Transfer pricing rules are tightening in parallel across the world, and March 2026 brought a fresh wave of obligations. Five jurisdictions — Colombia, Georgia, Poland, France and Latvia — introduced new reporting duties, thresholds or court rulings that reach any multinational with related-party dealings in those markets. The common thread is more disclosure, lower thresholds and less room for treating transfer pricing as an afterthought.
Key takeaways
- Colombia's tax authority, DIAN, requires large taxpayers to build transfer pricing adjustments into their 2025 income tax return under Article 260-3 of the Tax Code.
- Georgia's Order No. 52 introduces annual reporting for international controlled transactions above GEL 500,000, filed with the March tax declaration.
- Poland's Supreme Administrative Court confirmed that companies using the deferred "Estonian CIT" regime must still meet transfer pricing obligations.
- France aligned with the EU public country-by-country reporting directive for groups with global revenue above EUR 750 million.
- Latvia overhauled its framework from 1 January 2026, adding a Controlled Transactions Report for related-party dealings above EUR 250,000.
A jurisdiction-by-jurisdiction snapshot
Across the five markets, the changes run from Colombia folding TP adjustments into its 2025 return and Georgia's new GEL 500,000 reporting threshold to Poland's Estonian-CIT court ruling, France's EU public country-by-country reporting, and Latvia's new Controlled Transactions Report. Each carries its own trigger, threshold and deadline, set out in the table.
| Jurisdiction | Change | Threshold / trigger | Key action |
|---|---|---|---|
| Colombia | TP adjustments in 2025 return (Art. 260-3) | Large taxpayers | File via Form 2516, annexed to Form 110 |
| Georgia | Order No. 52 annual reporting | Above GEL 500,000 | File with March tax declaration |
| Poland | Court ruling on Estonian CIT | Thresholds met | Prepare Local File and TPR-C reports |
| France | EU public CbC reporting | Global revenue over EUR 750m | File machine-readable report in EU register |
| Latvia | New framework from 1 Jan 2026 | Non-resident dealings over EUR 250,000 | File Controlled Transactions Report within 12 months |
Colombia, Georgia and Poland: disclosure and enforcement
Colombia's DIAN now expects large taxpayers subject to the transfer pricing regime to incorporate the necessary adjustments directly into their 2025 income tax return, as required under Article 260-3 of the Tax Code to uphold the arm's length principle. Those adjustments must be reflected in the return and in Form 2516, the Fiscal Reconciliation Report annexed to Form 110, then disclosed again in the transfer pricing informative return due in September and documented in the local report.
Georgia's Order No. 52 creates a new annual reporting obligation for international controlled transactions, submitted alongside the March tax declaration for the prior year. Reporting is triggered once total value exceeds GEL 500,000 — a figure that includes transaction values, the market value of free goods or services, and outstanding payables and receivables. Taxpayers must disclose related parties, transaction types, amounts in both original currency and GEL, debt balances, and whether transfer pricing documentation exists.
Poland's development came through the courts. Its Supreme Administrative Court ruled that companies applying the deferred "Estonian CIT" regime are not exempt from transfer pricing rules; they must prepare Local File documentation and submit TPR-C reports where thresholds are met. The court confirmed that the regime remains part of the Corporate Income Tax Act, so in the absence of an explicit exemption, the arm's length principle continues to apply.
France and Latvia: public reporting and a new report
France adopted rules aligning national law with the EU public country-by-country reporting directive and introduced a multiple reporting exemption. The regime applies to multinational groups with global revenue above EUR 750 million, whose reports must be machine-readable, filed in an EU register and kept publicly accessible for five years. Companies must disclose corporate income tax information for each EU member state and for jurisdictions on the EU list of non-cooperative jurisdictions.
Latvia overhauled its transfer pricing framework with effect from 1 January 2026, through amendments to the Law "On Taxes and Fees." The centrepiece is a new Controlled Transactions Report (CTR) for companies whose related-party transactions with non-resident affiliates exceeded EUR 250,000 in the previous year. The CTR must be filed within 12 months of the financial year end through the State Revenue Service's Electronic Declaration System — and, importantly, it summarises key transaction data without replacing full transfer pricing documentation.
The direction of travel is unmistakable: lower thresholds, machine-readable filings and cross-border data sharing are making inconsistent transfer pricing far easier for authorities to spot.
Why these updates matter for Gulf groups
For UAE and wider Gulf-headquartered groups, the significance is not any single country's rule but the pattern. A group with subsidiaries or counterparties in any of these markets needs consistent transfer pricing positions and documentation that hold together across jurisdictions — because an inconsistency disclosed in one filing is increasingly visible to every other authority. In practice, the bigger exposure is rarely a single wrong price; it is a mismatched story, where the same transaction is described one way in a Latvian filing and another in the UAE Local File.
Frequently asked questions
What are the new transfer pricing rules in Latvia for 2026?
From 1 January 2026, Latvia requires a Controlled Transactions Report for companies whose transactions with non-resident related parties exceeded EUR 250,000 in the prior year. It is filed within 12 months of the financial year end through the State Revenue Service's Electronic Declaration System and supplements, but does not replace, full transfer pricing documentation.
Does Poland's Estonian CIT regime require transfer pricing compliance?
Yes. Poland's Supreme Administrative Court ruled that companies using the deferred Estonian CIT regime must still meet transfer pricing obligations, including Local File documentation and TPR-C reporting where thresholds apply. The regime remains within the Corporate Income Tax Act, so the arm's length principle continues to apply.
What is the threshold for transfer pricing reporting in Georgia?
Georgia's Order No. 52 triggers annual reporting once international controlled transactions exceed GEL 500,000. That total includes transaction values, the market value of free goods or services, and outstanding payables and receivables. The report is filed with the March tax declaration for the previous year.
What is EU public country-by-country reporting?
EU public country-by-country reporting requires multinational groups with global revenue above EUR 750 million to publish corporate income tax information by jurisdiction. Under the rules France adopted, reports must be machine-readable, filed in an EU register and remain publicly accessible for five years, covering each EU member state and listed non-cooperative jurisdictions.
How SBC Tax Consulting can help
SBC helps multinationals keep transfer pricing consistent across a shifting global map. We monitor jurisdictional changes, assess where new thresholds and filings bite, and prepare aligned transfer pricing documentation and international tax positions that stand up across borders. Whether you file in Riyadh, Dubai, Bogota or Riga, we keep your policy coherent and audit-ready. To review your multi-country exposure, contact our team.
This publication is for general information only and does not constitute professional advice. Please consult your SBC advisor before acting on any matter covered here.