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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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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South Africa: SARS consults customs rules for transfer pricing adjustments
The consultation is set to conclude on 3 October 2025. The South African Revenue Service (SARS) has initiated a public consultation regarding draft changes to the rules under sections 40, 41, and 120 of the 1964 Customs and Excise Act, relating
See MoreArgentina joins CRS MCAAÂ
As of 25 July 2025, 55 jurisdictions have signed the Addendum to the CRS MCAA. Argentina signed the Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS MCAA) on 1 July
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Ukraine clarifies transfer pricing penalty changes effective from March 2025
These amendments, which took effect on 25 March 2025, adjust the penalties applicable to late or missing submissions of TP-related reports and notifications. The Ukrainian State Fiscal Service issued a clarification on upcoming changes to the Tax
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UK proposes tighter transfer pricing rules, replacing diverted profits tax with new UTPP
The UK government will tighten transfer pricing rules and replace the diverted profits tax with a new corporation tax charge. The government has announced plans to revise the UK's international tax framework, which involves narrowing the
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OECD publishes new transfer pricing profiles for Azerbaijan and Pakistan, updates 11 others
The OECD has published updated transfer pricing country profiles for 11 jurisdictions. RegFollower Desk The Organisation for Economic Co-operation and Development (OECD) has released new transfer pricing country profiles for Azerbaijan and
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Poland: Council of Ministers approve bill to ease group taxation, transfer pricing rules
Poland's Council of Ministers approved a proposal to simplify group taxation and transfer pricing regulations on 21 May 2025. Poland’s Council of Ministers approved a proposal on 21 May 2025 to streamline the country’s group taxation and
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UK: HMRC consults transfer pricing framework, permanent establishment rules, diverted profits tax
The UK’s tax authority, His Majesty’s Revenue and Customs (HMRC) has launched consultations seeking public input on potential updates to the UK’s transfer pricing framework, permanent establishment rules and the diverted profits tax on 28
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OECD consults Ukraine’s transfer pricing rules
The OECD is working with Ukraine's Ministry of Finance to align Ukraine's Transfer Pricing Framework with OECD Transfer Pricing Guidelines, as part of the implementation of Ukraine's National Revenue Strategy. Project description To ensure
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Poland gazettes consolidated transfer pricing rules for corporate tax
Poland published the updated consolidated text of the transfer pricing regulations related to corporate income tax in the Official Gazette on 8 April 2025, reflecting the provisions which have been in effect from 21 March 2025. The provisions of the
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UK consults advance tax clearance service for large innovative investment projects, transfer pricing treatment of CCAs
The Chancellor of the Exchequer announced that the government launched a consultation on a proposed new service aimed at providing advance statutory certainty on the application of UK corporation tax rules for businesses undertaking the "very
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India enacts Finance Act 2025, offers support for targeted sectors of the economy
India's Central Board of Direct Taxes (CBDT) has released the Finance Act 2025 on 29 March 2025. The Act was officially enacted on 29 March 2025, following the President's assent, implementing the provisions outlined in the 2025–2026
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