UK: HMRC updates transfer pricing guidance
The UK’s HM Revenue and Customs (HMRC) revised its Transfer Pricing Operational Guidance (INTM480000) on 10 November 2025. The update revises the section Searching for comparables: range of results (INTM485120), which sets out HMRC’s approach to
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Bulgaria: MoF updates transfer pricing rules
Bulgaria’s Ministry of Finance (MoF) issued Ordinance H-3 of 7 November 2025, updating the country’s transfer pricing framework to align with the latest OECD Transfer Pricing Guidelines. The ordinance was published in the State Gazette on 11
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OECD releases updated GIR MCAA signatories list
The Organisation for Economic Cooperation and Development (OECD) published an updated list of signatories, including their signing dates, to the Multilateral Competent Authority Agreement on the Exchange of Global Anti-Base Erosion (GloBE)
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Portugal: Parliament approves corporate tax cuts from 2028
Portugal’s parliament has gazetted Law No. 64/2025 on 7 November 2025, reducing corporate income tax rates. Under the new law, the standard corporate income tax (CIT) rate will decrease to 17% for tax periods commencing on or after 1 January
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Hungary gazettes laws on ratification of CARF MCAA
Hungary’s President has signed the Law No. LXXIII of 2025 on the Multilateral Competent Authority Agreement on Automatic Exchange of Information Pursuant to Crypto-Asset Reporting Framework (CARF MCAA), and its list of participating jurisdictions,
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Hungary gazettes laws on ratification of DPI MCAA
Hungary’s President has signed the Law No. LXXIII of 2025 on the Multilateral Competent Authority Agreement on Automatic Exchange of Information on Income Derived Through Digital Platforms (DPI MCAA) approving the DPI MCAA and its list of
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Hungary joins GIR MCAA
Hungary has joined the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA), under Pillar 2 of the OECD/G20 Inclusive Framework's two-pillar solution, as of 31 October 2025. The Global Anti-Base Erosion
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Chile joins crypto-asset reporting framework (CARF-MCAA)
Chile joined the Multilateral Competent Authority Agreement on Automatic Exchange of Information Pursuant to the Crypto-Asset Reporting Framework (CARF MCAA) on 21 October 2025. This framework standardises the reporting of crypto-asset
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Australia: ATO consults draft Public CBC reporting instructions
The Australian Taxation Office announced yesterday, 5 November 2025, that consultations are open on the draft instructions for completing the Public country-by-country (CBC) report. Under the Public CBC reporting rules, certain public and
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Costa Rica: DGT updates transfer pricing return dates for 2024, 2025
Costa Rica’s tax administration (DGT) has published Resolution MH-DGT-RES-TEMPORAL-0001-2025 in the Official Gazette on 31 October 2025 clarifying deadlines for submitting the transfer pricing information returns for fiscal years 2024 and
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Kenya: KRA consults on draft income tax regulations for advance pricing agreement, minimum top-up tax for 2025
The Kenya Revenue Authority (KRA) released two draft regulations for public consultation, covering its global minimum tax regime and advance pricing agreement procedures for 2025, on 3 November 2025. In compliance with the Statutory Instruments
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Australia: ATO publishes draft guidance for public CbC reporting
The Australian Taxation Office (ATO) has published a draft guidance on how to complete the public Country-by-Country (CbC) report on 31 October 2025. The public CbC reporting rules apply for reporting periods starting on or after 1 July 2024, and
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Brazil mandates disclosure of ultimate beneficial owners of investment funds, companies
Brazil’s Federal Revenue Service published an update to the rule on 31 October 2025, which deals with the identification of the ultimate beneficiaries of investment funds, companies, and legal arrangements operating in the country. This measure
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OECD reports increase in MAP and APA caseloads in 2024 data published on Tax Certainty Day 2025
The OECD has released new tax dispute statistics, highlighting generally positive results despite ongoing challenges on 31 October 2025. Tax certainty: OECD releases new statistics on tax disputes, showing positive outcomes but with challenges
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Argentina tightens reporting rules on cross-border transaction
RF Report Argentina published Decree 767/2025 in the Official Gazette on 28 October 2025, introducing significant updates to its cross-border transaction reporting rules, effective for fiscal years ending on or after 29 October 2025. The
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Australia: ATO updates APA guidance
The Australian Taxation Office (ATO) updated Law Administration Practice Statement PS LA 2015/4 to reflect enhancements to its advance pricing arrangement (APA) programme. The changes incorporate recommendations from the ATO’s 2023 APA Programme
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Slovak Republic updates transfer pricing documentation guidelines
Regfollower Desk The Slovak Republic’s Ministry of Finance has released updated guidelines on transfer pricing documentation (MF/012879/2025-724) and introduced a new 2025 corporate income tax return form, which includes a redesigned “Table I
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Australia: Federal Court pauses Oracle royalty tax case to permit treaty arbitration with Ireland
The Full Federal Court of Australia ruled in favour of Oracle, allowing its Mutual Agreement Procedure with Ireland to proceed by staying domestic tax proceedings, reaffirming taxpayers’ treaty rights to prevent double taxation over intra-group
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