OECD publishes transfer pricing profiles for eight countries
The OECD has published the revised transfer pricing country profiles, including profiles for Bosnia and Herzegovina, Brazil, Costa Rica, Croatia, Greece, Iceland, Korea (Rep.), and Norway on 22 January 2026. These profiles focus on countries'
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UK: HMRC updates guidance on transfer pricing, PE rules, diverted profits tax
The UK tax authority, His Majesty's Revenue and Customs (HMRC) has updated its International Manual, providing revised guidance on key taxation areas affecting multinational companies. The updates, published on 16 January 2026, include the
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Singapore: IRAS updates transfer pricing guidance, raises indicative margin for related party loans
The Inland Revenue Authority of Singapore (IRAS) has updated its Transfer Pricing guidance for 2026 on 2 January 2026, including the indicative margin for related party loans. For the year 2026, the indicative margin applicable to Risk-Free Rates
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Poland: MoF updates 2024 transfer pricing guide on foreign currency conversion
Poland’s Ministry of Finance (MoF) published updated FAQs in the sixth edition of the TPR Guide – Questions and Answers on 31 October 2025, providing clarification on 2024 transfer pricing reporting obligations. The updates address revised
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Australia: ATO consults transfer pricing considerations for inbound distribution models
The Australian Taxation Office (ATO) has initiated a consultation on a draft update to Practical Compliance Guideline PCG 2019/1, concerning transfer pricing considerations for inbound distribution arrangements. This includes updated profit
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Argentina: ARCA consults draft transfer pricing regulation
Argentina’s tax and customs agency (ARCA) has initiated a public consultation on a draft regulation to replace General Resolution No. 4717/2020 on transfer pricing and international transactions on 9 December 2025. This resolution, which
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UK: HMRC outlines reforms to transfer pricing, PE rules, DPT for 2026
The UK’s HM Revenue & Customs (HMRC) on 26 November published a policy paper outlining extensive reforms to the UK’s transfer pricing framework, permanent establishment (PE) rules and the Diverted Profits Tax (DPT). The update follows a
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UK retains SME transfer pricing exemption, plans new multinational reporting regime
The UK government will maintain its current transfer pricing exemption for small and medium-sized enterprises (SMEs), while moving ahead with plans to introduce a new International Controlled Transactions Schedule (ICTS) for multinational
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Singapore: IRAS revises transfer pricing rules, launches pilot SSA for baseline routine marketing and distribution activities
The Inland Revenue Authority of Singapore (IRAS) updated its transfer pricing guidance on 19 November 2025, introducing a new section outlining the simplified and streamlined approach (SSA) for pricing qualifying baseline marketing and distribution
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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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Kazakhstan 2026 tax code: A full reset of the country’s approach to corporate taxation
Kazakhstan’s new Tax Code, coming into force on 1 January 2026, is more than a technical rewrite. It’s a full reset of the country’s approach to corporate taxation, profit allocation, and cross-border oversight. Behind the headlines of
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Netherlands: MoF consults on tax measures for cross-border transactions
The consultation ends on 1 December 2025. The Netherlands Ministry of Finance initiated a public consultation on 20 October 2025 on a draft legislation outlining tax-related accompanying measures for cross-border transactions. The proposed
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Bulgaria consults proposed transfer pricing reforms, positions to match OECD standards
The consultation is set to conclude on 23 October 2025. Bulgaria has initiated a public consultation on its proposed draft regulations to update its transfer pricing regulations as part of its efforts to join the Organisation for Economic
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OECD: Finland, Liechtenstein, and Norway join GIR MCAA
In total, 20 countries have signed the agreement as of 30 September 2025. According to an OECD update on 30 September 2025, Finland, Liechtenstein, and Norway have signed the Multilateral Competent Authority Agreement on the Exchange of GloBE
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South Africa: SARS consults draft rules for CARF implementation, CRS amendments
The consultation concludes on 3 October 2025. South Africa’s National Treasury and the South African Revenue Service (SARS) introduced draft regulations on 15 September 12025, aimed at enhancing the country's approach to cryptoasset oversight
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South Africa: SARS consults customs rules for transfer pricing adjustments
The consultation is set to conclude on 3 October 2025. The South African Revenue Service (SARS) has initiated a public consultation regarding draft changes to the rules under sections 40, 41, and 120 of the 1964 Customs and Excise Act, relating
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OECD releases updated signatory list for GIR MCAA
Switzerland is the latest signatory to join the GIR MCAA. The OECD has released the list of 16 countries that have signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) as of 19 September
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OECD extends comment period on copper pricing toolkit
The deadline for submitting comments has been extended to 17 September 2025. The OECD announced an extension for public comments on its draft toolkit in August 2025, designed to help developing countries address transfer pricing challenges in
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