Romania: ANAF approves updated transfer pricing rules to prevent tax disputes, align with OECD standards
Romania's Ministry of Finance and the National Agency for Fiscal Administration (ANAF) announced, on 30 June 2026, that they have introduced revised transfer pricing regulations designed to bring greater clarity and consistency to how multinational
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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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US: IRS revives controversial transfer pricing rule after decades of dormancy
The US Internal Revenue Service (IRS) is dusting off a 40-year-old tax provision that could dramatically reshape how multinational companies price transactions involving intellectual property, raising concerns among international tax practitioners
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Ecuador rejects OECD Pillar One Amount B safe harbour in new SRI circular
Ecuador’s Internal Revenue Service (SRI) has clarified that the OECD’s Pillar One – Amount B framework has not been adopted in the country, reaffirming that taxpayers must continue to apply existing domestic transfer pricing rules to routine
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UN Tax Committee Discusses Transfer Pricing
On 24 March 2026 the UN Committee of Experts on International Cooperation in Tax Matters discussed the workstreams for transfer pricing during the current mandate of the Committee. The subcommittee on transfer pricing presented its planned
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European Commission unveils 2026 work programme, signalling withdrawal of key tax proposals
EU unveiled 2026 plan on 21 October 2025 to boost sovereignty, security, and competitiveness. The European Commission has presented its 2026 work programme, outlining a series of initiatives aimed at strengthening Europe’s sovereignty,
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UN Tax Committee progresses on extractives, digital tax, transfer pricing initiatives
The UN Tax Committee reviewed proposals to establish new workstreams on extractive industries, digital economy, and transfer pricing—aiming to enhance guidance on critical minerals valuation, digital services and remote work taxation, and transfer
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OECD publishes the third batch of updated transfer pricing country profiles
The OECD has published updated transfer pricing country profiles for 25 jurisdictions, adding new profiles for Cabo Verde, Guatemala, Thailand, the UAE, and Zambia. The OECD has released a new batch of updated transfer pricing country profiles on
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Poland: MoF announces measures to combat aggressive transfer pricing strategies
The new measures assist the National Tax Administration in detecting and countering large corporations that evade or underreport their income tax. Poland’s Ministry of Finance has announced two new measures on 19 August 2025, to tackle
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India: Lower house approves higher standard deductions, pension exemptions, incentives for Saudi investment funds
Lok Sabha approves Taxation Laws (Amendment) Bill 2025, proposing higher standard deductions, pension exemptions, and incentives for Saudi investment funds. The Lok Sabha, India’s Lower House of Parliament approved the Taxation Laws (Amendment)
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Malaysia updates transfer pricing audit framework for 2025
IRBM revises penalty and surcharge rules in the updated guidelines. The Inland Revenue Board of Malaysia (IRBM) has issued the Malaysia Transfer Pricing Tax Audit Framework 2025 on 31 July 2025, replacing the previous Transfer Pricing Tax Audit
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Japan issues FAQs on foreign SSA application amid non-adoption
Japan’s NTA clarifies tax treatment for foreign SSA adoption, reaffirming the use of existing transfer pricing rules. Japan’s National Tax Agency (NTA) issued FAQs addressing the Simplified and Streamlined Approach (SSA) on 30 June 2025, also
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Malta launches 2025 electronic corporate tax return
Malta’s Commissioner for Revenue has made the 2025 electronic corporate income tax return available online, introducing changes related to transfer pricing and new attachments for various tax credits. Malta’s Commissioner for Revenue has
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Denmark proposes tax reform to align with OECD guidelines and simplify transfer pricing rules
The Danish Minister of Taxation introduced Bill L 194 to align with the OECD’s Minimum Tax Guidelines and ease transfer pricing (TP) documentation on 9 April 2025. The Bill aims to implement OECD administrative guidance under Pillar Two,
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Russia mandates transfer pricing method in controlled transaction notifications
Russia's Federal Tax Service (FTS) issued Letter No. ШЮ-4-13/2827@ on 13 March 2025 about the notification of controlled transactions. It clarifies that from 2024, taxpayers must disclose the transfer pricing method used to justify the market
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Austria updates transfer pricing guidelines, aligns with OECD standards
The Austrian Ministry of Finance published a decree (BMF decree of 11.03.2025, 2025-0.159.492, BMF-AV No. 33/2025) on 11 March 2025, updating the Austrian Transfer Pricing Guidelines 2021 (Austrian Guidelines). This update aligns the guidelines
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Vietnam updates regulations on related-party transactions, transfer pricingÂ
The Vietnam government has issued Decree No. 20/2025/ND-CP amending Decree No. 132/2020/ND-CP on transfer pricing on 10 February 2025, addressing the treatment of lenders or guarantors as related parties. A borrowing or guaranteed enterprise is
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Israel clarifies CbC reporting rules for MNEs
The Israel Tax Authority (ITA) issued Income Tax Circular No. 1/2025 on 11 February 2025, which clarifies amendments to the Income Tax Ordinance. The amendments pertain to transfer pricing and country-by-country (CbC) reporting requirements. The
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