Colombia: DIAN highlights 2025 transfer pricing adjustment requirements
Colombia’s tax authority (DIAN) has issued a notification, on 6 February 2026, for large taxpayers subject to the transfer pricing regime to make any required transfer pricing adjustments when filing their 2025 fiscal year income tax return. As
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Chile revises procedures for transfer pricing adjustment requests
Chile's Internal Revenue Service (SII) has published Resolution No. 6 of 9 January 2025, which updates procedures for requesting transfer pricing adjustments after adjustments by foreign tax authorities. It updates and replaces Resolution No. 67
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Malaysia publishes surcharge FAQs related to transfer pricing adjustments
On 18 January 2024, the Inland Revenue Board of Malaysia (IRBM) published an FAQ list about surcharges for transfer pricing adjustments. The FAQ document is available on the transfer pricing guidance webpage. Under the Finance Act 2020, the tax
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Hungary: Finance minister presents 2023 budget bill to parliament
On 22 June 2022, the Hungarian finance minister submitted the 2023 Budget Bill in parliament providing following tax measures related to transfer pricing changes. The bill proposes to revise the regulation of the application of the interquartile
See MoreItaly confirms VAT treatment of TP adjustments
On 30 December 2021, the Italian Revenue Agency has published Ruling No. 884 clarifying the VAT treatment of transfer pricing (TP) adjustments. In the case at issue in Ruling Answer No. 884/2021, a resident company made a number of TP
See MoreFinland: Parliament adopts the law on transfer pricing adjustment
On 9 December 2021, the Finnish Parliament has approved the amendment to the transfer pricing adjustment provision, (VML Section 31) of the Tax Procedure Act (VML). On 16 December 2021, the President signed the law, the amendment will take effect
See MoreFinland: Ministry of Finance issues budget proposal for 2022
On 9 September 2021, the Ministry of Finance of Finland has released the government’s budget proposal for 2022 including following tax measures. Companies may make an extra deduction of 150% in their taxation for 2022-2027 for research and
See MoreSingapore updates GST Guide on Transfer Pricing Adjustments
On 1 June 2021, the Inland Revenue Authority of Singapore (IRAS) has published second edition of e-Tax Guide GST: Transfer Pricing Adjustments. The e-Tax guide explains the GST treatment for adjustments on the transfer prices of transactions
See MorePoland: MOF publishes tax explanations on transfer pricing adjustment
On 2 April 2021, the Polish Ministry of Finance has published tax clarifications on transfer pricing regarding the adjustment of transfer prices within the meaning of Art. 11e of the CIT Act (Article 23q of the PIT Act), in relation to the
See MoreBelgium: TP Circular on OECD guidelines
On 25 February 2020, the Belgian tax authorities published the final version of the transfer pricing (TP) Circular No. 2020/C/35 in French on their website on transfer pricing guidelines for multinational enterprises and tax
See MoreMexico issued transfer pricing adjustment rule
Mexican tax authorities has been issued rule 3.9.1 of the Miscellaneous Rule on 8 December 2016 regarding transfer pricing adjustments.The rule establishes that all transfer pricing adjustments should be reflected in the tax return in which the
See MoreNorway: the amount of transfer pricing adjustments doubles
On June 22, 2012 the Norwegian tax authorities (Skatteetaten) announced total transfer pricing adjustments for 2012 of NOK 16.6 billion (approximately U.S. $ 2.8 billion / € 2.2 billion), whereas, in 2010, the total amount was NOK 8.5 billion. In
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