Transfer Pricing 2026

Definitive global law guides offering comparative analysis from top-ranked lawyers


INTRODUCTION
5

Contributed by Paolo Ludovici, Luca Tortorella, Marlinda Gianfrate and Angelica Masciulli, Gatti Pavesi Bianchi Ludovici
5

AUSTRIA
11

Law and Practice
11

Contributed by Grant Thornton Austria
11

Trends and Developments
24

Contributed by Grant Thornton Austria
24

BRAZIL
30

Law and Practice
30

Contributed by William Freire Advogados
30

CYPRUS
51

Law and Practice
51

Contributed by Kinanis LLC
51

Trends and Developments
62

Contributed by Kinanis LLC
62

EUROPE-WIDE
67

Trends and Developments
67

Contributed by TPA Global
67

FRANCE
74

Law and Practice
74

Contributed by &Co Advisory
74

Trends and Developments
92

Contributed by &Co Advisory
92

ITALY
98

Law and Practice
98

Contributed by Maisto e Associati
98

Trends and Developments
117

Contributed by Gatti Pavesi Bianchi Ludovici
117

LUXEMBOURG
124

Law and Practice
124

Contributed by ATOZ Tax Advisers
124

Trends and Developments
141

Contributed by ATOZ Tax Advisers
141

MEXICO
145

Law and Practice
145

Contributed by QCG Transfer Pricing
145

NETHERLANDS
162

Law and Practice
162

Contributed by Borgen Tax
162

Trends and Developments
179

Contributed by RED Transfer Pricing
179

PERU
185

Law and Practice
185

Contributed by +Value
185

SOUTH KOREA
201

Law and Practice
201

Contributed by Lee & Ko
201

Trends and Developments
221

Contributed by Yoon & Yang LLC
221

SPAIN
228

Law and Practice
228

Contributed by Cuatrecasas
228

Trends and Developments
240

Contributed by Cuatrecasas
240

SWITZERLAND
248

Law and Practice
248

Contributed by Tax Partner AG
248

Trends and Developments
268

Contributed by Tax Partner AG
268

UAE
274

Law and Practice
274

Contributed by Kinanis Tax Consultancy Middle East Limited
274

Trends and Developments
285

Contributed by Kinanis Tax Consultancy Middle East Limited
285

USA
290

Law and Practice
290

Contributed by White & Case LLP
290

Trends and Developments
302

Contributed by White & Case LLP
302

ZAMBIA
308

Law and Practice
308

Contributed by Mulenga Mundashi Legal Practitioners
308

Trends and Developments
321

Contributed by Mulenga Mundashi Legal Practitioners
321

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