Czech Republic updates jurisdictions list for MCAA-CRS, CbC report exchange
The Czech Ministry of Finance issued Financial Bulletin No. 1/2025 on 9 January 2025 which updates the list of jurisdictions participating in exchanges under the Multilateral Competent Authority Agreement (MCAA) on automatic financial account
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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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Germany: Ministry of Finance updates transfer pricing guidelines for 2024
The German Ministry of Finance published BMF Letter No. 2024/1078709 on 12 December 2024, updating the guide on transfer pricing for 2024. The new guidelines clarify key aspects of transfer pricing which includes income correction and
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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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Bangladesh: NBR to conduct first transfer pricing audit to tackle tax evasion
Bangladesh tax authority National Board of Revenue (NBR) announced that it will conduct its first transfer pricing audit of multinational companies (MNCs) operating in the country. Bangladesh first introduced transfer pricing provisions in the
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US: IRS and Treasury Plan to Issue Guidance on Streamlined Approach to Baseline Distribution Activities
In the IRS and Treasury Priority Guidance Plan for 2024/25, issued on 3 October 2024, there is a plan for a new section 482 guidance project to provide guidance for taxpayers consistent with Amount B of Pillar One. The OECD Amount B Guidance
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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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UK considers changes to transfer pricing, advance pricing rules in Autumn Budget 2024
UK’s Chancellor of the Exchequer Rachel Reeves, in her Autumn Budget 2025 announcement on 30 October 2024, said her government is considering modernising the country’s transfer pricing rules and the advance pricing agreement system. Reeves
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Germany passes Fourth Bureaucracy Relief Act, cuts accounting document retention and updates transfer pricing rules
Germany’s Federal Council (Bundesrat) passed the Fourth Bureaucracy Relief Act on 18 October 2024 following its approval by the Bundestag (lower house of parliament) on 26 September 2024. One key aspect of the Act is that it reduces
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Ukraine clarifies corporate tax rules for German entities under transfer pricing provisions
The Ministry of Finance of Ukraine has issued a clarification concerning the corporate taxes of the Federal Republic of Germany and their relevance to Ukrainian tax law, particularly in the context of transfer pricing regulations on 30 September
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Hungary releases 2024 audit plan with targets transfer pricing
Hungary's National Tax and Customs Administration (NAV) has released its audit strategy for the 2024 calendar year, highlighting transfer pricing as its key area of focus among other sectors. The new transfer pricing reporting obligation introduced
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Australia initiates consultation on transfer pricing rules for petroleum resource rent tax
On 18 March 2024, the Australian Treasury announced that it initiated a public consultation on Petroleum Resource Rent Tax transfer pricing regulations. The deadline for receiving comments on the matter is set at 12 April 2024. In the 2023 24
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Norway issues new guidance on transfer pricing reporting requirements for 2024
On 8 February 2024, the Norwegian Tax Administration (NTA) released a guidance regarding the amendments of the transfer pricing disclosures in tax returns for organizations, due by 31 May 2024 for the fiscal year ending in 2023. The guidance
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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
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