Chile: SII, mining authority push advance pricing agreements to lock in transfer prices
Chile's tax authority (SII) announced on 20 July 2026 that SII and Chile’s Copper Commission (Cochilco) hosted a conference on 13 July 2026, aimed at encouraging major mining companies to enter into advance pricing agreements—formal contracts
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Argentina: ARCA simplifies goods export registration for transfer pricing
Argentina’s tax authority (ARCA) has published General Resolution 5872/2026 in the Official Gazette of 3 July 2026, which consolidates and updates the mandatory registration process for export contracts involving goods with transparent market
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Lithuania consults transfer pricing documentation, arm’s length range draft guides
The Lithuanian State Tax Inspectorate (STI) has opened a public consultation on 13 July 2026 on draft guides for transfer pricing documentation and establishing the arm's length range. The Q&A-style guides reflect the most common compliance
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Romania gazettes modernised advance pricing agreement, transfer pricing documentation rules
Romania has published Order No. 827/2026 and Order No. 828/2026 in the Official Gazette on 30 June 2026. Order No. 827 revises the procedures and application requirements for issuing and modifying advance pricing agreements (APAs), while Order No.
See MoreRomania: ANAF approves updated transfer pricing rules to prevent tax disputes, align with OECD standards
Romania's Ministry of Finance and the National Agency for Fiscal Administration (ANAF) announced, on 30 June 2026, that they have introduced revised transfer pricing regulations designed to bring greater clarity and consistency to how multinational
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Chile: SII launches benchmark tool to assess transfer pricing risk
Chile’s Internal Revenue Service (SII) announced, on 23 June 2026, that it has unveiled industry-specific benchmark indicators enabling distribution companies to evaluate their transfer pricing compliance and identify potential tax risks. The
See MoreRomania 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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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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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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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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Malta updates corporate income tax return for 2026 with transfer pricing, new reporting changes
Malta's Commissioner for Revenue has announced that the electronic corporate income tax return for the year of assessment 2026 is now available through its online services. The supplemental document for Fiscal Units is also available for
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Rwanda implements new transfer pricing rules, business tax regulations, loss carryforward extensions
Rwanda has published Ministerial Order No. 003/26/10/TC of 29 April 2026 in the Official Gazette, introducing updated transfer pricing rules under Law No. 027/2022 of 20 October 2022, the country’s new income tax law, accounting for small
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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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India: 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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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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Ukraine: MoF consults transfer pricing reform bill
Ukraine’s Ministry of Finance (MoF) opened a public consultation on a draft law titled “On Amendments to the Tax Code of Ukraine Regarding Further Improvement of Transfer Pricing Rules” on 24 February 2026. The draft was prepared with the
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OECD releases Amount B Pillar One guidance, pricing automation tool
The OECD published new materials on 17 February 2026 to assist with the rollout of Amount B under Pillar One, which provides a simplified transfer pricing framework for baseline marketing and distribution activities. The release includes updated
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