nº 102600000016 on 27 May 2026, updating its list of jurisdictions considered to have low or zero taxation for tax control and transfer pricing
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Japan: National Tax Agency updates CbC exchange jurisdictions list
Japan’s National Tax Agency has published an updated list of jurisdictions for the exchange of Country-by-Country (CbC) reports. Country-by-Country (CbC) reports are a standardised tax reporting framework requiring large multinational
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Bolivia: SIN further extends 2025 filing deadline for financial statements, transfer pricing documentation
Bolivia’s National Tax Service (SIN) has issued Resolution No. 102600000017 of 27 May 2026 to further extend the deadline for the digital submission of financial statements, the annual report, the transfer pricing study, and the related-party
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Canada: CRA releases updated 2025 corporate income tax guide
The Canadian Revenue Agency (CRA) has issued an updated corporate income tax guide for tax year 2025 on 28 May 2026. The guide covers the following: Accelerated capital cost allowance (CCA) for liquefied natural gas (LNG) facilities The
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Malawi enacts 2026–27 budget, introduces VAT on digital services by foreign companies
Malawi has enacted the legislation implementing the 2026–2027 Budget, which was published in the Official Gazette on 14 April 2026 and entered into force on 15 April 2026. This follows after Malawi’s Minister of Finance, Economic Planning and
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Sweden: Court rules in favour of Kubal, overturns transfer pricing-based adjustment
Sweden’s Supreme Administrative Court has ruled in favour of Kubikenborg Aluminium AB (Kubal), overturning a transfer pricing-based adjustment made by the Swedish Tax Agency in a dispute concerning the deductibility of damages arising from an
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Kenya refines country-by-country reporting rules in Finance Bill 2026
Kenya’s Finance Bill, 2026, introduces significant updates to Country-by-Country (CbC) reporting through amendments to the Income Tax Act. These changes focus on refining definitions and aligning statutory references to ensure clarity and
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Rwanda establishes formal APA framework under new transfer pricing rules
Rwanda has introduced new transfer pricing rules establishing a clearer tax framework for controlled transactions, replacing the 2020 rules, which ceased to apply in October 2023 under the amended Income Tax Law No. 027/2022. The updated transfer
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Moldova: STS introduces electronic transfer pricing information form ahead of June deadline
Moldova’s State Tax Service (STS) has announced the rollout of an electronic transfer pricing information form within the Electronic Declaration system, accessible through taxpayers' Personal Cabinets on 12 May 2026. This new platform will handle
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