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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Colombia: DIAN highlights 2025 transfer pricing adjustment requirements
Colombia’s tax authority (DIAN) has issued a notification, on 6 February 2026, for large taxpayers subject to the transfer pricing regime to make any required transfer pricing adjustments when filing their 2025 fiscal year income tax return. As
See MoreOECD 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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