Australia: Administrative Review Tribunal rules in favour of Alcoa against ATO in key transfer pricing ruling
This case focused on a major transfer pricing issue, where ATO claimed Alcoa underpriced its alumina sales to Aluminium Bahrain B.S.C. (Alba) from 1993 to 2009, causing a tax shortfall of over AUD 213 million. Australia’s Administrative Review
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Israel seeks input on local R&D centres and IP valuations
Israel’s tax authority (ITA) released a draft Tax Circular on 27 February 2025 for public comment. The circular outlines criteria and requirements for local R&D centres and post-acquisition IP sales, offering potential certainty from the
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Kazakhstan’s Transfer Pricing Legislative Amendments 2023
Kazakhstan is undergoing a pivotal transformation in its transfer pricing framework, marked by the Majilis' approval of substantial amendments to the existing legislation. The aim is to curb revenue losses, prevent capital outflow, and align with
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Italy: Revenue agency issues draft guidelines on investment management transfer pricing
On 20 October 2023, the Italian Revenue Agency issued the draft transfer pricing guidelines for implementing the Investment management exemption regime (IME). The draft was in public consultation until 3 November 2023. The IME was introduced by
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Poland releases guidelines relating to cost-plus method in transfer pricing
On 29 September 2023, Poland published formal guidance regarding the application of the cost-plus method to ensure accurate valuation of transactions involving related entities for international tax purposes. The purpose of this guide is to provide
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OECD: Consultation Document on Transfer Pricing for Minerals
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework. This is a draft toolkit to support developing countries in combating base erosion and profit shifting relating
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Poland: MoF publishes guideline on transfer pricing method
On 24 March 2023, the Polish Ministry of Finance published guidance clarifying the application of the resale price method to determine the arm's length value of transactions between related parties. The guidance focuses on practical aspects of using
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Brazil: Lower House passes transfer pricing reform measure
On 30 March 2023, the Brazilian Lower House of Congress adopted Measure No. 1,152 to overhaul its transfer pricing system that was introduced on 29 December 2022. In addition to introducing the arm's length principle into the Brazilian transfer
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UAE publishes new corporate tax law
On 9 December 2022, the UAE Ministry of Finance (MoF) released the Federal Decree-Law No. 47 of 2022 on business taxation to enact a new Corporate Tax Law in the UAE. The new law has been supplemented with Frequently Asked Questions (FAQs). The
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Greece: Parliament adopts a draft bill to update code of tax procedure
On 27 October 2022, the parliament of Greece adopted a tax law ratification bill for consideration. The bill includes the following measures: Includes definitions; Establishment of regulatory procedures for tax declaration and payment;
See MorePoland: MOF launches public consultations for TP method on resale price
On 4 April 2022, the Polish Ministry of Finance launched a public consultation on draft guidelines clarifying the resale pricing method for determining the arm's length value of transactions between associated parties. The guidance clarifies,
See MorePeru modifies export & import transactions reporting requirements under TP rules
On 26 March 2022, Peru issued Legislative Decree No. 1537 in the official gazette regarding relaxing the term for the presentation of the communication of exported and imported goods and the obligation of the information to be registered in said
See MoreRussia: FTS clarifies the application of transfer pricing control under sanctions
On 14 March 2022, the Federal Tax Service (FTS) published guidance (Letter No. ШЮ-4-13/2724) stipulating that the application of sanctions against Russian individuals and legal entities may adversely affect the economic conditions of the
See MoreNigeria: FIRS posts digital FAQs regarding transfer pricing
On 15 March 2022, the Federal Inland Revenue Service (FIRS) made a post of frequently asked questions and answers (FAQs) related to transfer pricing (TP) through online. This includes applicable regulations and their scope; documentation
See MoreJordan issues Executive Instructions on new TP rules for MNE groups
On 16 September 2021, the Hashemite Kingdom of Jordan has published Executive Instructions No. 3 of 2021 regarding new transfer pricing (TP) rules for MNE groups. Jordan has published Regulation No. 40 of 2021 On 7 June 2021 which introduces
See MoreJordan introduces transfer pricing rules for MNE groups
On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 in the Official Gazette. The Regulation has introduced transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. The Regulation
See MoreParaguay releases sixth TP method for commodity transactions
On 16 April 2021, the tax authority of Paraguay has published General Resolution No. 86 with effect from 17 April 2021, regarding the application of the special transfer pricing (TP) rules, related to the sixth method, for certain commodity
See MoreDominican Republic: DGII issues a Decree to amend TP rules
On 21 April 2021, the Directorate General of Internal Revenue (DGII) published Decree 256-21, which makes modification on articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the Decree no. 78-14, of March 14,
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