UK: HMRC consults transfer pricing framework, permanent establishment rules, diverted profits tax
The UK’s tax authority, His Majesty’s Revenue and Customs (HMRC) has launched consultations seeking public input on potential updates to the UK’s transfer pricing framework, permanent establishment rules and the diverted profits tax on 28
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OECD consults Ukraine’s transfer pricing rules
The OECD is working with Ukraine's Ministry of Finance to align Ukraine's Transfer Pricing Framework with OECD Transfer Pricing Guidelines, as part of the implementation of Ukraine's National Revenue Strategy. Project description To ensure
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Cape Verde joins OECD agreement on exchange of CbC reports
Cape Verde has signed the OECD Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) on 9 April 2025. Under BEPS Action 13, all large multinational enterprises (MNEs) are required to prepare a
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Poland gazettes consolidated transfer pricing rules for corporate tax
Poland published the updated consolidated text of the transfer pricing regulations related to corporate income tax in the Official Gazette on 8 April 2025, reflecting the provisions which have been in effect from 21 March 2025. The provisions of the
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Norway will not implement Amount B but will accept it from other jurisdictions
The Norwegian Tax Administration published a release on 31 March 2025 outlining the implementation of Amount B, which aims to simplify transfer pricing rules under Pillar One. Norway’s Ministry of Finance has decided that amount B shall not be
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UK consults advance tax clearance service for large innovative investment projects, transfer pricing treatment of CCAs
The Chancellor of the Exchequer announced that the government launched a consultation on a proposed new service aimed at providing advance statutory certainty on the application of UK corporation tax rules for businesses undertaking the "very
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India enacts Finance Act 2025, offers support for targeted sectors of the economy
India's Central Board of Direct Taxes (CBDT) has released the Finance Act 2025 on 29 March 2025. The Act was officially enacted on 29 March 2025, following the President's assent, implementing the provisions outlined in the 2025–2026
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Russia mandates transfer pricing method in controlled transaction notifications
Russia's Federal Tax Service (FTS) issued Letter No. ШЮ-4-13/2827@ on 13 March 2025 about the notification of controlled transactions. It clarifies that from 2024, taxpayers must disclose the transfer pricing method used to justify the market
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Israel seeks input on local R&D centres and IP valuations
Israel’s tax authority (ITA) released a draft Tax Circular on 27 February 2025 for public comment. The circular outlines criteria and requirements for local R&D centres and post-acquisition IP sales, offering potential certainty from the
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Poland proposes changes to DAC6 disclosure rules
Poland’s Ministry of Finance has proposed amendments to the mandatory disclosure rules (MDR) for potentially aggressive tax arrangements on 17 February 2025. The draft law aims to improve relations between taxpayers and tax authorities and
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Vietnam updates regulations on related-party transactions, transfer pricing
The Vietnam government has issued Decree No. 20/2025/ND-CP amending Decree No. 132/2020/ND-CP on transfer pricing on 10 February 2025, addressing the treatment of lenders or guarantors as related parties. A borrowing or guaranteed enterprise is
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Brazil extends commodity transaction registration deadline
Brazil has extended the deadline for commodity transaction registration deadline, issued in Normative Instruction No. 2.249 of 6 February 2025 which outlines amendments to Normative Instruction RFB No. 2.161 of 28 September 2023 regarding transfer
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Israel clarifies CbC reporting rules for MNEs
The Israel Tax Authority (ITA) issued Income Tax Circular No. 1/2025 on 11 February 2025, which clarifies amendments to the Income Tax Ordinance. The amendments pertain to transfer pricing and country-by-country (CbC) reporting requirements. The
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Costa Rica issues draft resolution on annual transfer pricing reporting obligation
Costa Rica's Directorate-General of Taxation has published a notice in the Official Gazette announcing a public consultation on a draft resolution on 13 February 2025. The resolution pertains to submitting the informative statement on transfer
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Algeria clarifies transfer pricing documentation and asset depreciation rules
Algeria’s Ministry of Finance has issued two key orders: the Order of 15 February 2024, outlining transfer pricing documentation requirements, and the Order of 25 February 2024, setting depreciation periods for fixed assets to calculate taxable
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Australia: ATO updates guidance on transfer pricing for inbound-related private group funding
The Australian Taxation Office (ATO) has released new guidance on transfer pricing for inbound related party funding within private groups that receive funding from an overseas related party or associate for property and construction on 15 January
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Cambodia issues transfer pricing rules from 2025
Cambodia's Ministry of Economy and Finance has announced Prakas 574 on 19 September 2024 introducing revised transfer pricing regulations, which went into force on 1 January 2025. The key changes include: Updated definition of "related
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Singapore: IRAS updates 2025 transfer pricing guidance, lowers indicative margin for related-party loans
The Inland Revenue Authority of Singapore (IRAS) released updated transfer pricing guidelines on 2 January 2025. The indicative margin for related-party loans has been revised to +170 basis points (1.70%) from +220 basis points (2.20%) for the
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