China releases 16th annual APA report (2024), highlighting strong growth, efficiency
China’s State Taxation Administration (STA) published its 16th Annual Advance Pricing Agreement (APA) Report on 25 November 2025, providing a comprehensive overview of the country’s APA programme and its development between 2005 and 2024. The
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Bulgaria: MoF updates transfer pricing rules
Bulgaria’s Ministry of Finance (MoF) issued Ordinance H-3 of 7 November 2025, updating the country’s transfer pricing framework to align with the latest OECD Transfer Pricing Guidelines. The ordinance was published in the State Gazette on 11
See MoreTurkey: Revenue Administration issues decree on transfer pricing documentation
On 25 February 2020, the Turkish Revenue Administration has published Presidential Decree No. 2151 in the official gazette, which amends transfer pricing documentation rules. The decree aims to set out OECD’s Base Erosion and Profit Shifting
See MoreLuxembourg: EU General Court upholds EC Commission’s decision in Fiat case
On 24 September 2019, the EU General Court upheld the Commission’s decision that Fiat received unlawful State aid from Luxembourg, and at the same time cancelled the decision which had found the same with respect to Starbucks in the
See MoreEgypt: Government publishes amends income tax law regarding transfer pricing rules
Government has published Ministerial Decree No. 221 of 2018 amending certain provisions of the Income Tax Law Executive Regulations under Ministerial Decree No. 991 of 2005 relating to transfer pricing rules on 22nd May 2018. The definition of
See MoreTurkey: Council of Minister proposes transfer pricing provisions
A draft Communique regarding transfer pricing has been published in Turkey. It generally represents measures of the OECD’s base erosion and profit shifting (BEPS) Action 13 on country-by-country reporting and transfer pricing documentation. The
See MoreIndia:Transfer pricing method applies uniformly to all international transactions
The Delhi High Court, in the case of: Magneti Marelli Powertrain India Pvt. Ltd. v. DCIT (ITA 350/2014), held that taxpayer’s contractual obligation to make a payment as per business and commercial requirements and arrangements cannot ipso facto
See MoreTurkey: Amendment in transfer pricing legislation
The Law No. 6728 on the amendment of certain laws for the improvement of the investment landscape has been published in the Official Gazette on 9 August 2016. This law amended certain transfer pricing provisions. Some of the provisions are given
See MorePhilippines: Transfer Pricing Regulations
On 23 January 2013, the Philippines Secretary of Finance issued transfer pricing regulations (Revenue Regulation (RR) No. 02-2013). The regulations provide guidance for applying the arm’s length principle for pricing in related-party transactions
See MoreNigeria introduced new TP regulations
Nigeria has announced new Transfer Pricing Regulations on October 22, 2012. This will be applicable retroactively to August 2, 2012. The TP Regulations provide that all transactions between connected parties should be at arm’s length. Taxpayers
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