TPcases

Albania's transfer pricing legislation is set out in Articles 36–36/7 of Law No. 8438 (1998), supplemented by Ministry of Finance ...

Angola's transfer pricing rules are grounded in Corporate Income Tax Act No. 26/20, article 50, with related-party definitions under Presidential ...

Argentina's transfer pricing framework is governed by Income Tax Law N° 20,628, with the OECD Transfer Pricing Guidelines serving as ...

Australia's transfer pricing framework is governed by Subdivision 815-B of the Income Tax Assessment Act 1997, explicitly referencing the OECD ...

Austria's transfer pricing framework is grounded in Section 6(6) of the Income Tax Act and the Austrian Transfer Pricing Guidelines ...

Azerbaijan's transfer pricing framework is governed by Tax Code Article 13.2.65 and the 2017 Rules for Determining and Applying Transfer ...

Bahamas maintains a 0% corporate tax rate and has no formal transfer pricing legislation or tax treaties. It has signed ...

Bangladesh's transfer pricing framework is governed by Chapter XIA of the Income-tax Ordinance 1984, introduced by the Finance Act 2012 ...

Belgium regulates transfer pricing primarily under Article 185 §2 of the Belgian Income Tax Code 1992, with explicit reference to ...

Bermuda levies no corporate income tax and has no domestic transfer pricing legislation. It is widely used in multinational tax ...

Bosnia and Herzegovina applies transfer pricing rules through separate FBiH and RS rulebooks, with the arm's length principle codified under ...

Brazil overhauled its transfer pricing rules with Law No. 14,596/2023, introducing the arm's length principle and aligning with the OECD ...

Bulgaria's transfer pricing rules are governed by the Corporate Income Tax Act (CITA) and Ordinance No H-9, following OECD guidelines ...

Cabo Verde's transfer pricing framework is grounded in Article 65 of the Corporate Income Tax Code and Ministerial Order 75/2015, ...

Canada regulates transfer pricing under Section 247 of the Income Tax Act, RSC 1985, with the arm's length principle as ...

The Cayman Islands applies a 0% corporate income tax rate and has no domestic transfer pricing legislation. As a leading ...

Chile's transfer pricing framework is governed by Article 41 E of the Income Tax Law, supported by Circular No. 10 ...

China's transfer pricing framework is grounded in the Enterprise Income Tax Law, Chapter 6, Article 41, applying the arm's length ...

Colombia's transfer pricing framework is grounded in Tax Code Article 260-2, applying the arm's length principle. OECD Transfer Pricing Guidelines ...

Costa Rica's transfer pricing framework is grounded in Article 81 bis of the Income Tax Law, with related-party definitions under ...

Croatia's transfer pricing framework is based on Profit Tax Act, Article 13, introduced in 2004. The OECD Transfer Pricing Guidelines ...

Cyprus levies a flat 12.5% corporate tax rate and operates an IP box regime with an effective rate below 2.5% ...

The Czech Republic anchors its transfer pricing rules in Income Tax Act 586/1992, Section 23 para 7. OECD Transfer Pricing ...

Denmark's transfer pricing framework is governed by the Tax Assessment Act, Section 2, interpreted dynamically in line with the OECD ...

The Dominican Republic regulates transfer pricing under Article 281 of the Tax Code, requiring arm's length pricing for related-party transactions ...

Ecuador's transfer pricing rules, introduced in December 2004, are set out in the Ley de Régimen Tributario Interno and its ...

Egypt's transfer pricing framework is grounded in Article 30 of Income Tax Law No. 91 of 2005, with the 2018 ...

El Salvador's transfer pricing framework is set out in Tax Code Articles 62-A, 124-A, 125, and 199-A to 199-D, with ...

Estonia's transfer pricing framework is grounded in subsection 50(4) of the Income Tax Act and Transfer Pricing Regulation no. 53, ...

Ethiopia's transfer pricing framework is governed by Directive No. 981/2024, effective January 2024, replacing earlier 2015 and 2021 rules. The ...

The European Union oversees member states' tax rules through directives including ATAD, enforcing arm's length and anti-avoidance standards. The EU ...

Finland's transfer pricing framework is governed by Article 31 of the Assessment Procedure Act (VML), applying the arm's length principle ...

France's transfer pricing framework is based on Article 57 of the General Tax Code, with administrative doctrine expressly referencing the ...

Georgia's transfer pricing framework is governed by Tax Code Articles 126–129 and Finance Minister Decree #423 (2013), aligned with the ...

Germany's transfer pricing framework is governed by Section 1 of the External Tax Relations Act (Außensteuergesetz), incorporating the arm's length ...

Greece regulates transfer pricing under Income Tax Code L.4172/2013, Article 50, applying the arm's length principle consistently with OECD Transfer ...

Greenland regulates transfer pricing under Landstingslov nr. 12 af 2. november 2006, applying an arm's length standard to intercompany interest, ...

Guatemala's transfer pricing framework is established under Decree 10-2012, Article 54, applying the arm's length principle. OECD Guidelines carry no ...

Honduras governs transfer pricing through Decree No.232-2011 and Agreement No.027-2015, applying the arm's length principle with OECD Transfer Pricing Guidelines ...

Hong Kong applies transfer pricing rules under the Inland Revenue Ordinance, aligned with OECD Guidelines, with a standard profits tax ...

Hungary's transfer pricing framework is governed by Section 18 of Act LXXXI of 1996 on Corporate Tax and Dividend Tax, ...

Iceland's transfer pricing framework is anchored in Article 57 of Income Tax Act no. 90/2003, with documentation requirements governed by ...

India regulates transfer pricing under Sections 92 to 92F of the Income Tax Act 1961, applying the arm's length price ...

Indonesia's transfer pricing framework is governed by Income Tax Law No. 7 of 2021 and Minister of Finance Regulation PMK-172/2023, ...

Ireland's transfer pricing framework is governed by section 835C of the Taxes Consolidation Act 1997, as updated by Finance Act ...

The Isle of Man applies a 0% corporate tax rate, with limited exceptions for banks and large retailers taxed at ...

Israel regulates transfer pricing under Section 85A of the Income Tax Ordinance (1961), supported by the 2006 Market Conditions Regulations, ...

Italy's transfer pricing framework is governed by Article 110(7) of the TUIR and the Ministerial Decree of 14 May 2018, ...

Jamaica's transfer pricing framework is governed by Income Tax Act Section 17 and the Income Tax (Amendment) Act 2015, with ...

Japan's transfer pricing framework is governed by ASMT Article 66-4, requiring arm's length pricing in transactions with foreign related parties ...

Kazakhstan regulates transfer pricing through its dedicated Transfer Pricing Law, broadly aligned with OECD Guidelines. The corporate tax rate is ...

Kenya's transfer pricing framework is governed by the Income Tax Act Section 18(3) and Legal Notice No. 67 of 2006, ...

Korea's transfer pricing framework is governed by the Act on Adjustment of International Taxes (AAIT), enacted in 1996, and is ...

Kosovo's transfer pricing framework is governed by Article 28 of Law No. 06/L-105 and Administrative Instruction MF-02/2017, explicitly aligned with ...

Labuan is a low-tax, secrecy jurisdiction in Malaysia, serving as a gateway for Islamic finance in Asia. Offshore trading companies ...

Latvia applies the arm's length principle under Corporate Income Tax Law Section 4, with OECD Transfer Pricing Guidelines used as ...

Liberia's transfer pricing framework is set out in Section 3.2(b) of the Income Tax Transfer Pricing Regulations, applying the arm's ...

Liechtenstein's transfer pricing framework is grounded in Article 49 of the Tax Act and Article 31b of the Tax Ordinance, ...

Lithuania's transfer pricing framework is grounded in Article 40 of the Corporate Income Tax Law, with detailed rules updated in ...

Luxembourg's transfer pricing framework is governed by Articles 56 and 56bis of the LITL, incorporating the arm's length principle and ...

Malaysia regulates transfer pricing under Section 140A of the Income Tax Act 1967, supported by the Income Tax (Transfer Pricing) ...

Maldives transfer pricing is governed by the Income Tax Act (Law 25/2019) and Transfer Pricing Regulation 2020-R-43, drafted with reference ...

Malta introduced specific transfer pricing legislation via Legal Notice 284 of 2022, effective January 2024, with the arm's length principle ...

Mauritius has no dedicated transfer pricing legislation but applies the arm's length principle under section 75 of the Income Tax ...

Mexico's transfer pricing framework is governed by Articles 76 and 179 of the Mexican Income Tax Law, with explicit reference ...

New Zealand's transfer pricing rules are set out in sections GC 6–14 and GB 2 of the Income Tax Act ...

Nigeria's transfer pricing framework is governed by the Income Tax Transfer Pricing Regulations 2018 and Section 22(2)(b) of the Companies ...

Norway applies the arm's length principle under General Tax Act Section 13-1, with direct reference to the OECD Transfer Pricing ...

Pakistan's transfer pricing framework is grounded in Income Tax Ordinance 2001, Section 108, and Income Tax Rules 2002, Chapter VI, ...

Panama's transfer pricing framework is governed by Art. 762-A of the Código Fiscal, as amended by Law No. 33 of ...

Papua New Guinea's transfer pricing rules are governed by Division 15 of the Income Tax Act 1959, supported by Tax ...

Paraguay's transfer pricing framework is established under Law No. 6380/2019, effective January 2021, supported by Decree No. 4644/2020. Rules align ...

Peru's transfer pricing framework is established under Article 32-A of the Income Tax Law, referencing the arm's length principle and ...

The Philippines applies transfer pricing rules rooted in legislation dating to 1939, supplemented by Revenue Regulations No. 34-2020 on documentation ...

Poland regulates transfer pricing under Article 11c of the Corporate Income Tax Act and Article 23o of the Personal Income ...

Portugal regulates transfer pricing under Article 63 of the Corporate Income Tax Code, with Ministerial Order 268/2021 formally incorporating the ...

Puerto Rico's corporate tax combines an 18.5% normal tax with a graduated surtax. The jurisdiction has been used by US ...

Romania's transfer pricing framework is governed by Law no. 227/2015 and Order no. 442/2016, incorporating the OECD Transfer Pricing Guidelines ...

Russia regulates transfer pricing under Sections 105.1–105.17 of the Russian Tax Code, with the arm's length principle codified in Article ...

Saudi Arabia's transfer pricing framework is governed by the 2019 Transfer Pricing Bylaws, with the arm's length principle rooted in ...

Senegal's transfer pricing legislation is found in Article 17 of the General Tax Code, which references the OECD Transfer Pricing ...

Seychelles transfer pricing is governed by sections 4 and 54(1) of the Business Tax Act 2009, endorsing the arm's length ...

Singapore's transfer pricing framework is grounded in Section 34D of the Income Tax Act 1947 and the Transfer Pricing Documentation ...

Slovakia's transfer pricing framework is grounded in Income Tax Act Articles 17 and 18, applying the arm's length principle to ...

Slovenia's arm's length principle is codified in the Corporate Income Tax Act, Article 16, supplemented by the Rules on Transfer ...

South Africa regulates transfer pricing under Section 31 of the Income Tax Act 58 of 1962, supported by SARS Practice ...

Spain's transfer pricing framework is established under Corporate Income Tax Act Art.18 (Ley 27/2014), applying the arm's length principle with ...

Sri Lanka's transfer pricing framework is governed by Sections 76 and 77 of the Inland Revenue Act No. 24 of ...

Sweden regulates transfer pricing under Chapter 14 Section 19 of the Swedish Income Tax Act (1999:1229), applying the arm's length ...

Switzerland grounds transfer pricing in Article 58 of the Federal Law on Federal Direct Tax, with the OECD Transfer Pricing ...

Taiwan applies transfer pricing rules under the Income Tax Act, broadly aligned with OECD Guidelines. The corporate tax rate is ...

Tanzania's transfer pricing framework applies local guidelines consistent with UN and OECD Transfer Pricing Guidelines, under a 30% corporate tax ...

Thailand's transfer pricing framework is grounded in Section 71 bis of the Revenue Code and Ministerial Regulation No. 369 (B.E ...

The Netherlands codifies the arm's length principle in Article 8b of the Corporate Income Tax Act 1969, with OECD Transfer ...

Tunisia's transfer pricing framework is governed by Article 48 septies of the income and corporate tax code, revised under Finance ...

Türkiye regulates transfer pricing under Article 13 of Corporate Income Tax Law No. 5520, applying the arm's length principle with ...

Uganda's transfer pricing framework is governed by section 90(1) of the Income Tax Act, effective 1 July 2011, and is ...

Ukraine's transfer pricing framework is governed by Article 39 of the Tax Code, applying the arm's length principle as amended ...

The United Nations, through ECOSOC and its Committee of Experts, develops transfer pricing guidance including the UN Practical Manual on ...

The UAE's transfer pricing framework is established under Federal Decree-Law No. 47 of 2022, Articles 34–36, with a 9% corporate ...