Transfer Pricing

OECD BEPS | Turkey

Amount B will not be applied to transactions involving distributors, sales agents, and brokers operating in Turkey

EU | Transfer Pricing

MNEs will be required to submit their first top-up tax information return by 30 June 2026, tax authorities will need to exchange this information by 31 December 2026

OECD | Transfer Pricing

Jurisdictions can adopt OECD’s Latest Guidelines  on the Amount B approach for relevant transactions starting from fiscal years commencing on or after January 1, 2025

India | Tax Policy

New Income Tax Bill on the horizon, push for certainty and economic expansion, focus on manufacturing incentives and IFSC growth

Denmark | Transfer Pricing

First Ruling Favoring a Taxpayer in a Transfer Pricing Case

US | Transfer Pricing

Notice 2025-4 Aligns with OECD Report on Amount B of Pillar 1, Launching For Comments 

Morocco | Transfer Pricing

An In-depth Exploration of Morocco’s Transfer Pricing Regulations, OECD Alignment, and Implications for Businesses

UAE | Direct Tax

Ministry of Finance Announces Updates to Corporate Tax Law Affecting Multinationals

Germany | Transfer Pricing

Stricter deadlines, higher penalties effective January 1, 2015

OECD | Transfer Pricing

Announced at the 2024 OECD Tax Certainty Day, celebrating jurisdictions that showcased excellence in resolving tax disputes through the Mutual Agreement Procedure (MAP) and Advance Pricing Agreements (APA)

ESG Principles

Exploring how ESG principles are reshaping business practices and financial strategies in the global economy.

Australia | Direct Tax

Litigation resulted in favorable outcome for ATO in 53% of cases, Settlements involving income tax and transfer pricing secured ATO 69% of disputed amounts 

UK | Tax Policy

Alongside the many announced changes, key highlights include efforts to close the tax gap, investments in HMRC and technology, as well as plans for e-invoicing and transfer pricing

Australia | Transfer Pricing

Effective from 1 January 2025, most significant change to CbC  reporting to-date

European Union Tax Policy

EU has approved its official position concerning UN Framework Convention on International Tax Cooperation.

EU | Transfer Pricing 

Judgment of the Court of Justice of the European Union in Case C-585/22

US | Transfer Pricing

Stricter Enforcement and Documentation Standards

OECD BEPS

Aimed at Facilitating Amount B Implementation, simplified and streamlined pricing approach for baseline marketing and distribution activities.

Peru | Customs | Transfer Pricing

English Translation of Guidelines Available Here!

Ireland | Direct Tax

Transferring the assets in the Escrow Fund to Ireland will take several months to complete

UK | Transfer Pricing 

Best practice approaches to Transfer Pricing to lower risk and avoid common mistakes

Brazil | Transfer Pricing

Multiple Tax developments in Brazil by the end of August:

Germany | Transfer Pricing

Case Overview: US Multinational's European Reorganization

Brazil | Transfer Pricing

English and Portuguese versions available!

UN | International Tax

A path to a universally accepted and effective international tax framework remains complex

OECD | Transfer Pricing

Essential for ensuring that developing countries can tax lithium exports appropriately

US | Transfer Pricing

$16 billion of Potential Incremental Tax and Interest Liabilities

European Commission | Country by Country Reporting

New regulation aims to enhance tax transparency and comparability across EU. Affects MNCs with €750M+ revenue. Feedback period now open.

United Nations | Transfer Pricing

Shaping Global Tax Norms and Addressing Transfer Pricing Challenges

US | Mexico | Transfer Pricing

This is the second renewal of the agreement, preserving the core elements of the original framework 

European Union | Court of Justice

CJEU upholds EU directive on tax reporting for cross-border arrangements. Ruling addresses scope, clarity of terms, legal privilege, and proportionality. Balances tax enforcement with fundamental rights protection. Belgian case prompted preliminary ruling.

European Union | Tax Avoidance 

Have Your Say on the Directive aimed to fight aggressive tax planning and tax avoidance

Poland | Mandatory Disclosure Rules 

What a month for Mandatory Disclosure Rules (MDR) in Poland!

Poland | Mandatory Disclosure Rules

First MDR interpretation issued after 5-year wait. Director of National Tax Information breaks silence, potentially opening doors for more MDR clarifications. Taxpayers anticipate increased guidance on complex tax scheme reporting.

United Nations | International Tax

Priorities include Taxation of the digitalized and globalized economy; income derived from cross-border services, high-net-worth individuals

Belgium | Transfer Pricing

Mandatory from FY 2025

Australia | Direct Tax | Transfer Pricing

Full Federal Court Reverses Federal Court Decision on Embedded Royalty.

Belgium | CIT | Transfer Pricing

Only applicable to groups that will not make Belgian advance payments for the 2024 QDMTT and/or 2024 IIR

Brazil | Transfer Pricing

Aligned with OECD Guidelines

OECD BEPS

Pillar One and Pillar Two Tax Measures, CbCR Safe Harbour Guidance, Qualified Status 

Australia | CIT

If approved, public CbC reporting will be effective for reporting periods starting on or after 1 July 2024

OECD Pillar 1

Pillar 1 encounters roadblocks

OECD BEPS

Advancing towards a final agreement on Pillar One, the anticipated signing of the Multilateral Convention by the end of June

EU | CIT

Concerns negotiations between European Union and the Swiss Confederation, the Principality of Liechtenstein, the Principality of Andorra, the Principality of Monaco and the Republic of San Marino

Belgium | Pillar 2

On May 21, 2024, the Belgian tax administration released new guidance on mandatory registration requirements

Belgium | BEPS

Rectification of prior legislative oversights identified in the original December 19, 2023 Pillar Two law

OECD BEPS

Tax Challenges Arising from the Digitalisation of the Economy.

OECD Amount B of Pillar One

A simplified approach to applying the arm's length principle to baseline marketing and distribution activities.

European Union | Transfer Pricing

Explanatory Memorandum on the Proposal of Council Directive on Transfer Pricing

Australia | Direct Tax

Aiming at greater transparency and accountability in corporate tax matters

India | Transfer Pricing

A structured and proactive approach to transfer pricing certainty 

EU | Transfer Pricing

The directive should apply from 1 January 2025 (instead of 1 January 2026).