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The knowledge hub · Country guides

Transfer pricing, country by country

Practitioner-built guides to transfer pricing and international tax rules — documentation thresholds, penalties, dispute resolution and what’s changing — each verified against primary sources and re-verified every year, with the date on the page.

Simple World Map Author: Al MacDonald Editor: Fritz Lekschas License: CC BY-SA 3.0 ID: ISO 3166-1 or "_[a-zA-Z]" if an ISO code is not available
Guide available — click a country to open it
Published guides

Start with your jurisdiction

Albania

Transfer pricing in Albania was rewritten with effect from 1 January 2024: Law no. 29/2023 and…

Verified Aug 2026

Angola

Transfer pricing in Angola runs on a single 2013 decree: three permitted methods, one…

Verified Aug 2026

Argentina

A practitioner's guide to transfer pricing in Argentina: the article 17 arm's length regime, ARCA's…

Verified Aug 2026

Armenia

Transfer pricing in Armenia runs on domestic law rather than an OECD country profile: Chapter 73 of the…

Verified Aug 2026

Australia

Transfer pricing in Australia combines a statute hard-wired to the 2022 OECD Guidelines with the world's…

Verified Aug 2026

Austria

Transfer pricing in Austria turns on a single statutory valuation rule — § 6 Z 6 EStG 1988 — read…

Verified Aug 2026

Azerbaijan

A practitioner's guide to transfer pricing in Azerbaijan — Article 14-1 of the Tax Code, the mandatory…

Verified Aug 2026

Belgium

A practitioner's guide to transfer pricing in Belgium — the arm's length rule in Article 185, §2 CIR 92,…

Verified Aug 2026

Bosnia and Herzegovina

Transfer pricing in Bosnia and Herzegovina is not one regime but three — the Federation, Republika…

Verified Aug 2026

Botswana

Transfer pricing in Botswana was rebuilt on 1 July 2026 — a brand-new Income Tax Act, a new set of…

Verified Aug 2026

Brazil

Transfer pricing in Brazil after Law 14,596/2023: the arm's length principle in domestic law,…

Verified Aug 2026

Bulgaria

Transfer pricing in Bulgaria has been rebuilt for 2026: Ordinance No. H-3 gives the OECD Guidelines…

Verified Aug 2026

Cabo Verde

A practitioner's guide to transfer pricing in Cabo Verde: the arm's length rule in Article 65 CIRPC and…

Verified Aug 2026

Canada

Transfer pricing in Canada was rewritten for 2026: section 247 of the Income Tax Act now codifies…

Verified Aug 2026

Chile

A practitioner's guide to transfer pricing in Chile — Article 41 E as rewritten by Law 21.713, the SII's…

Verified Aug 2026

China

Transfer pricing in China, explained by practitioners: the Enterprise Income Tax Law arm's length rule,…

Verified Aug 2026

Colombia

Transfer pricing in Colombia, explained by practitioners: how DIAN applies articles 260-1 to 260-11 of…

Verified Aug 2026

Costa Rica

A practitioner's guide to transfer pricing in Costa Rica — the arm's length rule in article 81 bis, the…

Verified Aug 2026

Croatia

Transfer pricing in Croatia after the 2025-2026 reforms: Article 13 of the Profit Tax Act, the rewritten…

Verified Aug 2026

Cyprus

A practitioner's guide to transfer pricing in Cyprus: Article 33 of the Income Tax Law, the 2026…

Verified Aug 2026

Czech Republic

A practitioner's guide to transfer pricing in the Czech Republic: how Section 23(7) of the Income Taxes…

Verified Aug 2026

Denmark

Transfer pricing in Denmark: a practitioner's guide to ligningsloven § 2, the 60-day mandatory…

Verified Aug 2026

Dominican Republic

A practitioner's guide to transfer pricing in the Dominican Republic: the Article 281 arm's length rule,…

Verified Aug 2026

Egypt

A practitioner's guide to transfer pricing in Egypt: Article 30, the 2018 Egyptian Transfer Pricing…

Verified Aug 2026

Estonia

Transfer pricing in Estonia turns on a single charging rule, a distribution-based 22/78 cost of…

Verified Aug 2026

Finland

A practitioner's guide to transfer pricing in Finland: the section 31 arm's length rule, Verohallinto's…

Verified Aug 2026

France

Transfer pricing in France, mapped end to end: Article 57 CGI, the EUR 150 million documentation regime,…

Verified Aug 2026

Georgia

A practitioner's guide to transfer pricing in Georgia: the Chapter XVII arm's length rules, the Revenue…

Verified Aug 2026

Germany

A practitioner's guide to transfer pricing in Germany — § 1 AStG and the 2024 administrative principles,…

Verified Aug 2026

Ghana

Transfer pricing in Ghana runs on Act 896 and the 2020 Regulations (L.I. 2412) — a BEPS-styled regime…

Verified Aug 2026

Greece

Transfer pricing in Greece runs on Article 50 of the Income Tax Code and tight AADE compliance mechanics…

Verified Aug 2026

Guatemala

A practitioner's guide to transfer pricing in Guatemala: SAT's arm's length regime under Decree 10-2012,…

Verified Aug 2026

Honduras

Transfer pricing in Honduras, mapped for practitioners: the arm's length rules under Decreto 232-2011,…

Verified Aug 2026

Hong Kong

A practitioner's guide to transfer pricing in Hong Kong — Part 8AA of the Inland Revenue Ordinance, the…

Verified Aug 2026

Hungary

Transfer pricing in Hungary from 2026: the arm's length rules in the Corporate Tax Act, the new NGM…

Verified Aug 2026

Iceland

Transfer pricing in Iceland rests on three paragraphs of the Income Tax Act and the OECD Guidelines they…

Verified Aug 2026

India

Transfer pricing in India runs on its own statute, its own range and one of the world's toughest…

Verified Aug 2026

Indonesia

A practitioner's guide to transfer pricing in Indonesia: the arm's length rules consolidated in PMK…

Verified Aug 2026

Ireland

A practitioner's guide to transfer pricing in Ireland — Part 35A of the Taxes Consolidation Act 1997,…

Verified Aug 2026

Israel

Transfer pricing in Israel runs on one charging provision, a genuine method hierarchy and a…

Verified Aug 2026

Italy

Transfer pricing in Italy turns on Article 110(7) TUIR, the Ministerial Decree of 14 May 2018 and an…

Verified Aug 2026

Jamaica

A practitioner's guide to transfer pricing in Jamaica: the Eighth Schedule method hierarchy, the J$500…

Verified Aug 2026

Japan

A practitioner's guide to transfer pricing in Japan: the arm's length rule in Article 66-4 of the Act on…

Verified Aug 2026

Jordan

Transfer pricing in Jordan runs on the "fair price" principle: Regulation No. 40 of 2021, a JOD 500,000…

Verified Aug 2026

Kazakhstan

Transfer pricing in Kazakhstan runs on a standalone 2008 statute rather than the OECD Guidelines: this…

Verified Aug 2026

Kenya

Transfer pricing in Kenya, mapped for practitioners: the Section 18(3) arm's length rule and the 2006…

Verified Aug 2026

Kosovo

Transfer pricing in Kosovo runs on a single statutory article and a 2017 Administrative Instruction:…

Verified Aug 2026

Latvia

Transfer pricing in Latvia runs through a distributed-profit tax system that prices every adjustment at…

Verified Aug 2026

Liberia

A practitioner's guide to transfer pricing in Liberia: the 2016 Regulations and Practice Note, the LRA's…

Verified Aug 2026

Liechtenstein

A practitioner's guide to transfer pricing in Liechtenstein: the arm's length rule in Article 49 of the…

Verified Aug 2026

Lithuania

Transfer pricing in Lithuania runs on Article 40 of the CIT Law and the OECD-aligned 1K-123 TP Rules —…

Verified Aug 2026

Luxembourg

Transfer pricing in Luxembourg rests on two articles of the income tax law and one financing circular —…

Verified Aug 2026

Malaysia

A practitioner's guide to transfer pricing in Malaysia — section 140A, the Transfer Pricing Rules 2023,…

Verified Aug 2026

Maldives

A practitioner's guide to transfer pricing in the Maldives: MIRA's arm's length rule under the Income…

Verified Aug 2026

Malta

Malta transfer pricing, from first principles: how the Transfer Pricing Rules (S.L. 123.207) have…

Verified Aug 2026

Mauritius

Transfer pricing in Mauritius has shifted from a single arm's length provision to a documented regime:…

Verified Aug 2026

Mexico

Transfer pricing in Mexico, current to 2026: the arm's length rules in the Ley del Impuesto sobre la…

Verified Aug 2026

Moldova

Transfer pricing in Moldova went from concept to enforcement in three years: this guide sets out Tax…

Verified Aug 2026

Mongolia

Transfer pricing in Mongolia, decoded: a four-tier documentation regime, turnover-linked penalties,…

Verified Aug 2026

Montenegro

Transfer pricing in Montenegro, from the arm's length rule in Article 38a to the EUR 75,000…

Verified Aug 2026

Mozambique

Transfer pricing in Mozambique runs on a single 2017 decree with hard-coded arithmetic, a MZN 2,500,000…

Verified Aug 2026

Namibia

Transfer pricing in Namibia rests on a single statutory provision — section 95A of the Income Tax Act —…

Verified Aug 2026

Netherlands

A practitioner's guide to transfer pricing in the Netherlands — article 8b, the Verrekenprijsbesluit…

Verified Aug 2026

New Zealand

A practitioner's guide to transfer pricing in New Zealand — subpart GC of the Income Tax Act 2007, the…

Verified Aug 2026

Nigeria

Transfer pricing in Nigeria: a practitioner's guide to the 2018 Regulations, FIRS-to-NRS enforcement,…

Verified Aug 2026

North Macedonia

Transfer pricing in North Macedonia is a narrow, cross-border-only regime: the Law on Profit Tax and the…

Verified Aug 2026

Norway

Transfer pricing in Norway rests on a single statutory provision — skatteloven § 13-1 — a dynamic…

Verified Aug 2026

Pakistan

A practitioner's guide to transfer pricing in Pakistan — section 108 of the Income Tax Ordinance 2001,…

Verified Aug 2026

Panama

A practitioner's guide to transfer pricing in Panama: the Código Fiscal Chapter IX rules, the DGI's Form…

Verified Aug 2026

Papua New Guinea

Transfer pricing in Papua New Guinea was rebuilt on 1 January 2026, when sections 73 and 74 of the…

Verified Aug 2026

Paraguay

A practitioner's guide to transfer pricing in Paraguay: the Principio de Independencia in articles 35 to…

Verified Aug 2026

Peru

Transfer pricing in Peru: how SUNAT applies Article 32-A of the Income Tax Law — methods, the…

Verified Aug 2026

Philippines

A practitioner's guide to transfer pricing in the Philippines — Section 50 of the Tax Code, Revenue…

Verified Aug 2026

Poland

A practitioner's guide to transfer pricing in Poland: the arm's length rules in Chapter 1a of the CIT…

Verified Aug 2026

Portugal

A practitioner's guide to transfer pricing in Portugal — Article 63 of the Corporate Income Tax Code,…

Verified Aug 2026

Qatar

Transfer pricing in Qatar is built from domestic law rather than an OECD country profile: Articles 52 to…

Verified Aug 2026

Romania

Transfer pricing in Romania binds the OECD Guidelines directly into statute — with mandatory median…

Verified Aug 2026

Russia

A practitioner's guide to transfer pricing in Russia: how Section V.1 of the Tax Code, the Federal Tax…

Verified Aug 2026

Rwanda

A practitioner's guide to transfer pricing in Rwanda under Ministerial Order Nº 003/26/10/TC of 29 April…

Verified Aug 2026

Saudi Arabia

A practitioner's guide to transfer pricing in Saudi Arabia — ZATCA's Transfer Pricing Bylaws, the arm's…

Verified Aug 2026

Senegal

Transfer pricing in Senegal, from the article 17 arm's length rule to DGID documentation,…

Verified Aug 2026

Serbia

Transfer pricing in Serbia runs on domestic law rather than an OECD country profile: a single composite…

Verified Aug 2026

Seychelles

Transfer pricing in Seychelles is no longer a single arm's length sentence: this guide sets out the…

Verified Aug 2026

Singapore

A practitioner's guide to transfer pricing in Singapore — the section 34D arm's length rule, IRAS…

Verified Aug 2026

Slovakia

Transfer pricing in Slovakia combines a fully codified arm's length rule — complete with a statutory…

Verified Aug 2026

Slovenia

Transfer pricing in Slovenia pairs a fully OECD-aligned statute (ZDDPO-2 Articles 16–17) with a…

Verified Aug 2026

South Africa

Transfer pricing in South Africa: section 31, SARS documentation thresholds, escalating enforcement and…

Verified Aug 2026

South Korea

A practitioner's guide to transfer pricing in South Korea — the Adjustment of International Taxes Act,…

Verified Aug 2026

Spain

A practitioner's guide to transfer pricing in Spain — article 18 LIS and its regulation, AEAT…

Verified Aug 2026

Sri Lanka

A practitioner's guide to transfer pricing in Sri Lanka: the arm's length rules in the Inland Revenue…

Verified Aug 2026

Sweden

A practitioner's guide to transfer pricing in Sweden: the correction rule in the Income Tax Act,…

Verified Aug 2026

Switzerland

Transfer pricing in Switzerland is governed by no transfer pricing statute at all — the arm's length…

Verified Aug 2026

Taiwan

A practitioner's guide to transfer pricing in Taiwan: Article 43-1 of the Income Tax Act, the Ministry…

Verified Aug 2026

Tanzania

Transfer pricing in Tanzania: a practitioner's guide to section 33 of the Income Tax Act, the 2018…

Verified Aug 2026

Thailand

A practitioner's guide to transfer pricing in Thailand: the Revenue Code rules and Director-General…

Verified Aug 2026

Tunisia

Transfer pricing in Tunisia runs on a thin statute and thick administrative guidance: Article 48 septies…

Verified Aug 2026

Türkiye

A practitioner's guide to transfer pricing in Türkiye — the disguised profit distribution regime under…

Verified Aug 2026

Uganda

A practitioner's guide to transfer pricing in Uganda — how the Uganda Revenue Authority applies the…

Verified Aug 2026

Ukraine

A practitioner's guide to transfer pricing in Ukraine: Article 39 of the Tax Code, the UAH 150 million…

Verified Aug 2026

United Arab Emirates

A practitioner's guide to transfer pricing in the United Arab Emirates: the arm's length rules in…

Verified Aug 2026

United Kingdom

Transfer pricing in the United Kingdom is entering its most consequential reset in a generation: Finance…

Verified Aug 2026

United States

Transfer pricing in the United States runs on section 482, the best method rule and penalty-driven…

Verified Aug 2026

Uruguay

A practitioner's guide to transfer pricing in Uruguay: the Chapter VIII arm's length regime, DGI's…

Verified Aug 2026

Vietnam

Transfer pricing in Vietnam was rebuilt on 1 July 2026: Decree 255/2026/ND-CP, a 35th–75th percentile…

Verified Aug 2026

Zambia

Transfer pricing in Zambia combines an OECD-consistent statute with a mandatory metals reference price,…

Verified Aug 2026

Zimbabwe

Zimbabwe transfer pricing reaches every related-party transaction — domestic as well as cross-border,…

Verified Aug 2026

Guides that stay current

Most country transfer-pricing guides are written once and quietly left to age. Ours carry a public “last verified” date, are built from primary sources — national legislation, revenue-authority guidance and the OECD’s Transfer Pricing Country Profiles — and are re-verified on an annual cycle. Between verifications, our editorial pipeline tracks developments daily through the knowledge hub and the global case library.

Beyond the guides

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