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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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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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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Denmark: 2024-25 legislative plan proposes updates to minimum tax, transfer pricing to match OECD rules
Denmark's government announced the legislative programme for the parliamentary year 2024-25 on 1 October 2024. The bill follows up on the government platform "Responsibility for Denmark" from December 2022 and the agreement on "A Stronger Business
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Peru enacts new rules for determining FMV of non-listed securities in related-party transactions
The Peruvian Government enacted Legislative Decree 1663 on 24 September 2024, amending the Income Tax Law to introduce rules for determining the fair market value (FMV) of non-listed securities in related-party transactions. This closes a gap in the
See MorePeru 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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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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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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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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Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
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Ecuador: SRI gazettes resolution amending transfer pricing rules
On 13 September 2023, Ecuador's Internal Revenue Service (SRI) issued Resolution No. NAC-DGERCGC23-00000025, which modifies the transfer pricing rules. The resolution includes following measures: Taxpayers who have conducted transactions with
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Egypt publishes income tax amendment law
On 15 June 2023, the Egyptian Tax Authority published Law No. 30 of 2023 in the Official Gazette amending some provisions of the Income Tax Law No. 91 of 2005. The Law entered into force on 16 June 2023. The key amendments to the Income Tax Law are
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Kenya: Transfer pricing tax measures in Finance Bill 2023
On 28 April 2023, the Cabinet Secretary of the Kenya Ministry of Finance submitted the Finance Bill 2023 (the Bill) to Parliament, which provides the following tax measures related to transfer pricing. The bill proposes to prohibit taxpayers from
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South Africa issues interpretation note on definition of associated enterprise
On 17 April 2023, the South African Revenue Service (SARS) published an interpretation note 128 on the definition of “associated enterprise”. This note provides guidance on the interpretation and application of the definition of “associated
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Brazil issues new transfer pricing legislation to align with OECD transfer pricing guidelines
On 29 December 2022, the outgoing Brazilian President issued draft legislation MP 1.152 to align Brazil’s unique transfer pricing system with the OECD Transfer Pricing Guidelines. The news rule will be compulsory for 2024, for fiscal year 2023,
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Malta implements formal transfer pricing rules
On 18 November 2022, Malta published Legal Notice 284 of 2022 in the Official Gazette implementing transfer pricing rules into Malta’s tax code. These rules shall apply for basis years commencing on or after 1 January 2024 in relation to any
See MoreKenya: Major changes in transfer pricing rules under Finance Act 2022
On 8 July 2022, the Kenyan Finance Act 2022 was gazetted which was signed into law by the President on 21 June 2022. The law introduced a number of changes to the transfer pricing regulatory framework in Kenya that will have far-reaching
See MoreSaudi Arabia issues draft Transfer Pricing Bylaws for public consultation
On 4 July 2022, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued a draft of Transfer Pricing (TP) Bylaws and invited public consultation. The public consultation period is open until 30 July 2022. The final Transfer Pricing Bylaws
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