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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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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Kazakhstan expands transfer pricing monitoring for cross-border transactions
Kazakhstan has expanded its list of goods, works, and services subject to transfer pricing monitoring. The updated list includes new items such as coal, lignite, hydrogen, polymers, raw aluminium, iron and steel products, various grains like rice
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Malaysia updates transfer pricing guidelines, audit framework
Malaysia’s Inland Revenue Board (IRB) has updated transfer pricing guidelines and transfer pricing audit framework. The transfer pricing guidelines have been updated in accordance with the amendments made to section 140A, the introduction of
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India extends transfer pricing safe harbor rules to FY 2024-25, updates filing deadline for international transactions
India's Central Board of Direct Taxes (CBDT) has released Notification No. 124/2024 outlining the Income Tax (Tenth Amendment) Rules, 2024 on 29 November 2024. According to the amendment, the transfer pricing safe harbor rules under Rule 10TD of
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Bosnia and Herzegovina updates transfer pricing rules
The Ministry of Finance of the Federation of Bosnia and Herzegovina (FBiH) has announced amendments to the Transfer Pricing Rulebook regarding Master File and Country-by-Country (CbC) reporting requirements. These changes were published in the
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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Indonesia releases revised guidelines for transfer pricing
On 29 December 2023, Indonesia’s Minister of Finance (MoF) released the revised transfer pricing guidelines Regulation No. 172 of 2023 (PMK-172). The updated and consolidated transfer pricing regulations in various chapters, such as: General
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Russia announces transfer pricing changes from 2024
On 27 November 2023, Russia issued Law No. 539-FZ in the Official Gazette, which outlines several amendments to the country’s transfer pricing regime. A summary of several key changes is outlined below: Secondary adjustments treated as
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Ecuador releases updated technical sheet for standardizing the analysis of transfer pricing
On 22 November 2023, the Ecuadorian Tax Authority released a new edition of the technical sheet for the standardization of transfer pricing analysis, effective for fiscal year 2023. This updated document introduces significant changes to filing
See MoreAustralia introduces a bill to expand definition of SGE
On 12 February 2020, the Treasury Laws Amendment (2020 Measures No. 1) Bill 2020 was submitted in the Australian House of Representatives. This bill contains two measures that maintain the integrity and efficiency of Australia's tax
See MoreSaudi Arabia: General Authority of Zakat and Tax (GAZT) publishes draft transfer pricing law
On 10 December 2018, General Authority of Zakat and Tax (GAZT) released draft transfer pricing regulations (TPBy-laws) for public consultation. The regulations broadly follow international standards, including the arm’s-length principle and
See MorePoland: President signed an act including amendment of TP measures effective in 2019
On 14 November 2018, President of Poland signed an act including amendment of transfer pricing measures effective in 2019. The new laws repeal the Article 9a of the CIT Act regarding transfer pricing, which is being replaced by Chapter 1a,
See MoreUkraine: Draft law on implementation of BEPS provisions
On 24 October 2018, Ukraine published a draft law on the implementation of some of the recommendation of the OECD/G20 reports on Base Erosion and Profit Shifting (BEPS). The draft law was developed by the Finance Ministry and National Bank supported
See MoreIreland announces Budget for 2019
On 9 October 2018, the Budget for 2019 was presented to Parliament by the Minister of Finance. The summary of 2019 Budget measures are following: Corporate Tax Film Relief The scheme provides relief in the form of a corporation tax credit related to
See MoreIreland announces corporation tax roadmap
On 5 September 2018, the Minister for Finance and Public Expenditure & Reform, Paschal Donohoe T.D., has published Ireland’s Corporation Tax Roadmap. The Roadmap takes stock of the changing international tax environment, outlines the actions
See MoreUS: Appeal Court Rules in Favour of IRS in Medtronic Case
On 16 August 2018 a US federal appeals court vacated and remanded a 2016 decision by the Tax Court in the case of Medtronic v. Commissioner. The Court of Appeals ruled that in its original decision in favour of Medtronic the Tax Court did not
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