Peru clarifies informative affidavit requirements for transfer pricing compliance
The National Superintendency of Customs and Tax Administration (Sunat) released Report No. 000063-2024-SUNAT/7T0000 on 9 September 2024, clarifying issues related to the informative affidavit required for import and export transactions involving
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Russia: FTS issues new transfer pricing reporting requirements
Russia's Federal Tax Service (FTS) has introduced new guidelines requiring detailed disclosure of the price formation chain in controlled transactions for transfer pricing purposes. According to Guidance Letter ZG-2-13/11134, issued on 2 August
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New Zealand issues Commissioner’s Statement on withholding in transfer pricing
The New Zealand tax authority released the Commissioner's statement (CS) 24/02: Withholding obligations arising in relation to transfer pricing arrangements on 30 August 2024. CS 24/02 details the Commissioner's stance and operational strategy
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UAE: FTA clarifies related parties definition for government entities
The UAE’s Federal Tax Authority (FTA) published a public clarification CTP002 of 21 July 2024, which clarified the definition of "related parties" where there is common ownership and/or control through a government entity. The corporate tax in
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Ecuador updates transfer pricing report guideline, introduces new penalties
The Internal revenue service (SRI) has issued “Resolution No. NAC-DGERCGC24-00000020” in the Ecuadorian Official Gazette on 28 May, 2024, which outlines details of the transfer pricing annex concerning related party transactions and the
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Slovak Republic releases 2023 transfer pricing documentation guidelines
Slovak Republic's Ministry of Finance has issued guidelines (MF/020061/2022-724) outlining the requirements for transfer pricing documentation for 2023. These guidelines categorise transfer pricing documentation into three types: Full-scope
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Hungary releases 2024 audit plan with targets transfer pricing
Hungary's National Tax and Customs Administration (NAV) has released its audit strategy for the 2024 calendar year, highlighting transfer pricing as its key area of focus among other sectors. The new transfer pricing reporting obligation introduced
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Latvia revises domestic list of tax-free or low-tax jurisdictions
On 28 February 2024, the Latvia Ministry of Finance released the updated domestic list of tax-free or low-tax jurisdictions. The renewed list went into effect on 1 March 2024. In the updated list, Latvia removed Belize, Bahamas, Seychelles, Turks
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Switzerland releases Q&A guidance on application of transfer pricing rules
On February 23, 2024, the Swiss Federal Tax Authorities (SFTA) published the Q&A guidance regarding the application of transfer pricing regulations in Switzerland. This guidance clarifies the application of the arm's-length principle and the
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Norway issues new guidance on transfer pricing reporting requirements for 2024
On 8 February 2024, the Norwegian Tax Administration (NTA) released a guidance regarding the amendments of the transfer pricing disclosures in tax returns for organizations, due by 31 May 2024 for the fiscal year ending in 2023. The guidance
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UK: HMRC publishes transfer pricing guidance on accurate delineation of actual transactions and analysis of risk
On 30 January 2024, the UK HMRC revised its transfer pricing operational guidance by including a new section on the accurate delineation of actual transactions and the analysis of risk. The updated transfer pricing operational guidance is
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Belarus modifies transfer pricing rules
On 27 December 2023, Belarus announced that it had made amendments to its transfer pricing rules. The new transfer pricing provisions are outlined in Law No. 327-Z of 27 December 2023, which went into effect on 1 January 2024. The new regulations
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Malta issues guidelines for transfer pricing rules
On 19 January 2024, Malta's Commissioner for Revenue published Guidelines in relation to the Transfer Pricing Rules. These guidelines are issued in terms of Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta) and are to be read in
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Belgium: Constitutional court revokes several federal and regional DAC6 legislation
On January 11, 2024, the Belgian Constitutional Court released a statement regarding four judgments related to legislation passed by the Federal government, the Walloon region, Brussels, and the French Community. These judgments pertain to the
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Indonesia releases revised guidelines for transfer pricing
On 29 December 2023, Indonesia’s Minister of Finance (MoF) released the revised transfer pricing guidelines Regulation No. 172 of 2023 (PMK-172). The updated and consolidated transfer pricing regulations in various chapters, such as: General
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Kazakhstan’s Transfer Pricing Legislative Amendments 2023
Kazakhstan is undergoing a pivotal transformation in its transfer pricing framework, marked by the Majilis' approval of substantial amendments to the existing legislation. The aim is to curb revenue losses, prevent capital outflow, and align with
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Brazil tax reform brings challenges to service sectors
The new Brazilian transfer pricing rules align with the OECD standard and are a radical change to the analysis of intra-group transactions, and offer several implementational challenges. Besides, the tax reform (PEC 45/2019) is being discussed in
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France: Tax authority updates transfer pricing guidelines for SMEs
On 22 November 2023, the French tax authority published an updated transfer pricing guide for small and medium-sized enterprises (SMEs). The guide covers a wide range of topics, including the concept of transfer pricing, the arm's length principle,
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