Indirect Tax
The United States imposes new tariffs on import of medium/heavy-duty vehicles, parts, and buses w.e.f. 1 November
Excerpts from various sources
The U.S. has imposed 25% ad valorem duty on imports of medium / heavy-duty vehicles and their parts, while imported buses (10%) would attract 10% duty from 1 November 2025. In case of importers qualifying under United States-Mexico-Canada Agreement, the 25% tariff will apply only to the non-US content value as determined by the Secretary of Commerce. Manufacturers assembling medium / heavy duty vehicles in the US can apply for an import adjustment offset equal to 3.75% of the aggregate value of all vehicles assembled domestically during the specified period.
China suspends 24% retaliatory tariff on select imports from U.S. for 1 year; Maintains 10% on all goods
Excerpts from The Mint
China PR has suspended the 24% additional tariff on all goods imported from the U.S. beginning 10 November 2025, for one year. However, the country will retain a 10% import duty as a response to the US’ reciprocal tariff’ move.
UAE announces amendments to VAT laws to enhance efficiency; Sets clear timeframe for refunds
Excerpts from UAE MoF website
The UAE Ministry of Finance has issued key VAT law amendments (Decree-Laws 16 & 17 of 2025) on 25 November, which shall be effective from 1 January 2026. Changes include a 5-year limit for using/reclaiming excess input VAT, easier import-invoice rules, power to conduct tax audits or assessments after the expiry of limitation period in certain cases, as well as stronger anti-evasion measures.
Ireland introduces new VAT grouping rules affecting intra-group transactions and compliance strategies
Excerpts from various sources
The Irish Revenue has announced a major change to the VAT grouping rules w.e.f. 19 November 2025. From now, only establishments physically located in Ireland can form VAT groups, with overseas head offices or branches excluded from eligibility. New VAT groups created from 19 November must comply immediately, while existing groups have until 31 December 2026 to align with the rules. Resultantly, intra-group transactions involving non-Irish entities may now trigger VAT or reverse-charge obligations.
Transfer Pricing
Argentina Revises Cross-Border Reporting Rules Under Decree 767/2025
On 28 October 2025, the government of Argentina published Decree 767/2025 in the Official Gazette, bringing into effect a revised set of reporting requirements for cross-border transactions administered by Agencia de Recaudación y Control Aduanero (ARCA).
Under Decree 767/2025, the following principal changes to cross-border transaction reporting have been introduced:
- Higher exemption threshold for independent trade — Entities engaging in import and/or export of goods between independent third parties now enjoy an exemption from providing ARCA-required information if the annual value of their operations does not exceed USD 500 million.
- Relaxed transfer-pricing documentation obligations — The requirement to submit a transfer pricing study and a Master File will no longer apply where the aggregate value of related-party transactions abroad (or with entities in low/no-tax or non-cooperative jurisdictions) stays below USD 150 million per year, or USD 15 million per individual transaction.
- Expanded definition of “quoted goods” — The term now covers specialized public entities, broadening the scope of goods subject to the updated regulatory framework.
- Electronic contract registration for export operations — Export contracts for quoted goods must be registered electronically with ARCA no later than 60 days from the shipment date, consistent with specified procedures and timeframes.
- Clarification of market parameters — The decree clarifies the market parameters to be used when assessing transactions carried out in transparent markets, enhancing transparency and predictability in compliance.
The changes apply to fiscal years ending on or after 29 October 2025. Decree 767/2025 marks a meaningful shift in Argentina’s cross-border transaction reporting framework. By raising exemption thresholds, easing documentation requirements for transfer pricing, broadening definitions, and enforcing electronic contract registrations, the government aims to strike a balance between regulatory oversight and practical compliance for businesses.
Singapore Issues Eighth Edition of Transfer Pricing Guidelines (TPG8)
The Inland Revenue Authority of Singapore (IRAS) released the Eighth Edition of the Transfer Pricing Guidelines (TPG8) on 19 November 2025, introducing a series of amendments aimed at clarifying existing practices, reducing compliance burdens in targeted areas, and refining Singapore’s transfer pricing (TP) framework. The revised guidance applies to businesses with domestic and cross-border related-party transactions and represents a notable evolution of Singapore’s TP landscape.
A key development in TPG8 concerns domestic related-party loans entered from 1 January 2025, where neither party is in the business of borrowing or lending. Under prior guidelines (TPG7), taxpayers were required to apply IRAS’ indicative margin or conduct a TP analysis to determine interest rates. TPG8 eases these requirements wherein applying IRAS’ indicative margin is now optional. A TP analysis to determine interest rates is no longer mandatory. Additionally, IRAS will not make TP adjustments for these loans and TP documentation is not required for such arrangements.
TPG8 also expands the requirements for the annual review of related-party loans, both domestic and cross-border.
TPG8 reiterates IRAS’ authority to recharacterize or disregard funding arrangements that lack commercial rationality or diverge from what independent parties would agree to after considering realistic alternatives. Hybrid instruments may also be challenged under Section 33A of the Income Tax Act where tax avoidance is identified. This reinforces the need for robust characterization and documentation of financing transactions.
While eligibility criteria for Simplified TP Documentation (STPD) remain unchanged, TPG8 introduces an important procedural clarification, wherein taxpayers must expressly declare that qualifying past TP documentation exists. This change ensures consistency and reliability in the use of simplified documentation.
Additionally, in alignment with the OECD BEPS 2.0 initiative, IRAS launched a three-year pilot of the Simplified and Streamlined Approach (SSA) - Singapore’s implementation of Amount B - for qualifying marketing and distribution activities, effective 1 January 2026 to 31 December 2028.
Furthermore, TPG8 introduces several other updates, including:
- Clarified procedures for disputing TP adjustments.
- Detailed articulation of the protective Mutual Agreement Procedure (MAP).
- Clarifications on strict pass-through costs, including documentation expectations.
- Confirmation that interest-free cross-border loans where Singapore is the lender will not attract TP adjustments.
TPG8 demonstrates IRAS’ continued focus on intercompany financing, enhanced TP governance, and alignment with global developments. While the guidelines introduce meaningful compliance relief in specific areas - particularly domestic related-party loans - they also heighten expectations for documentation, characterization, and monitoring of related-party arrangements.
Businesses operating in Singapore should review their existing TP practices to ensure alignment with the updated framework and consider the potential benefits of the SSA pilot for distribution-related transactions.