Transfer Pricing
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UK Launches Open Consultation on Transfer Pricing, Permanent Establishment and Diverted Profits Tax
Stakeholders are invited to review the draft legislation and submit…
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Turkey Decides Not to Implement OECD’s Amount B for Now
Amount B will not be applied to transactions involving distributors,…
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Council Reaches Political Agreement on DAC9
MNEs will be required to submit their first top-up tax…
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Pillar One Amount B: Key Update on Marketing and Distribution Activities
Jurisdictions can adopt OECD’s Latest Guidelines on the Amount B…
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India Unveils Union Budget 2025 with Tax Reforms reinforcing ambition to become a global investment and financial hub
New Income Tax Bill on the horizon, push for certainty…
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Accenture Secures Landmark Victory in the Danish Supreme Court
First Ruling Favoring a Taxpayer in a Transfer Pricing Case
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US: IRS Outlines Plans on Simplified Approach for Pricing Controlled Transactions Involving Marketing and Distribution activities
Notice 2025-4 Aligns with OECD Report on Amount B of…
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Transfer Pricing and Tax Compliance in Morocco: Navigating the Evolving Landscape
An In-depth Exploration of Morocco’s Transfer Pricing Regulations, OECD Alignment,…
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UAE Implements Domestic Minimum Top Up Tax
Ministry of Finance Announces Updates to Corporate Tax Law Affecting…
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Germany’s New Transfer Pricing Compliance Rules for 2025
Stricter deadlines, higher penalties effective January 1, 2015
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OECD 2023 MAP & APA Awards: Discover the Fastest, Most Efficient amongst OECD Countries
Announced at the 2024 OECD Tax Certainty Day, celebrating jurisdictions…
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Navigating the ESG Landscape: Transfer Pricing in a Sustainable World
Exploring how ESG principles are reshaping business practices and financial…
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Australia: Insights on Tax Settlements and Compliance in 2023–24 for Public and Multinational Businesses
Litigation resulted in favorable outcome for ATO in 53% of…
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Direct Tax | E-Invoicing and E-Reporting | Indirect Tax | Latest News | Tax Policy | Transfer PricingDeep Dive into Tax Measures from UK´s Autumn 2024 Budget
Alongside the many announced changes, key highlights include efforts to…
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Australia: Changes to Country-by-Country Local File Reporting
Effective from 1 January 2025, most significant change to CbC …
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EU Reaffirms Commitment to Inclusive and Effective International Tax Cooperation
EU has approved its official position concerning UN Framework Convention…
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EU Court Confirms Legality of Dutch Law Limiting Interest Deduction on Intra-Group Loans
Judgment of the Court of Justice of the European Union…
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US IRS Updates on Transfer Pricing Penalties
Stricter Enforcement and Documentation Standards
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OECD/G20 Inclusive Framework Introduces Model Competent Authority Agreement
Aimed at Facilitating Amount B Implementation, simplified and streamlined pricing…
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Peru Clarifies Informative Affidavit Requirements for Goods´ Transactions with Related Parties
English Translation of Guidelines Available Here!
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Apple Case: Ireland´s reaction to getting 13 bln EUR richer
Transferring the assets in the Escrow Fund to Ireland will…
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UK´s HMRC Published Guidelines for Transfer Pricing Compliance for UK Businesses
Best practice approaches to Transfer Pricing to lower risk and…
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Brazil: Key Tax and Regulatory Changes Announced
Multiple Tax developments in Brazil by the end of August:
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German Tax Court Decision on Principal Model Without Exit Tax
Case Overview: US Multinational’s European Reorganization
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Brazil’s Normative Instruction on Transfer Pricing Rules- Available to Download Here!
English and Portuguese versions available!
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UN Tax Framework Convention: the final text of the Terms of Reference (TOR) adopted with notable votes against or abstention
A path to a universally accepted and effective international tax…
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OECD Publishes Transfer Pricing Framework for Lithium
Essential for ensuring that developing countries can tax lithium exports…
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Coca-Cola to Pursue Appeal Following Tax Court Decision
$16 billion of Potential Incremental Tax and Interest Liabilities
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United Nations Committee of Experts on International Cooperation in Tax Matters: Transfer Pricing Compliance Assurance Toolkit; Transfer Pricing during the COVID-19 economic downturn
Shaping Global Tax Norms and Addressing Transfer Pricing Challenges
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European Union: Draft Regulation on Corporate Income Tax Reporting establishes Common Template and Electronic Formats
New regulation aims to enhance tax transparency and comparability across…
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Renewal of Qualified Maquiladora Approach Agreement Between U.S. and Mexico in 2024
This is the second renewal of the agreement, preserving the…
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European Court of Justice: Upholding the EU Directive on Tax Reporting Obligations
CJEU upholds EU directive on tax reporting for cross-border arrangements.…
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European Union: Evaluation of the Anti-Tax Avoidance Directive In Progress
Have Your Say on the Directive aimed to fight aggressive…
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Constitutional Court Rules Mandatory Disclosure Rules (MDR) Unconstitutional
What a month for Mandatory Disclosure Rules (MDR) in Poland!
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Poland: First Ruling on Mandatory Disclosure Rules (MDR)
First MDR interpretation issued after 5-year wait. Director of National…
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Belgium Updates Transfer Pricing Documentation Requirements
Mandatory from FY 2025
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Revised Draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation
Priorities include Taxation of the digitalized and globalized economy; income…
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Australia: PepsiCo’s Royalty Withholding and Diverted Profits Tax Decision Overturned
Full Federal Court Reverses Federal Court Decision on Embedded Royalty.
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Belgium: Administrative Tolerance for 2024 Moves Registration Requirement under Pillar 2 Regulations
Only applicable to groups that will not make Belgian advance…
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New Transfer Pricing Framework Introduced in Brazil
Aligned with OECD Guidelines
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OECD/G20 Inclusive Framework on BEPS Releases Updates on:
Pillar One and Pillar Two Tax Measures, CbCR Safe Harbour…
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Australia: Public Country-by-Country Reporting Legislation Introduced to the Parliament
If approved, public CbC reporting will be effective for reporting…
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US Efforts to Preserve Global Corporate Tax Deal Face Challenges
Pillar 1 encounters roadblocks
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Inclusive Framework on BEPS Targets Multilateral Convention Signature by End of June
Advancing towards a final agreement on Pillar One, the anticipated…
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EU Council Decision to Open Negotiations for amendment of the Agreements concerning the automatic exchange of financial account information to improve international tax compliance
Concerns negotiations between European Union and the Swiss Confederation, the…
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Belgium: Pillar Two Mandatory Notification for MNEs and Large Domestic Groups
On May 21, 2024, the Belgian tax administration released new…
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Belgian Parliament Adopts New Pillar Two Law with Key Modifications
Rectification of prior legislative oversights identified in the original December…
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OECD publishes 334 pages Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2023)
Tax Challenges Arising from the Digitalisation of the Economy.
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OECD/G20 Inclusive Framework on BEPS released the report on Amount B of Pillar One
A simplified approach to applying the arm’s length principle to…
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European Union: Proposal on Transfer Pricing Adjustments: Understanding Primary, Corresponding, and Compensating Adjustments
Explanatory Memorandum on the Proposal of Council Directive on Transfer…
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Enhancing Tax Transparency: Australia’s New Requirements for Disclosure of Subsidiaries in Financial Reports
Aiming at greater transparency and accountability in corporate tax matters
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India’s Advance Pricing Agreement (APA) Programme: The Comprehensive Procedural Framework
A structured and proactive approach to transfer pricing certainty
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European Union: Progress on the EU Council Directive on Transfer Pricing
The directive should apply from 1 January 2025 (instead of…