Aspect-Advisory

Enabling accountants, tax and legal advisors to serve the transfer pricing needs of their mid-tier corporate clients.

[Aspect-Advisory @AspectAdvisory]

🇱🇻Latvia: Beginning January 1, 2026, companies with total transactions exceeding €250,000 with related non-resident parties in the previous financial year must submit a controlled transactions report to the State Revenue Service (SRS).
#transferpricing

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OECD: a fourth batch of updated transfer pricing country profiles have been published this week:

Bosnia and Herzegovina
Brazil
Costa Rica
Croatia
Greece
Iceland
Korea
Norway

#transferpricing

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🇨🇾Cyprus: From the 2026 tax year onward, the annual thresholds for preparing a Cyprus transfer pricing Local File increase to €10m for financial transactions, €5m for goods transactions, and €2.5m for other categories of controlled transactions.
#transferpricing

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🇭🇺 Hungary: From 2026 -
- Local benchmarking now a mandatory legal requirement
- Reconciliation to statutory accounts required
- Changes to (DEMPE) requirements
- Mandatory benefit test
- Revised low value-added services rules
- Updated TP data-reporting
#transferpricing

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🇺🇸 US: The IRS is contemplating expanding draft regulations on a new, simplified transfer pricing method to include certain kinds of digital transactions, such as the distribution of copyrighted articles, an agency official said Thursday.
#transferpricing

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🇨🇷 Costa Rica: Gazette Resolution October 2025 establishes new deadlines for filing the transfer pricing information return:

FY 2024: No later than March 31, 2026.
FY 2025: No later than June 30, 2026, regardless of fiscal year.

Must be submitted through the TRIBU-CR system.

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🇸🇬 Singapore: The Simplified and Streamlined Approach for Baseline Marketing and Distribution Activities will be implemented on a pilot basis from 1 Jan 2026 -31 Dec 2028.
#transferpricing

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🇬🇧 UK: HMRC’s Guidelines for Compliance (GfC) were amended 19 Dec 2025 including:
- A new section 2.2.8 was added covering value chain analysis
- A new section 3.8 was added covering risks specific to offshore procurement hubs
#transferpricing

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🇧🇪 Belgium: 7 December 2025 Royal Decree - taxpayers will now not be required to append their transfer pricing studies to Form 275 LF. 🎉

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China - Annual APA Update: As of 2024, among the signed APAs, the TNMM is the most frequently used method, having been used 328 times and accounting for 83.9% of all transfer pricing methods adopted.

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OECD: 19 Nov 2025- released 2025 update to the OECD Model Tax Convention includes new guidance on cross-border remote work and transfer pricing. These changes reflect evolving global mobility patterns and the increasing importance of digital work arrangements.
#transferpricing

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🇦🇷Argentina: The minimum thresholds for transfer pricing annual filings have been increased, now set at ARS500m for transactions with independent parties and ARS150m for transactions with related parties or those in low-tax jurisdictions.

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🇸🇰Slovakia: MoF issued updated guidelines on transfer pricing documentation.
The updated guidelines expand the scope of information to be reported to include the exact type of transaction, name of the counterparty, country of the counterparty's residence, and transaction value.

[Aspect-Advisory @AspectAdvisory]

🇫🇷France: Announced it will not apply Amount B under Pillar One domestically, but will accept its application in covered jurisdictions with tax treaties .

Covered jurisdictions are generally low/middle-income Inclusive Framework jurisdictions, excluding EU, OECD and G20 members.

[Aspect-Advisory @AspectAdvisory]

A UN committee is gauging support for including mechanisms for resolving transfer pricing disputes in a global tax treaty.
The treaty’s top negotiators proposed creating a UN-managed transfer pricing database or pooling country resources to buy commercially available databases.

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OECD: Oct. 22 - released a new batch of updated transfer pricing country profiles, to reflect the current transfer pricing legislation and practices of 25 jurisdictions as of October 2025.

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Czech Republic: Aug 2025 judgement- the Supreme Administrative Court held that interest on a loan arising in the context of a corporate group’s internal restructuring was not deductible as the restructuring was primarily motivated by tax avoidance and lacked economic substance.

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European Commission - EU member states have not made any changes to the list of non-cooperative tax jurisdictions (“blacklist”), which currently comprises American Samoa, Anguilla, Fiji, Guam, Palau, Panama, Russia, Samoa, Trinidad and Tobago, U.S. Virgin Islands, Vanuatu.

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OECD: planning to release a discussion draft to address the benefits test for intragroup services, the interaction of intangibles and internal services and the application of TP methods. The OECD also plans to discuss high-value-added services such as cloud computing.