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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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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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 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 MoreParaguay introduces new guidance on TP law
On 30 December 2020, the tax authority of Paraguay issued Decree 4644/2020, providing further guidance on the technical aspects of Paraguay’s transfer pricing (TP) provisions included in Law 6380. Law No. 6,380/2019 modernized the Paraguayan
See MoreTurkey publishes transfer pricing General Communiqué No. 4
On 1 September 2020, the Turkish Revenue Administration has published transfer pricing General Communiqué No. 4 on disguised profit distribution in the Official Gazette No. 31231. The Communiqué explains information regarding new transfer pricing
See MoreSpain: Cabinet approves a draft bill for digital services tax (DST)
On 18 February 2020, the Spanish Cabinet reportedly approved a draft bill for the introduction of a digital services tax (DST). A 3% DST will be applicable for large companies whose respective groups have revenue of at least EUR 750 million
See MoreAustria: Finance Ministry publishes updated information regarding DST
On 24 February 2020, the Ministry of Finance published updated information regarding the process of how to register and make payment of digital service tax
See MorePoland: Administrative Court allows expenditure on intra-group services
On 6 February 2020, Polish Administrative Court (the “Court”) issued its decision on a transfer pricing case regarding Poland vs Shared Service Center. A shared service center (SSC) in Poland both provided intra-group services to the group
See MoreCzech Republic: Government publishes final draft Bill of DST in Parliament
On 22 January 2020, the final draft Bill regarding the digital service tax (DST) was published in the Parliament. This Bill proposed to introduce a single digital tax of 7% for companies with a global revenue thresholds of EUR 750 million and
See MoreTurkey: Parliament passes laws on tax regulation
On 21 November 2019, the Turkish Parliament approved laws on tax regulation which includes new taxes, namely digital services tax (DST), valuable house tax and accommodation tax. The law increases tax rate from 30% to 40% for people earning
See MoreArgentina: AFIP announces draft transfer pricing guidance for public comments
On 2 October 2019, tax authority of Argentina (AFIP) announced a public consultation and posted on the AFIP website a draft resolution concerning transfer pricing compliance procedures. It would replace the existing transfer pricing rules in
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