Bulgaria introduces new transfer pricing rules aligned with OECD guidelines
Bulgaria's new Ordinance on Transfer Pricing Methods Application (the New Ordinance) entered into effect on 1 January 2026, replacing the previous 2006 regulatory framework. Introduced to align national tax regulations with updated OECD Transfer
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Latvia: SRS issues transfer pricing controlled transaction report guidance
Latvia’s tax authority, the State Revenue Service, on 18 September 2026, issued the methodological guidance covering transfer pricing controlled transaction report requirements. These documents provide official guidelines from the Latvian State
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Ukraine proposes broad transfer pricing reforms
The Ukrainian Parliament is reviewing the draft Law on amendments to the tax code of Ukraine regarding further improvement of Transfer Pricing (TP) rules, which was submitted on 4 September 2026. If adopted, the lew would enter into force on 1
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Malaysia gazettes Income Tax (Transfer Pricing) (Amendment) Rules 2026
Malaysia’s government has published Order No. P.U. (A) 300/2026, the Income Tax (Transfer Pricing) (Amendment) Rules 2026, in the Official Gazette on 27 August 2026, officially updating Malaysia's regulatory framework regarding transactions
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Ireland: Revenue clarifies Section 110 transfer pricing, profit participating note rules
Ireland Revenue has clarified the application of Section 110 of the Taxes Consolidation Act (TCA) 1997, including Transfer Pricing, arm's length requirements and restrictions on profit participating notes (PPNs), in eBrief 120/2026 published on 21
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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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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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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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