Germany Suspends APA Negotiations with China
The German Federal Central Tax Office (BZSt) recently published a notice announcing that bilateral advance pricing agreement (APA) negotiations with China are suspended as of July 2025 because of difficulties in reaching the negotiations’ objectives. The BZSt – Germany’s competent authority for APA negotiations – will not initiate any new proceedings (including for APA renewals) until further notice. However, bilateral APA negotiations already underway are not affected by the suspension.
OECD Publishes Second Batch of Updated Transfer Pricing Country Profiles, Includes New Insights on Hard-to-Value Intangibles and Simplified Distribution Rules
The OECD on July 22 released a new batch of 12 updated transfer pricing country profiles, reflecting the current transfer pricing legislation and practices in
- Austria
- Belgium
- Canada
- Ireland
- Latvia
- Lithuania
- Mexico
- The Netherlands
- New Zealand
- Singapore
- South Africa
- Spain.
The OECD is releasing updates to the transfer pricing country profiles in batches throughout 2025. With this second batch, following the first update in May, the total number of jurisdictions covered now stands at 78.
Moldova Amends Transfer Pricing File and Information Submission Requirements
Moldova’s Law No. 187 of 10 June 2025 amends the requirements regarding the submission of the transfer pricing local file and other transfer pricing information.Law No. 187, which entered into force on 18 July 2025, provides that the transfer pricing file for 2024 needs to be submitted only at the request of the tax authorities, within 120 days of the request, and no penalties will be imposed for filing after the prior deadline of six months after the end of the year. Moreover, the deadline to file transfer pricing information is the 25th day of the sixth month after the end of the fiscal year.
The controlled transaction threshold to file transfer pricing information and submit the transfer pricing file upon request is MDL 20 million.
Mauritius Enacts Mandatory Transfer Pricing Documentation Measures
Mauritius’ Finance Act 2025 introduces, for the first time, a requirement that taxpayers maintain documentation to support their transfer pricing positions.Mauritius’ tax regime already includes a provision for the application of the arm's length principle. Section 75 of the Income Tax Act 1995 generally requires companies to ensure that controlled transactions carried out in or from Mauritius are conducted at arm's length.
The Finance Act introduces a requirement for companies to maintain proper documentation in respect of related-party transactions. However, the act does not specify what constitutes "proper documentation." Additional information is expected to be provided through regulations.
OECD Issues Consultation on Transfer Pricing Framework for Copper
The OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) recently issued a document for public consultation that provides a framework to identify the primary economic factors that can influence the pricing of minerals using transfer pricing principles.Determining the Price of Minerals: A Transfer Pricing Framework for Copper is a toolkit aimed at policy makers and tax administrations in resource-rich developing countries where mining activity is being undertaken by multinational enterprises (MNEs). This toolkit builds on Determining the Price of Minerals: A Transfer Pricing Framework and applies its transfer pricing principles specifically to the pricing of copper.
According to the press release, the toolkit provides practical and meaningful guidance for developing countries to accurately delineate the transaction and price mineral sales on an arm’s length basis applicable to copper exports.
The OECD and IGF are seeking comments regarding the application and usability of the toolkit to ensure that they are fit for purpose and appropriately tailored to the needs and requirements of developing countries.
Comments must be submitted no later than 17 September 2025.