Transfer Pricing in 2025: What Exporters and Importers Need to Know?
Transfer pricing (TP) remains one of the key issues for companies engaged in foreign economic activity in 2025. New requirements, updated jurisdiction lists, and increased control from tax authorities demand an even more meticulous approach to transaction documentation.
What Has Changed in 2025? Key Updates in Transfer Pricing
1️⃣ Updated List of Countries (Territories) for TP Purposes
✔️ The government has reduced the list of countries whose transactions are considered controlled. The number has dropped from 78 to 46.
✔️ Countries with which double taxation agreements have been signed (Cyprus, Ireland, UAE, Morocco, Moldova, etc.) have been removed from the list.
✔️ Jurisdictions classified as offshore zones or limiting tax information exchange remain on the list.
2️⃣ Strengthened Control Over Transactions With Related Parties
✔️ The threshold for corporate rights ownership to qualify as a related party has been increased from 20% to 25%.
✔️ An economic relatedness criterion has been added: if transactions with a single non-resident exceed 75% of the company’s total revenue or expenses.
3️⃣ Impact of Changes on Controlled Transactions
✔️ Transactions with companies in “low-tax” jurisdictions may be subject to additional control.
✔️ The verification of compliance with market prices has become stricter.
✔️ New criteria for determining tax residency for individuals have been introduced.
How Will the New Rules Affect Exporters and Importers?
Companies involved in export-import operations should consider the following risks:
- Counterparties in “high-risk” jurisdictions. If your company cooperates with entities that remain on the government’s list, transactions with them may be classified as controlled, requiring additional reporting.
- Documentary evidence of economic feasibility. All transactions must have a market-based justification (comparable transactions in the open market, comparable pricing, etc.).
- Internal procedures review. Businesses should regularly audit their transfer pricing and pricing mechanisms for goods and services.
What Should Businesses Do to Comply With the New Requirements?
🔎 1. Analyze Your Operations
Check your counterparties:
✔️ Are they located in “low-tax” jurisdictions?
✔️ Do they qualify as related parties under the updated criteria?
📑 2. Update Documentation
✔️ Prepare updated contracts and market price calculations.
✔️ Conduct an arm’s length principle compliance check.
✔️ Ensure reporting meets the updated requirements.
📊 3. Implement Internal TP Controls
✔️ Regularly review financial flows and reporting.
✔️ Use monitoring tools to assess compliance with market conditions.
🛡️ 4. Seek Professional Consultation
✔️ Conduct an audit of your transfer pricing policies considering the new requirements.
✔️ Get expert advice on optimizing international transactions and tax burdens.
Conclusion
Transfer pricing in 2025 is subject to stricter control, requiring businesses to exercise caution and maintain thorough transaction documentation. Given the updated related-party criteria and expanded oversight of “high-risk” jurisdictions, companies must adapt their internal processes to mitigate additional tax risks.
A meticulous approach to transaction documentation, regular monitoring of legislative changes, and professional support will help reduce audit risks, avoid penalties, and ensure compliance with international standards.
📞 Do you have questions about transfer pricing in 2025? Schedule a consultation to get personalized recommendations!
