Malaysia: IRBM publishes transfer pricing rules 2023

June 02, 2023

On 29 May 2023, the Malaysian Inland Revenue Board of Revenue (IRBM) officially published Order No P.U. (A) 165 (TP Rules 2023) introducing a new transfer pricing documentation process effective from assessment year 2023 onwards. The main changes

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Kazakhstan: Government invites public comments regarding transfer pricing amendments

March 18, 2022

On 16 March 2022, the State Revenue Committee announced that they opened a public consultation on a draft bill to amend transfer pricing rules. The deadline for this public comments is 8 April 2022. The draft Bill contained the following measures

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Portugal publishes new transfer pricing Legislation

December 10, 2021

On 26 November 2021, the Portuguese Tax Administration (PTA) published Order No. 268/2021, which replaces Regulation No. 1446-C / 2001 of December 21, 2001. The new regulation revises the rules for implementing the arm's length principle under

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Germany: MOF issues new guidance on transfer pricing

July 15, 2021

On 14 July 2021, the German Ministry of Finance (MoF) published a decree providing updated administrative principles on transfer Pricing. The new decree replaces several decrees that were passed in the past at transfer prices, in particular the

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Paraguay introduces new guidance on TP law

January 26, 2021

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

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Turkey publishes transfer pricing General Communiqué No. 4

September 24, 2020

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

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Germany: Federal Ministry of Finance publishes a draft law with significant changes to TP rules

December 25, 2019

On 10 December 2019, Germany published a draft law implementing EU anti-tax avoidance directive. The Draft Law includes significant changes to the German transfer pricing rules. The following proposed changes have been taken place under the

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Portugal publishes changes to various Tax Codes

September 23, 2019

On 18 September 2019, the Portuguese Government officially published the Law no.119/2019. The new law has changed the following provisions: Corporate income tax: The procedure whereby non-resident companies may waive all or part of the

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Lithuania further changes TP documentation rules

August 21, 2019

On 12 August 2019, the tax authorities released the new transfer pricing (TP) rules, which will apply from 2019, in addition to the previously announced new TP rules. The tax authorities also include the following TP measures: Abolishing the

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Portugal approves amendments to the TP rules

July 28, 2019

On 19 July 2019, the Portuguese parliament approved Law No. 180/2019, which includes amendments to the country's transfer pricing (TP) rules. The new law changes the following rules: Abolishing the hierarchy in the selection of the transfer

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Canada: CRA publishes 2017 APA Program Report

July 17, 2018

The Canada Revenue Agency (CRA) has published an annual report on its APA program since the 2001 to 2002 fiscal year. Since 2016, the annual report has been based on a calendar year, whereas the previous annual reports were based on a fiscal year.

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Colombia: Tax reform 2016 and Transfer Pricing Updates

February 16, 2017

In accordance with law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, introduces the following main changes to the transfer pricing regime. According to article 260-3 of the Tax Code (TC), as amended by the tax

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Peru :Amendments to Transfer Pricing rules

January 10, 2017

In Peru, Law Decree No. 1312 was published on 31 December 2016. The Decree amended the existing Transfer pricing reporting requirement by accepting the proposed changes by the Organization for Economic Cooperation and Development (OECD) within the

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Spain: Modified legislation on transfer pricing published

December 22, 2014

On 28 November 2014, Laws 26/2014 and 27/2014, which modify the most important Spanish tax laws were published in the Spanish Official Gazette. This new legislation will generally come into force on 1 January 2015. This new legislation modified in

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