Montenegro sets 2026 arm’s length interest rate for related party loans
Montenegro has set the deemed arm’s length interest rate for 2026 at 4.97% after the Ministry of Finance adopted a Rulebook regulating interest rates on financial instruments between related parties. The Rulebook was published in the Official
See More
Serbia sets 2026 arm’s length interest rates for related party loans
Serbia's Ministry of Finance has introduced new interest rates for related party loans in 2026, with the rulebook set to take effect on 2 May 2026 following its publication in the Official Gazette on 24 April 2026. The regulations establish arm's
See More
Ecuador rejects OECD Pillar One Amount B safe harbour in new SRI circular
Ecuador’s Internal Revenue Service (SRI) has clarified that the OECD’s Pillar One – Amount B framework has not been adopted in the country, reaffirming that taxpayers must continue to apply existing domestic transfer pricing rules to routine
See More
UN Tax Committee Discusses Transfer Pricing
On 24 March 2026 the UN Committee of Experts on International Cooperation in Tax Matters discussed the workstreams for transfer pricing during the current mandate of the Committee. The subcommittee on transfer pricing presented its planned
See More
Switzerland clarifies application of hybrid arbitrage arrangements under transitional CbCR Safe Harbour
SFTA confirmed that OECD guidance on hybrid arbitrage arrangements under the transitional CbCR safe harbour applies in Switzerland only to transactions entered into after 18 December 2023. The Swiss Federal Tax Administration (SFTA) has issued
See More
India: CBDT expands transfer pricing safe harbour rules and raises transaction limits for select services
India’s Central Board of Direct Taxes (CBDT) issued Notification No. 21/2025 on 25 March 2025, introducing the Income-tax (Sixth Amendment) Rules, 2025. This encompasses three key modifications to the safe harbour rules for international
See MoreSerbia adopts rulebook on arm’s length interest rates for 2025
Serbia’s Ministry of Finance has issued the Rulebook on arm’s length interest rates for 2025, which was published in the Official Gazette of Serbia No. 17/2025 on 28 February 2025. The rulebook establishes specific interest rates for both
See More
Korea (Rep.): National Assembly passes 2024 Tax Law Amendment Bill
The South Korean National Assembly approved the 2024 Tax Law Amendment Bill on 10 December 2024. The amendments will affect various tax regulations which include: Deferral of Crypto Gains Tax The bill introduces a two-year deferral on the
See More
Austria gazettes Pillar Two CbCR Safe Harbour Regulation
Austria’s tax authorities published a decree in the Official Gazette on the temporary CbCR Safe Harbor (CbCR Safe Harbor Regulation) under the Minimum Taxation Act (“MinBestG”) on 5 December 2024. The MinBestG, which came into force on 31
See MoreIndia extends transfer pricing safe harbor rules to FY 2024-25, updates filing deadline for international transactions
India's Central Board of Direct Taxes (CBDT) has released Notification No. 124/2024 outlining the Income Tax (Tenth Amendment) Rules, 2024 on 29 November 2024. According to the amendment, the transfer pricing safe harbor rules under Rule 10TD of
See More
US: IRS and Treasury Plan to Issue Guidance on Streamlined Approach to Baseline Distribution Activities
In the IRS and Treasury Priority Guidance Plan for 2024/25, issued on 3 October 2024, there is a plan for a new section 482 guidance project to provide guidance for taxpayers consistent with Amount B of Pillar One. The OECD Amount B Guidance
See More
UK launches consultation on safe harbour anti-arbitrage rule transition to domestic law
The UK Treasury released draft legislation for consultation on implementing the transitional safe harbour anti-arbitrage rule. This initiative ensures the rule aligns with the OECD's G20 Inclusive Framework's December 2023 Administrative
See More
Turkey enacts tax reform law, includes Pillar Two global minimum tax
The Turkish Revenue Administration has officially published Law No. 7524 in the Official Gazette, on 2 August 2024, introducing significant tax reforms aimed at aligning with international standards. This legislation encompasses various measures,
See More
India to expand transfer pricing safe harbour rules
India’s finance minister, Nirmala Sitharaman, said India plans to broaden its safe harbour regulations for transfer pricing. The minister said this while presenting the 2024-24 federal budget on 23 July, 2024. The planned expansion of the
See More
Serbia releases 2024 arm’s length interest rates rulebook
Serbia’s Ministry of Finance has issued the rulebook on arm’s length interest rates for 2024. It was published in the official gazette on 31 May, 2024, and will take effect on 8 June, 2024. The rulebook sets distinct interest rates for
See More
Italy announces decree on Pillar Two transitional safe harbour rules
Italy’s Ministry of Finance announced the ‘TSH decree’, which was published in the official gazette on 28 May, 2024. This decree implements the Pillar Two transitional safe harbour (TSH) rules, as stipulated in Article 39 of Legislative
See More
Australia: ATO releases discussion paper on thin capitalization rules for foreign bank branches
On 17 April 2024, the Australian Taxation Office (ATO) published a discussion paper regarding the safe harbor formula for calculating the minimum capital requirements for inward investing deposit-taking institutions (ADIs) under the thin
See More
Greece proposes new law to implement EU minimum tax rules
On 23 February, 2024, the Greek Ministry of Finance initiated a public consultation on a proposed bill aiming to incorporate the OECD’s Pillar Two Model Rules, as outlined in the EU Minimum Tax Directive. This draft bill is currently open for
See More