Ever since the adoption of the BEPS action plan, the signatory countries have been working on the adoption and implementation of the action plan in their double tax treaties, as well as in their national laws and regulations.

In recent years, we have observed increasing efforts by both the signatory and non-signatory jurisdictions in the adoption of transfer pricing laws and regulations. For example, since 2020 Hungary, Qatar, Cyprus, and Malta have adopted, or are in the process of adopting, transfer pricing laws and regulations. All of the aforementioned jurisdictions portray similarities: the adoption codifies the requirements for local and master files, the necessity of benchmark studies to establish pricing for inter-company transactions at arm‘s length, and in some cases, there is a requirement to file country-by-country reports.

It is globally accepted that this trend will continue.

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