- Australia: On 22 April 2026, the Australian Taxation Office released updated guidance on transfer pricing issues related to inbound distribution arrangements. The guidance clarifies its scope and the reportable tax position schedule by introducing a “white zone” for certain taxpayers. Taxpayers within the white zone—such as those with APAs or those that recently obtained high assurance for their transfer pricing—likely will be subject to a lower level of scrutiny. Inbound distribution arrangements are those where an Australian entity distributes goods acquired from related foreign entities for resale or distributes digital products or services linked to intellectual property owned by related foreign entities.
- Italy: In a decision issued on 7 May 2026, the Supreme Court clarified the situations in which domestic transfer pricing rules apply to intragroup transactions.
- Luxembourg: A circular issued on 13 April 2026 formally introduces the OECD Amount B simplified transfer pricing approach approach for certain marketing and distribution activities. The circular clarifies that Luxembourg will recognise outcomes where a covered jurisdiction has correctly applied Amount B and the tax authorities will not make transfer pricing adjustments.
- Malawi: Legislation that applies as from 15 April 2026 requires taxpayers that have received an audit notification with respect to transfer pricing and other related party arrangements to retain all relevant records and documentation until the audit is formally completed.
- Moldova: The tax authorities published a notice on 12 May 2026 announcing a transfer pricing information form in the Automated Information System that must be used by companies engaging in related party transactions with an aggregate annual value of MDL 20 million or more. The form must be submitted electronically for tax periods beginning in 2025.
- Niger: An order issued by the Ministry of Economy and Finance on 4 May 2026 establishes transfer pricing documentation requirements for MNE groups operating in the country, requiring both a master file and a local file. The documentation must be submitted by 30 April of each year and must be updated as of 31 December of each fiscal year.
- OECD: The OECD published a public consultation document on 1 June 2026 that would update Chapter VII (intragroup services) of the transfer pricing guidelines to better align the guidance on intragroup services and the foundational principles in other chapters of the guidelines. The consultation runs through 22 July 2026.
- Romania: The government is holding a consultation on proposed changes to the advance pricing agreement (APA) procedure. Proposed changes include allowing an APA request for up to five years, improving the APA procedure and requiring more detailed transfer pricing information for APAs. A separate consultation is being held on updates to the transfer pricing documentation rules in line with the 2022 OECD Transfer Pricing Guidelines.
- Rwanda: A Ministerial Order published 29 April 2026 updates and replaces the transfer pricing regulations to introduce new rules that allow taxpayers to conclude unilateral, bilateral and multilateral APAs with the tax administration, require a transfer pricing study and local and master files.
- Singapore: The Inland Revenue Authority of Singapore has released an updated version of the e-Tax Guide, Transfer Pricing Guidelines (Ninth Edition) to add an FAQ on share-based compensation.
