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
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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 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
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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
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Switzerland publishes safe harbor interest rate limits for 2024
On 31 January 2024, the Swiss Federal Tax Administration released two circulars concerning the safe harbor interest rate limits for shareholders and related party financing for 2024. The rates vary based on whether the financing is in Swiss francs
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Kenya raises fringe benefit tax and non-resident loan interest rates
On 22 January 2024, the Kenya Revenue Authority released a notice related to the market interest rate for fringe benefit tax purposes and the deemed interest rate for non-resident loans for January, February, and March 2024. The market interest
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US: IRS evaluating group membership to fix arm’s length interest rate
On 29 December 2023, the Office of Chief Counsel Memorandum announced that the IRS is considering group membership to determine the arm's length interest rate chargeable for intragroup loans and make a section 482 adjustment. The memorandum provides
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Australia increases interest rate for simplified transfer pricing record-keeping options for loans
On 8 November 2023, the Australian Taxation Office (ATO) released an updated version of practice compliance guideline on simplified transfer pricing record-keeping options (PCG 2017/2). The updates outline the safe harbor interest rate for the
See MoreSerbia: MoF adopts arm’s length interest rates for 2023
On 29 March 2023, the Serbian Ministry of Finance has approved the rulebook on arm’s length interest rates for 2023. The rulebook will be effective from 6 April 2023. Interest rates in accordance with “arm’s-length” principle that applies
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Switzerland publishes safe harbor interest rates for 2023
The Swiss Federal Tax Administration (SFTA) recently released Circular Letter No. 203 and Circular Letter No. 204 on 7 and 8 February 2023, respectively. These circulars provide safe harbor interest rates for intercompany loans and advances in Swiss
See MoreSerbia: Ministry of Finance release arm’s length interest rates for 2022
On 16 December 2022, the Serbian Ministry of Finance published the Rulebook on arm’s Length interest rates applicable for 2022 that applies to related parties’ loans. The rulebook comes into force on 24 December 2022. Taxpayers can use the
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Australia: ATO releases updated interest rate for simplified transfer pricing record keeping options for loans
On 17 November 2022, the Australian Taxation Office (ATO) published an updated version of Practical Compliance Guideline (PCG) 2017/2 related to the eligibility criteria for applying simplified transfer pricing record keeping options for low level
See MoreSingapore publishes TP Guidelines on indicative margin for related-party loans
On 4 January 2022, the Singaporean Inland Revenue Authority updated transfer pricing guidelines to set the 2022 indicative margin at 1.8% for related-party loans. The indicative margins are applied on each related party loan not exceeding
See MoreSwitzerland publishes safe haven interest rates for 2022
The Swiss Federal Tax Administration (SFTA) has published two Circulars with safe-harbor interest rates 2022 for advances and intercompany loans in Swiss francs as well as in foreign currencies. Circular 195 of 27 January 2022 The minimum
See MorePoland publishes safe harbor rate of interest, related-party loans in 2022
On 24 December 2021, the Polish Official Gazette published a Regulation No. 1192, establishing base interest rates and margin rates for the purposes of transfer pricing for individual and corporate income taxes. The “Safe Harbor” interest rate
See MoreRussia increases the Interest rate from July 2021
On 23 July 2021, the Russian Central Bank announced the decision to increase the key rate from 5.5% to 6.5% with effect from 26 July 2021. For tax purposes, the key rate is important in relation to the safe harbor rates for interest income and
See MoreSwitzerland declares safe harbor interest rates
The Federal Tax Administration of Switzerland has published two separate circulars regarding safe harbor interest rate limits applicable to shareholder and related party loans in 2021. The rates may vary depend on whether the financing is in Swiss
See MoreSerbia: Ministry of Finance publishes safe harbor interest rates for 2020
The Serbian ministry of finance has published the Rulebook on arm’s length interest rates that are applicable for 2020, which apply to interest rates on loans and credits between associated parties. The Rulebook was published in the Official
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