Key changes
Parliament approved significant amendments to the Tax Code affecting corporate income tax, VAT, and transfer pricing.
Effective dates and transition rules vary by provision; some measures take effect on January 1, 2026.
Corporate income tax and TP
The reforms adjust deductibility rules, thin capitalization, and controlled transaction thresholds.
Updated documentation requirements and penalties raise the bar for compliance planning.
VAT changes
Clarifications on place of supply, input VAT recovery, and exemptions impact cross-border supply chains.
Systems and contracts should be reviewed to align pricing and invoicing with new rules.
Next steps for taxpayers
Companies should run gap assessments, update policies, and prepare for audits, with particular focus on transfer pricing documentation.
Our tax team can assist with impact analysis and implementation.