Malaysia issues transfer pricing guidelines for intra-group loans
Malaysia's Inland Revenue Board (IRBM) has published the Malaysia Transfer Pricing Guidelines for Intra-Group Loans (MFTIL), providing a comprehensive framework for determining whether financing transactions between associated persons comply with
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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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Singapore: IRAS issues new guidance on tax treatment of related party payments
The Inland Revenue Authority of Singapore (IRAS) has updated its guidance on Business Expenses, introducing new clarification on the tax treatment of payments for related party services. The update confirms that such payments may be deducted for tax
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Singapore updates transfer pricing guidance on share-based compensation under TNMM
The Inland Revenue Authority of Singapore (IRAS) has updated its Transfer Pricing Guidelines (Ninth Edition), released on 4 June 2026, to clarify the treatment of share-based compensation costs under the Transactional Net Margin Method
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Italy: Supreme Court exempts certain gratuitous intragroup guarantees from transfer pricing rules
Italy’s Supreme Court has clarified the circumstances in which domestic transfer pricing rules apply to intragroup transactions, confirming that transactions conducted without consideration may remain outside the scope of transfer pricing where
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Namibia: 2026-27 budget includes accelerated depreciation for businesses
Namibia's Parliament has released the Budget Statement for the Fiscal Year 2026-27 on 26 February 2026, introducing significant changes to the tax code to support both individuals and businesses. The key tax measures are: Corporate and
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Australia: ATO to revise transfer pricing guidance on imported products
The Australian Taxation Office (ATO) is revising its guidance (PCG 2029/1) on transfer pricing risks for businesses that import foreign goods and digital services. The ATO also plans to update its benchmarking tool by December, refining how it
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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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UN Tax Committee: Transfer Pricing Subcommittee Discusses Future Guidance
On 26 March 2025 the UN Tax Committee discussed their transfer pricing work. Since the previous session of the Committee, the Subcommittee on Transfer Pricing has gathered feedback from members on possible future workstreams that could be pursued by
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Germany revises transfer pricing guidelines for intra-group financing
Germany’s Federal Ministry of Finance (BMF) has issued a draft version of the Administrative Principles for Transfer Pricing 2023 (VWG VP), on 14 August 2024. This revision incorporates the new regulations found in Section 1, Paragraphs 3d and 3e
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South Africa: SARS issues new transfer pricing guidance for intra-group loans
On 17 January 2023, the South African Revenue Service (SARS) issued Interpretation Note 127 that explains how to calculate the taxable income of certain individuals or entities involved in international transactions, specifically in regard to loans
See MoreSouth Africa: Public Consultation on draft interpretation note on pricing of Intra-Group Loans
On 11 February 2022, the South African Revenue Services (SARS) published a draft interpretation note, determining the taxable income of certain persons from international transactions: intra-group loans and provides taxpayers with guidance on the
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South Korea enacts tax revision bill for 2022
In December 2021, South Korea has enacted a tax revision bill for 2022 which was passed by Korea’s National Assembly on 2 December 2021. The tax revision bill is generally effective from fiscal years beginning on or after 1 January 2022. The
See MoreIndia: CBDT notifies the arm’s-length pricing variation limit for 2021-22
On 29 October 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 124/2021, which provides for a tolerance limit of 1% for wholesalers and 3% in all other cases for the arm’s-length pricing determination in the
See MoreColombia: Government issues regulations identifying preferential tax regimes
On 28 October 2021, the Colombian Government has issued Decree 1357, through which it partially regulates article 260-7 of the Tax Code. The Decree identifies criteria to consider a jurisdiction as a Preferential Tax Regime. This decree was
See MoreSingapore releases updated Transfer Pricing Guidelines
On 10 August 2021, the Inland Revenue Authority of Singapore published the sixth edition of its E-Tax Guide on Transfer Pricing. The most important changes are summarized as follows: Additional guidance on cost contribution arrangements (CCAs)
See MorePeru announces the most appropriate method in the case of intra-group services
On 18 March 2021, the Peruvian tax authorities (SUNAT) has issued Report No. 135-2020-SUNAT/7T0000, through which SUNAT announced the use of the most appropriate method to determine the market value of services other than those classified as low
See MoreFrance: Court makes decision to reflect intra-group financial transactions
The French tax administration (FTA) published some decisions issued by the French courts and an administrative guidance regarding the arm’s length nature of intragroup financial transactions. Court’s decisions: In the last quarter of
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