BDO Transfer Pricing News

Introduction

The last weeks of 2025 saw a flurry of transfer pricing activity, as many jurisdictions tinkered with – and in some cases initiated major revamps – of their transfer pricing regimes, often as part of their annual budget processes. Canada, for example, announced measures that would modernise the transfer pricing rules, which were first enacted in 1997 and have not been subject to any significant change until now. The UK budget package, as expected, included several transfer pricing announcements related to the two transfer pricing consultations, one on legislative updates and another discussing future changes to documentation. Bulgaria’s Ministry of Finance published a new transfer pricing ordinance that entered into force on 1 January 2026 and is designed to fully align Bulgaria’s transfer pricing rules with the latest OECD transfer pricing guidelines. The Inland Revenue Authority of Singapore released the 8th edition of the Singapore Transfer Pricing Guidelines, introducing updates to Singapore transfer pricing compliance requirements, and importantly, enhanced international tax dispute resolution tools. Finally, Israel’s Ministry of Finance, the Israel Tax Authority (ITA) and the Israel Innovation Authority (IIA) unveiled an income tax circular that provides a comprehensive tax reform for the high-tech industry.

In judicial news, the Court of Justice of the European Union released an important decision settling an issue that has been a topic of discussion for some time in the EU: the VAT treatment of transfer pricing adjustments between related parties. The court ruled that transfer pricing adjustments are indeed subject to VAT, although it adopted a case-by-case approach in reaching its decision.

And on a topic that has not yet received much attention, we include an article from South Africa on the interaction of transfer pricing and artificial intelligence (AI). The traditional tools of the transfer pricing world were designed around human-led activities, particularly a framework for analysing the development, enhancement, maintenance, protection, and exploitation of intangibles (DEMPE). This article explores how AI is challenging conventional interpretations of intangible assets and how the DEMPE framework must adapt in the face of autonomous and semi-autonomous systems that are reshaping global value chains.